Volume 3 of 5

Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan 

And

Final Environmental Impact Statement 

U.S. Department of the Interior 

Bureau of Land Management 

Billings Field Office, Montana 

June 2015 
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Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Table of Contents – Volume 3

Chapter 5: Consultation and Coordination

5 Consultation and Coordination..........................................................................................................5-1

5.1 Introduction.........................................................................................................................5-1

5.2 Public Participation Opportunities ......................................................................................5-1

5.2.1 Scoping .................................................................................................................5-2

5.2.2 Transportation Planning Workshops.....................................................................5-3

5.3 Consultation and Coordination............................................................................................5-3

5.3.1 Tribal Consultation ...............................................................................................5-3

5.3.2 Tribal Consultation Responsibilities.....................................................................5-4

5.3.3 U.S. Fish and Wildlife Service Consultation ........................................................5-5

5.3.4 State Historic Preservation Office Consultation ...................................................5-6

5.3.5 Resource Advisory Council ..................................................................................5-6

5.3.6 Cooperating Agencies...........................................................................................5-7

5.3.7 Informal Consultation and Coordination ..............................................................5-8

5.4 Plan Distribution .................................................................................................................5-9

5.5 Public Comment Period on the Draft RMP and EIS .........................................................5-16

5.5.1 Notification .........................................................................................................5-17

5.5.2 Public Meetings ..................................................................................................5-17

5.5.3 Comment Analysis..............................................................................................5-18

5.5.4 Comment Analysis Process.................................................................................5-19

5.5.5 Summary of Public Comments: Personal Opinions/Preferences and 

Outside the Scope of this Document...................................................................5-20

5.5.6 BLM Review and Response to Comments .........................................................5-23

5.5.7 Other Public Involvement...................................................................................5-35

5.5.8 List of Preparers..................................................................................................5-36

5.5.9 Responses to Public Comments..........................................................................5-42

References........................................................................................... Ref-1

Glossary ...................................................................................................1

Appendix A: Laws, Regulations, Policies, and Guidance

Appendix B: Best Management Practices (BMPs)

Appendices C-O are located in Volume 4

Appendices P-Z, AA, AB, and AC are located in Volume 5

Maps are located in Volume 5

Table of Contents i
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Proposed Resource Management Plan and Final Environmental Impact Statement

List of Tables – Volume 3

Table 5-1 Federal, Tribal, State and Local Representatives Invited to Participate As Cooperating 

Agencies for the Billings and Pompeys Pillar National Monument RMP/EIS ..........................5-9

Table 5-2 BLM Open House Meeting Locations – Draft RMP/EIS.........................................................5-17

Table 5-3 Issue Categories .......................................................................................................................5-18

Table 5-4 Commenter Index.....................................................................................................................5-25

Table 5-5 Billings and Pompeys Pillar National Monument RMP/EIS Preparers....................................5-37

Table 5-6 Montana State Office Reviewers..............................................................................................5-40

Table 5-7 Cooperating Agencies and Contacts.........................................................................................5-41

Table 5-8 BLM Response to Public Comments ...............................................................................................5-42

ii Table of Contents
CHAPTER 5:

CONSULTATION 

AND

COORDINATION

CHAPTER 5:

CONSULTATION 

AND

COORDINATION

Burnt Timber Road (PMWHR)
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Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-1

5 Consultation and Coordination

5.1 Introduction

This chapter describes the public participation opportunities made available through the 

development of the Billings/Pompeys Pillar Draft Resource Management Plan and 

Environmental Impact Statement (RMP/EIS). This chapter also describes the consultation that 

occurred and collaborative efforts with various entities, including the State of Montana; the 

eight counties in the planning area; the Tribes; and the U.S. Fish and Wildlife Service. A 

distribution list included in this chapter identifies agencies, congressional staff, businesses and 

organizations that were sent a copy of the Draft RMP/EIS. 

The Draft RMP/EIS was prepared by an interdisciplinary team of resource specialists, 

identified at the end of this chapter, from the Billings Field Office and Montana State Office. 

Technical review and support were provided by the field office, cooperators and the State of 

Montana.

Fifteen agencies, counties and tribal representatives participated in the development of the 

Draft RMP/EIS as cooperating agencies, including the Northern Cheyenne Tribe, the Bureau of 

Indian Affairs, the Bureau of Reclamation, Montana Fish, Wildlife and Parks, the Montana 

State Historic Preservation Officer, the Department of Natural Resources and Conservation 

(Northeastern Land Office and Southern Land Office), Montana Association of Counties, and 

the following Montana counties: Carbon County, Golden Valley County, Musselshell County, 

Wheatland County, Musselshell Planning Project, Yellowstone County, and Big Horn County, 

Wyoming. The Eastern Montana Resource Advisory Council also participated, and a 

discussion of their involvement is included later in this chapter.

Members of the interdisciplinary planning team have consulted formally and informally with 

numerous agencies, groups and individuals during the preparation of this document. 

Consultation, coordination and public involvement occurred as a result of scoping meetings, 

briefings and meetings with federal, state tribal and local government representatives, informal 

meetings and individual contacts. 

5.2 Public Participation Opportunities

A number of opportunities were available in an effort to inform and involve the public about 

the planning process and participate in the development of the plan prior to release of the Draft 

RMP/EIS for public review and comment. A press release with regional distribution was 

issued at the start of the scoping and travel management meetings. In addition, a scoping 

package and a newsletter/update were distributed to the general mailing list and posted on the 

website. The scoping package announced the start of the planning process and informed the 

public of the various stages of the planning process and request comments and information. 

The first newsletter, distributed after the formal scoping period, provided the public with an 

update and progress of the planning process, as well as to announce the travel planning 

meetings. In addition to informing the public through newsletters/mailers, a website for the 

Billings/Pompeys Pillar RMP was launched to provide the public access to planning 
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5-2 Chapter 5: Consultation and Coordination

documents, calendars, information on the planning process, as well as a photo gallery of the 

planning area. The website is continually updated to provide status reports and new 

information throughout the planning process. 

The major public participation events are described in more detail below. 

5.2.1 Scoping

The scoping process identifies land use issues, conflicts and opportunities. These issues may 

stem from new information or changed circumstances, the need to address environmental 

protection concerns, or a need to reassess the appropriate mix of allowable uses based on new 

information. 

Scoping is the first stage of the planning process and closely involves the public with 

identifying issues, providing resource and other information, and developing planning criteria 

to guide preparation of the document. A Notice of Intent to prepare the Draft RMP/EIS was 

published in the Federal Register on May 15, 2008. This notice served as the beginning of 

BLM’s formal scoping process. A news release was distributed to various media points on 

May 16, 2008, announcing the public the formal public scoping and comment period. 

A scoping package for the Draft RMP/EIS was mailed in May 2008, to 1,205 individuals 

comprised of potential stakeholders, agencies, organizations and tribes. The newsletter 

introduced the BLM and the RMP planning process, and included a general description of the 

planning area. The scoping package also provided information regarding the preliminary 

planning issue themes, planning criteria, and project milestones timeline; and suggested 

methods for public involvement. The scoping package included a postage-paid self-mailer 

comment form was included in the newsletter to allow the public to easily submit their 

comments and/or information. 

The BLM hosted seven public open houses during August 2008 to provide the public with 

opportunities to become involved in the process; learn about the project and planning process, 

meet the RMP team members and resource specialists, and to offer comments. A news release 

was issued to various media points on August 4, 2008, announcing the open houses. Fliers that 

included information about the BLM open house meetings were posted in local communities 

throughout the planning area. The open houses were held at the following locations: Pompeys 

Pillar National Monument; Bridger; Big Timber; Red Lodge; Lovell, Wyoming; Roundup; and 

Billings. The open house format allowed attendees to learn about the planning project and 

general information about the planning area, as well as provided a setting for the attendees to 

visit with resource specialists and submit comments. Fact sheets were made available to 

attendees, and included information about the planning process, preliminary planning issues 

and general information about the area. Site and resource maps and posters were displayed 

illustrating the current situation and management techniques practiced among different 

resources and land areas. A total of about 90 participants attended the open houses. 

A total of 129 separate written submissions were received. Most written submissions included 

numerous comments; therefore the 129 submissions reflected a total of 575 separately-coded 

comments.
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5.2.2 Transportation Planning Workshops

In addition to scoping, four travel planning workshops were held during June 2009. The 

workshops were held in Lovell, Wyoming; and in Bridger, Roundup and Billings, Montana. A 

news release was distributed to the media on May 18, 2009, announcing the workshops. A 

newsletter, distributed to 1,524 stakeholders, agencies and tribes, also announced the 

transportation workshops. A fact sheet was available at the workshops that provided 

information on travel management. The workshops provided the public an opportunity to 

review road and trail data on BLM public lands and to offer comments on the transportation 

network. A total of 39 individuals attended the transportation workshops. 

5.3 Consultation and Coordination

5.3.1 Tribal Consultation

The laws requiring Native American consultation are as follows: National Historic 

Preservation Act, as amended, National Environmental Policy Act, American Indian Religious 

Freedom act, and Native American Graves Protection and Repatriation Act. The 1992 NHPA 

amendments place major emphasis on the role of Native American groups in the Section 106 

review process. Subsequent revisions to the regulations of the ACHP published August 5, 2004, 

incorporate specific provisions for federal agencies to involve Native American groups in land 

or resource management decisions and for consulting with these groups throughout the process. 

Before making decisions or approving actions that could result in changes in land use, physical 

changes to lands or resources, changes in access or alienation of lands, federal managers must 

determine whether Native American interests would be affected, observe pertinent consultation 

requirements, and document how this was done. The consultation record is the federal agency’s 

basis for demonstrating that the responsible manager has made a reasonable and good faith 

effort to obtain and consider appropriate Native American input in decision making.

General directions for Section 106 tribal consultation are as follows (also see BLM Handbook 

8120):

1) The federal agency must consult with any Native American group that attaches 

religious and cultural significance to historic properties that may be affected by 

an undertaking regardless of location.

2) The agency must make a reasonable and good faith effort to identify Native 

American groups to be consulted.

3) The agency must be respectful of tribal sovereignty in conducting consultation.

4) The agency must recognize the government-to-government relationship.

5) Historic properties of religious and cultural significance may be located on 

ancestral, aboriginal, or ceded lands of Native Americans.
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6) The Native American group may enter into agreement with the agency regarding 

any aspect of tribal participation in the Section 106 review process. The 

agreement may specify a tribe’s geographic area of interest, types of projects 

about which they wish to be consulted, or provide the tribe with additional 

participation or concurrence in agency decisions under Section 106 provided 

that no modification is made to the roles of other parties without their consent.

The BLM acknowledges all Native American tribes that have historically and traditionally used 

land in the planning area and treats federally recognized tribes as sovereign nations. The BLM 

has initiated consultation with the Northern Cheyenne and Crow Tribes. An important 

component of this process is to continue to foster meaningful relationships with these tribes to 

understand and incorporate tribal culture, resources, needs, interests, and expectations into the 

RMP revision process.

5.3.2 Tribal Consultation Responsibilities 

As a federal agency, the BLM is mandated to consult with American Indian tribes concerning 

the identification of cultural values, religious beliefs, and traditional practices of American 

Indian people, as well as other possible environmental and social concerns that may be affected 

by actions on federal lands. Tribal consultation is the active, affirmative process of: 1) 

identifying and seeking input from appropriate American Indian governing bodies, community 

groups, and individuals; and 2) considering their interests as a necessary and integral part of the 

BLM’s decision making process. The aim of consultation is to involve affected American 

Indian groups in the identification of issues and the definition of the range of acceptable 

management options. 

Tribal consultation includes the identification of places (i.e., physical locations) of cultural 

value to American Indian groups. Places that may be of cultural value include, but are not 

limited to, locations associated with the traditional beliefs concerning tribal origins, cultural 

history, or the nature of the world; locations where religious practitioners go, either in the past 

or the present, to perform ceremonial activities based on traditional cultural rules or practice; 

ancestral habitation sites; trails; burial sites; and places from which plants, animals, minerals, 

and waters possessing healing powers or used for other subsistence purposes, may be taken. 

Additionally, some of these locations may be considered sacred to particular American Indian 

individuals or tribes. Under the auspices of the American Indian Religious Freedom Act of 

1978, Executive Order 13007, the Native American Graves Protection and Repatriation Act of 

1990, and the National Historic Preservation Act, as amended, the BLM must take into account 

the effects of land use decisions on these types of locations. See Traditional Cultural Properties 

under Section 3.9, Cultural Resources, for a summary on tribal consultation conducted as part 

of the RMP/EIS process.

The BLM works in cooperation with American Indian tribes to coordinate and consult before 

making decisions or approving actions that could result in changes in land use, physical 

changes to lands or resources, changes in access, or alienation of lands. The Federal Land 

Policy and Management Act and the National Historic Preservation Act of 1966, as amended, 

require coordination with tribes in preparing and maintaining inventories of the public lands 

and determining their various resources and other values, developing and maintaining long-
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range plans providing for the use of the public lands, and managing the public lands. Federal 

programs are required to be carried out in a manner sensitive to American Indian concerns and 

tribal government planning and resource management programs

In accordance with the National Historic Preservation Act and the recognition of the 

government-to-government relationship between tribes and the federal government, letters were 

sent to seventeen tribal governments and officials at the start of the planning process on March 

25, 2008, to inform them of the Billings/Pompeys Pillar National Monument RMP/EIS and an 

opportunity to partner with the BLM as a cooperating agency. The letters also requested their 

input on issues and concerns to be considered during the planning process for the RMP/EIS. A 

second, follow-up letter was sent to the tribes on June 10, 2008. The Northern Cheyenne Tribe 

requested to serve in the capacity as a formal cooperating agency. While no other tribes 

became an official cooperating agency, coordination has continued through letters and updates 

(refer to Table 5-1). The opportunity for meetings and briefings will occur with the release of 

the RMP/EIS and will occur throughout the RMP process.

The coordination and consultation process was initiated with mail correspondence. Letters 

were posted describing the RMP/EIS process and soliciting input from the tribes and 

individuals. The letters also offered an invitation to meet with each tribe individually to clarify 

the RMP process as well as solicit concerns of tribal members. These letters were followed by 

a second letter again offering the same. 

During development of the Alternatives, the seventeen tribes were sent copies of Chapter 2 for 

their review. All documents sent to the Cooperators throughout the planning process were also 

sent to the seventeen tribes requesting their review/comments. 

5.3.3 U.S. Fish and Wildlife Service Consultation

Federal agencies are required to comply with the provisions of the Endangered Species Act of 

1973, as amended. This includes a requirement to consult with the U.S. Fish and Wildlife 

Service (USFWS) on any action that may affect species listed as threatened and endangered or 

result in destruction or adverse modification of habitat designated as critical for listed species. 

In addition, federal agencies must confer with the USFWS on any action that is likely to 

jeopardize the continued existence of any species proposed to be listed or any action that may 

result in the destruction or adverse modification of critical habitat proposed to be designated for 

listed species.

This RMP/EIS is considered to be a major project and this document describes potential 

impacts to threatened and endangered species as a result of management actions proposed in 

the RMP. Contacts were made with the USFWS early in the planning process. An initial list of 

federally listed threatened or endangered plant, animals, or fish species or habitats present in 

the Billings Field Office planning area was requested in May 29, 2008, with additional followup in November 2009. On January 11, 2010, the USFWS provided input for the RMP/EIS on 

species that are currently listed as threatened, endangered, proposed, or candidates for 

protection under the Endangered Species Act, as well as input on migratory birds. There are 

two federally listed threatened wildlife species and two endangered species that either occur in 

the planning area or use habitat found within the planning area. These include: black-footed 
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ferret (endangered/non-essential experimental population), grizzly bear (threatened), Canada 

lynx (threatened/non-essential experimental population), and whooping crane (endangered). 

While the USFWS declined to serve as a formal cooperating agency during the planning 

process at the local level, informal meetings were held with the USFWS to discuss issues and 

alternatives. The USFWS, as a reviewing agency, was provided the opportunity to review and 

provide comments on the draft Chapter 2 Range of Alternatives in March 2011 as well as the 

draft RMP/EIS in August 2011. In March 2012, the USFWS became a cooperating agency on 

a national level with the BLM to address Greater Sage-Grouse conservation in RMP 

amendments and RMP revisions bureau-wide. February 2012, managers and specialists from 

Montana/Dakotas BLM conducted a sage-grouse coordination meeting with Montana 

representatives of USFWS and Montana Fish, Wildlife and Parks. March 2012, 

Montana/Dakotas BLM briefed representatives from each Montana Fish, Wildlife, and Parks

regional offices and USFWS representatives on the Implications and Implementation of the 

National Sage-grouse Planning Strategy. Also in March 2012, the BLM Montana/Dakotas 

State Director met with the DOI Solicitor, USFWS and USFS to discuss Sage-grouse 

issues/concerns in BLM RMP amendments and revisions. The Regional Sage-grouse 

Management Team will meet in April 2012. Consultation with the USFWS will continue 

throughout the RMP process. 

A draft biological assessment evaluating the impacts of the preferred alternative on federal 

threatened and endangered species will be submitted to the USFWS concurrently with the 

public release of this document. The proposed RMP/Final EIS will include the final biological 

assessment and resulting USFWS biological opinion. 

5.3.4 State Historic Preservation Office Consultation

The BLM cultural resource management program operates in accordance with 36 CFR Part 

800, which provides specific procedures for consultation between the BLM and the State 

Historic Preservation Office (SHPO). The SHPO participated as a cooperating agency for the 

RMP. The SHPO was consulted during the development of the Draft RMP/EIS concerning 

cultural resources that may be affected and was included on the RMP mailing list throughout 

scoping and public involvement. 

5.3.5 Resource Advisory Council

Resource Advisory Councils (RACs) were created in 1995 to advise the BLM on land 

management programs and issues. The RAC consists of a 15-member advisory group who 

represent three broad interest categories: commodity interests, non-commodity interests, and 

government/academic interests. The RAC members are chosen by the Secretary of Interior in 

consultation with the governor of the state in which they serve. One of the strengths of the 

RAC is their ability to provide assistance and input on a wide variety of land use issues. 

The Eastern Montana Resource Advisory Council (RAC) was actively involved in the 

Billings/Pompeys Pillar Draft RMP/EIS planning process. The first meeting with the RAC on 

the Billings/Pompeys Pillar RMP was held on May 21, 2008. A presentation on the RMP 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-7

process was provided, highlighting the components and issues of the planning area, preliminary 

planning criteria and project status. 

Early on in the process, the RAC identified two members to serve as liaisons to the RMP and 

regularly attended RMP team meetings to provide input and feedback. In an effort to help 

BLM develop management alternatives for transportation planning and special designations 

and to foster a collaborative planning environment, the RAC formed two sub-committees: 

Travel Management and Special Designations. These two RAC sub-committees had 

representatives from each of the three interest categories (defined above) to provide balanced 

representation. The RAC sub-committees and the BLM worked together to develop 

management goals and objectives, review data, and provide feedback on management options 

and alternatives. The entire RAC, as well as the RAC-appointed sub-committees, continued to 

be involved in the planning process during the preparation of the Draft RMP/EIS, through 

briefings and updates.

5.3.6 Cooperating Agencies

A cooperating agency is any federal, state, or local government agency or Native American 

tribe that enters into an agreement with the lead federal agency to assist in the development of 

an environmental analysis. On March 10, 2008, the BLM mailed letters to the federal, tribal, 

state and local representatives shown in Table 5-1, inviting them to participate as cooperating 

agencies for the Billings/Pompeys Pillar RMP. A follow-up letter was sent in early May, 2008, 

requesting participation in the planning process. 

Of the forty-three agencies and tribes invited to participate as cooperating agencies, fifteen 

accepted the invitation to participate, including the: Northern Cheyenne Tribal Council, 

Bureau of Indian Affairs, Rocky Mountain Region; Bureau of Reclamation, Montana Area 

Office; State Historic Preservation Office (Montana); Department of Natural Resources and 

Conservation – Northeastern and Southern Land Offices; Montana Association of Conservation 

Districts; Montana Fish, Wildlife and Parks; Carbon county; Golden Valley county; 

Musselshell county; Musselshell Planning Project (a consortium of counties in the planning 

area); Wheatland county; Yellowstone county; and Big Horn county (Wyoming). Some of the 

agencies and tribes that declined to serve as participating agencies, as well as those agencies or 

tribes that did not respond, will continue to be involved and informed throughout the planning 

process through mailings and project status updates. Early in the process, the cooperating 

agency representatives were included in all RMP team status updates and RMP team planning 

meetings. Twelve cooperating agency representatives attended RMP team meetings in 2008 

and early 2009. A formal planning process/status update was mailed to cooperating agencies in 

December, 2008, and included the Scoping Report. After development of management goals 

and objectives for alternative formulation, the cooperating agency representatives indicated an 

interest in being involved and updated at major milestones of the planning process. On March 

15, 2011, the cooperating agencies were mailed the Billings/Pompeys Pillar National 

Monument RMP draft Chapter 2, including the preliminary management alternatives. A 

meeting was held on March 29, 2011 to discuss the alternatives, review cooperator comments, 

and review the status of the planning process. No response was received and no cooperating 

agencies participated in the meeting, so a follow-up letter was sent on March 30, 2011. No 

response or comments were received as a result of the follow-up letter. 
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A copy of the Draft RMP/EIS was mailed to the cooperating agencies and tribes on August 10, 

2011. A cooperators meeting was held on August 30, 2011 to review cooperator comments. 

One cooperating agency participated in the August 30 meeting and comments were received 

from one additional agency. 

The BLM is aware that there are specific State laws and local plans relevant to aspects of 

public land management that are discrete from, and independent of, Federal law. However, 

BLM is bound by Federal law. As a consequence, there may be inconsistencies that cannot be 

reconciled. The FLPMA and its implementing regulations require that BLM's land use plans be 

consistent with State and local plans only if those plans are consistent with the purposes, 

policies, and programs of federal laws and regulations applicable to public lands. Where State 

and local plans conflict with the purposes, policies, and programs of Federal law there will be 

an inconsistency that cannot be resolved. While County and Federal planning processes, under 

FLPMA, are required to as integrated and consistent as practical, the Federal agency planning 

process is not bound by or subject to County plans, planning processes, or planning 

stipulations.

5.3.7 Informal Consultation and Coordination

On January 13, 2009, the BLM hosted an economic workshop in Billings to inform 

stakeholders how BLM land uses influence local and regional economic activity. Twenty-three 

individuals representing various federal, state and local agencies and organizations attended the 

workshop. Economists from the Montana BLM and the U.S. Forest Service (teams enterprise) 

presented economic information and led group discussions to promote a better understanding of 

how the economic analysis is integrated into the RMP process and gain local insights about 

local economies and feedback on the process from stakeholders. 

The BLM has conducted less formal coordination and consultation with various entities 

throughout the development of the Draft RMP/EIS. As directed by the Watershed Protection 

and Flood Prevention Act and the Clean Water Act, the BLM has included the U.S. 

Environmental Protection Agency, Montana Department of Environmental Quality, and 

Natural Resource Conservation Service in scoping activities, and updates of the planning 

process in the RMP newsletter. Permit holders, including livestock grazing permittees and 

lessees, and other stakeholders, have been included in public scoping efforts and mailings. 

On February 22, 2012, BLM hosted a conference call concerning the Billings RMP/EIS air 

quality impact analysis with an Air Quality Technical Workgroup consisting of representatives 

from the EPA, USFS, FWS, and NPS. This call formally initiated collaborative planning and 

review activities under the Memorandum of Understanding Among the U.S. Department of 

Agriculture, U.S. Department of Interior, and U.S. Environmental Protection Agency, 

Regarding Air Quality Analysis and Mitigation for Federal Oil and Gas Decisions Through the 

National Environmental Policy Act Process. During the February 22, 2012 call, BLM 

presented background information on existing air quality within the BiFO, predicted oil and gas 

activities, estimated emissions associated with the RFD, and a proposed air quality analysis 

approach for the BiFO RMP revision. BLM solicited comments from each of the MOU 

agencies and will continue to coordinate with these agencies throughout the development 

process for the BiFO RMP revision.
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Table 5-1 Federal, Tribal, State and Local Representatives Invited to Participate As 

Cooperating Agencies for the Billings and Pompeys Pillar National Monument 

RMP/EIS

Crow Tribal Council Bureau of Reclamation – Montana Area Office

Northern Cheyenne Tribal Council National Park Service – Big Horn Canyon National Recreation Area

Arapahoe Business Council Custer National Forest

Shoshone Business Committee Gallatin National Forest – Big Timber District 

Oglala Sioux Tribal Council State Historic Preservation Office

Rosebud Sioux Tribal Council Natural Resource Conservation Service

Spirit Lake Tribal Council Montana Department of Environmental Quality

Standing Rock Sioux Tribal Council State Department of Agriculture

Blackfeet Tribal Business Council Montana Association of Conservation Districts

Cheyenne River Sioux Tribe Montana Fish, Wildlife and Parks

Pine Ridge - Natural Resources Office Dept. of Natural Resources and Conservation – Northeastern Land Office

Lower Brule Sioux Tribal Council Dept. of Natural Resources and Conservation – Southern Land Office

Fort Peck Tribal Executive Board Big Horn County (Montana) 

Fort Belknap Community Council Carbon County 

Chippewa Cree Business Committee Golden Valley 

Three Affiliated Tribes Business Council Stillwater County 

Turtle Mountain Band of Chippewa Sweet Grass County 

Big Horn County - Wyoming Wheatland County 

Wyoming Game and Fish, Cody Region Office Yellowstone County 

U.S. Fish and Wildlife Service Musselshell County 

Bureau of Indian Affairs, Rocky Mountain Region Musselshell Planning Project (consortium of counties in the planning area)

Environmental Protection Agency – Region 8

5.4 Plan Distribution

Since initial scoping, the BLM has maintained a mailing list of individuals, businesses, 

organizations, and federal, state, tribal and local government representatives interested in the 

development of the Billings/Pompeys Pillar Draft RMP/EIS. In an effort to reduce printing 

costs, notices were mailed to everyone on the RMP mailing list in January 2012, requesting 

confirmation of their preference to remain on or be deleted from the mailing list, along with 

options for viewing the Draft RMP/EIS. 
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The Draft RMP/EIS is available on the BLM web site at: 

http://www.blm.gov/mt/st/en/fo/billings_field_office/rmp.html The Draft RMP/EIS is 

available for public review at the following locations:

 BLM Offices:

► Billings Field Office 

► Butte Field Office

► Lewistown Field Office

► Miles City Field Office

► Montana State Office

► Cody Field Office (Wyoming)

► Worland Field Office (Wyoming)

► Wyoming State Office

 U.S. Forest Service Offices:

► Custer National Forest – Supervisor’s Office

► Custer National Forest – Beartooth Ranger District

► Gallatin National Forest – Supervisor’s Office

► Gallatin National Forest – Yellowstone District (Big Timber)

► Helena National Forest – Supervisor’s Office 

► Lewis and Clark National Forest – Supervisor’s Office

► Lewis and Clark National Forest – Musselshell Ranger District

 Public Libraries;

► Big Horn County Public Library (Hardin)

► Big Timber Carnegie Public Library

► Billings Public Library

► Bozeman Public Library

► Bridger Public Library

► Harlowton Public Library

► Laurel Public Library

► Red Lodge Carnegie Library

► Roundup Community Library

► Stillwater County Library (Columbus)

► Big Horn County Library - Lovell Branch (Wyoming)

► Park County Library – Cody (Wyoming)

Printed copies of the Draft RMP/EIS have been distributed to the agencies, tribal entities, 

organizations, and businesses listed below. The Draft RMP/ EIS, either on CD or in printed 

format was also mailed to individuals who requested a copy. 

 Federal Government

► U.S. Army Corps of Engineers - Omaha District, 

► U.S. Army Corps of Engineers – Missoula Regulatory Office
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► U.S. Army Corps of Engineers – Billings Regulatory Office

► U.S. Army Corps of Engineers – Helena Regulatory Office

► U.S. Dept Energy - Office of Environmental Management

► U.S. Dept Energy – Western Area Power Administration

► U.S. Environmental Protection Agency – Region 8

► U.S. Fish and Wildlife Service

► U.S. Geological Survey

► USDA Farm Service Agency

► USDA Forest Service

► USDA Natural Resources Conservation Service – Big Timber Field Office 

► USDA Natural Resources Conservation Service – Columbus Field Office

► USDA Natural Resources Conservation Service – Bozeman Field Office 

► USDA Natural Resources Conservation Service – Joliet Field Office

► USDA Natural Resources Conservation Service – Hardin Field Office 

► USDA Natural Resources Conservation Service – Bridger Plant Center

► USDA Natural Resources Conservation Service – Crow Agency Field Office

► USDI Bureau of Indian Affairs

► USDI Bureau of Reclamation

► USDI Field Solicitor’s Office

► USDI National Park Service

► USDI National Park Service – National Historic Landmarks

► USID National Park Service – Lewis and Clark National Historic Trail

► USDI National Park Service – Big Horn Canyon NRA

► USFS Nez Perce National Historic Trail

 State Government

► Rep. Duane Ankney – House District43

► Rep. Tom Berry – House District 45

► Rep. Joanne Blyton – House District 59

► Rep. Virginia Court – House District 52

► Rep. Clayton Fiscus – House District 45

► Rep. Wylie Galt - House District 83

► Rep. Dave Hagstrom - House District 53

► Rep. David Howard - House District 60

► Rep. Donald Jones - House District56

► Rep. Krayton Kerns - House District 58

► Rep. Sarah Laszloffy - House District 57

► Rep. Dennis Lenz - House District 50

► Rep. Margaret MacDonald - House District 54

► Rep. Kelly McCarthy - House District51

► Rep. Mary McNally - House District 49
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► Rep. Jonathan McNiven - House District 44

► Rep. Carolyn Pease-Lopez - House District42

► Rep. Patricia Peppers - House District 41

► Rep. Alan Redfield - House District 61

► Rep. Cary Smith - House District 55

► Rep. Daniel Zolnikov - House District 47

► Rep. Douglas Kary - House District 48

► Senator Elsie Arntzen – Senate District 27

► Senator Ron Arthun – Senate District 31

► Senator Taylor Brown – Senate District 22

► Senator Robyn Driscoll – Senate District 26

► Senator Jeff Essmann – Senate District 28

► Senator Dave Lewis - Senate District 42

► Senator Alan Olson - Senate District 23

► Senator Jason Priest - Senate District 30

► Senator Sharon Steward-Peregoy - Senate District21

► Senator Kendall Van Dyk - Senate District 25

► Senator Edward Walker - Senate District 29

► Senator Roger Webb - Senate District 24

► State of Montana, Office of the Governor – Tim Baker

► Montana DEQ – Air Resource Management Bureau – Dave Klemp

► Montana DEQ – Air Resource Management Bureau – Vickie Walsh

► Montana DEQ – Bonnie Lovelace

► Montana DEQ

► Montana DEQ – Watershed Protection Section – Mark Ockey

► Montana Dept of Natural Resources & Conservation – SLO – Matt Wolcott

► Montana Dept of Natural Resources & Conservation – NeLO – Barny Smith

► Montana Department of State Lands

► Montana Department of Transportation – Stefan Streeter

► Montana Department of Transportation – Mike Tierney

► Montana Highway Commission

► Montana Fish, Wildlife, and Parks (Helena) – Jeff Hagener

► Montana Fish, Wildlife, and Parks (Helena) – Joe Maurier

► Montana Fish, Wildlife, and Parks (Helena) – Catherine Wightman

► Montana Fish, Wildlife, and Parks (Helena) – Rob Brooks

► Montana Fish, Wildlife, and Parks (region 5) – Kevin Holland

► Montana Fish, Wildlife, and Parks (region 5) –Ray Mule’

► Montana Fish, Wildlife, and Parks (region 5) – Jay Newell

► Montana Fish, Wildlife, and Parks (region 5) –Monty Paugh

► Montana Fish, Wildlife, and Parks (region 5) – Doug Haberman

► Montana Office of Indian Affairs – Lesa Evers
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► Montana State Historic Preservation Office – Dr. Mark Baumler

► Montana State Historic Preservation Office – Dr. Stan Wilmoth

► South Dakota DENR Air Quality Program – Brian Gustafson

► Wyoming Game and Fish Department (Cody Office) -

► Wyoming Game and Fish Department – Kevin Hurly

► Wyoming Game and Fish Department – Bill Wichers

► Wyoming Historic Preservation Office – Mary Hopkins

 County/Local Government

► Big Horn County (MT) Commissioners

► Big Horn (MT) Conservation District – Gloria Menke

► Big Horn County (WY) Commissioners

► Big Horn County (WY) Economic Development Inc. – Barbara Anne Green 

► Big Horn County (WY) Weed and Pest Control – Ruth Richards

► Carbon County Commissioners

► Carbon County Commissioners – Doug Tucker

► Carbon County Historic Preservation Officer – Debra Hronek

► Carbon County Planning – Greg McGann

► Carbon County Resource Council

► Carbon County Weed Department – Brian Ostwald

► Carbon Conservation District – Penny Landon

► Fergus Conservation District – Shonny Nordlund

► Gallatin Conservation District – Marcie Murnion-Learn

► Golden Valley Commissioners

► Musselshell County

► Musselshell County Commissioners

► Musselshell County – Bryan Adolph

► Musselshell County – Larry Lekse

► Musselshell County Planning Board – Tom Berry

► Musselshell County Planning Board – Alan Churchill

► Musselshell County Weed Department – Carol Martin

► Lower Musselshell Conservation District – Alice Wolff

► Upper Musselshell Conservation District – Cheryl Miller

► Phillips County Commissioners

► Prairie County Board of Commissioners – Todd Devlin

► Stillwater County

► Stillwater County Commissioners

► Stillwater County Weed District

► Stillwater Conservation District – Barbara Berry

► Sweet Grass County Commissioners

► Sweet Grass County Planning Department – Page Dringham
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► Sweet Grass County Weed Program – Stacey Barta

► Sweet Grass Conservation District – Guelda Halverson

► Yellowstone County

► Yellowstone County Commissioners

► Yellowstone County Public Works Dept – Timothey Miller

► Yellowstone County Weed Department – Scott Bockness

► Yellowstone Conservation District – Laverne Ivie

► Montana Association of Conservation Districts – Jeff Tiberi

► Billings Chamber of Commerce – John Brewer

► Billings Chamber of Commerce – Bruce McIntyre

► Billings Parks and Recreation – Mike Whitacker

► Billings Chamber of Commerce – Executive Director

► Billings City/County Planning – Dave Green

► Billings City/County Planning – Karen Miller

► City of Billings Planning Department – Wyeth Friday

► City of Billings – Tina Volek

► City of Billings – City/County Planning Department

► City of Billings – Mayor

► City of Billings – Trails

► City of Billings & Yellowstone County (Planning) – Candi Beaudry

► Big Sky Economic Development Council – Patty Nordlund

► City of Laurel – James Caniglia

► City of Lovell, Wyoming – Mayor

► City of Red Lodge – Lindsay Johnson

► City of Cody, WY – Kathaleen Spencer

► Harlowton Area Chamber of Commerce

► Park County, WY

► Red Lodge Chamber of Commerce

► Stillwater Economic Development Coordinator – Marissa Hauge

► Sweet Grass Chamber of Commerce

► Central Montana RC&D/Central Montana Regional Water Authority –

Monty Sealy

► Absarokee Rural Fire District

► Bear Creek Fire Department

► Big Horn County (MT) Rural Fire Department

► Big Timber Volunteer Fire Department

► Billings Fire Department

► Billings Logan International Fire Department

► Blue Creek Volunteer Fire Department

► Bridger Volunteer Fire Department

► Broadview Volunteer Fire Department
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► Bull Mountain Volunteer Fire Association

► Clyde Park Rural Volunteer Fire Department

► Columbus Rural Fire Department

► Cook City-Silvergate Fire Department

► Crow Agency Volunteer Fire Department

► Dean Creek Volunteer Fire Department

► Dodson People’s Creek Department

► Fromberg Volunteer Fire Department

► Gardiner Volunteer Fire Department

► Golden Valley County Fire

► Haley Bench Volunteer Fire Department – Huntley

► Harlowton Volunteer Fire Department

► Hawk Creek Volunteer Fire Department

► Homewood Park Volunteer Fire Department

► Joliet Rural and Volunteer Fire Department

► Judith Gap Volunteer Fire Department

► Molt Volunteer Fire Department

► Laurel Volunteer Fire Department

► Lavina Volunteer Fire Department

► Livingston Fire Department

► Lockwood Fire District 8

► Lodge Grass Volunteer Fire Department

► Malta Volunteer Fire Department

► Melstone Volunteer Fire Department

► Nye Volunteer Fire Company

► Paradise Valley FSA 

► Park City Rural Fire District

► Park County Rural Fire #1

► Phillips County Volunteer Fire Department

► Rapelje Volunteer Fire Company

► Red Lodge Fire Department

► Red Lodge Rural Fire District

► Reed Point Volunteer Fire Company

► Roberts Rural Fire District 6

► Roundup Volunteer Fire Department

► Ryegate Volunteer Fire Department

► Saco Volunteer Fire Department

► Shawmut Volunteer Fire Department

► Shepherd Volunteer Fire Department

► Stillwater County Fire

► Twodot Volunteer Fire Department
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► Wheatland County Volunteer Fire Department

► Wilsall Volunteer Fire Department

► Winnett Volunteer Fire Department

► Worden/HBPP Volunteer Fire Department

 Tribal Government

► Arapahoe Business Council

► Blackfeet Tribal Business Council

► Chippewa Cree Business Committee

► Cheyenne River Sioux Tribe Reservation

► Confederated Tribes of the Colville Reservation – THPO

► Confederated Tribes of the Colville Reservation – Chairman

► Confederated Tribes of the Umatilla Indian Reservation – THPO

► Crow Tribal Council

► Crow Tribe – THPO

► Fort Peck Tribal Council

► Lower Brule Sioux Tribal Council

► Nez Perce Tribe – THPO

► Nez Perce Tribe – Chairman

► Northern Cheyenne Tribe – THPO

► Oglala Sioux Tribal Council

► Rosebud Sioux Tribal Council

► Shoshone Business Committee

► Spirit Lake Tribal Council

► Standing Rock Sioux Tribal Council

► Three Affiliated Tribes Business Council

► Turtle Mountain Band of Chippewa

 Congressional

► Congressman Ryan Zinke

► Senator Max Baucus (ret)

► Senator Steve Daines

► Senator John Tester

5.5 Public Comment Period on the Draft RMP and EIS

A notice of availability announcing the release of the Draft RMP/EIS was published in the

Federal Register on March 29, 2013, initiating a 90-day public comment period. The public 

comment period ended on June 29, 2013. During the 90-day public comment period, the public 

was provided the opportunity to review and comment on the Draft RMP/EIS.
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5.5.1 Notification

The BLM issued a news release on March 29, 2013, announcing the release of the Draft 

RMP/EIS, which provided the dates and times of the public commenting workshops. The BLM

also distributed a newsletter via U.S. mail and e-mail to individuals on the BLM mailing list,

which provided the dates and locations to who all commented at workshops and public 

meetings. In addition to news releases and other notifications from the BLM regarding the 

comment period, some members of the public received notification from other sources. Several 

articles and news bulletins regarding the release of the Draft RMP/EIS were published in local 

newspapers. Many of the articles listed the dates for the public meetings and workshops. The 

Draft RMP/EIS was posted on the RMP website, hard copies were sent to Cooperating 

Agencies, other federal agencies in the planning area, libraries in the planning area, RAC 

members, local and state senators/representatives, and to tribes with affinity to the planning 

area, electronic copies of the document were distributed to the RMP mailing list, and additional 

hard-copies available upon request.

5.5.2 Public Meetings

During the public comment period, the BLM, Billings Field Office held six open house 

workshops in April/May of 2013 in towns and cities throughout the planning area (Table 5-2). 

The commenting workshops were offered to inform readers about how to navigate the Draft 

RMP/EIS, and how to prepare and submit substantive comments. The public meetings also 

provided additional opportunity for the public to ask questions and submit comments. BLM 

managers, resource specialists, and other representatives of the BLM were present during these 

meetings to discuss and answer questions. News releases were released to local newspapers 

announcing the Open House format meetings.

Table 5-2: BLM Open House Meeting Locations – Draft RMP/EIS

Community Location Date Time Attendance

Bridger

Bridger Senior Center /Golden 

Age Society

118 C Street

April 30, 2013 7-9 pm 17

Big Timber

Carnegie Public Library / 

Community Room

314 McLeod Street

May 1, 2013 7-9 pm 9

Red Lodge Senior Center

207 S. Villard Avenue May 2, 2013 7-9 pm 21

Roundup

Emergency Service Building

Ambulance Barn

704 1st St. East

May 6, 2013 7-9 pm 6

Lovell, WY

Big Horn Canyon National 

Recreation Area Visitor 

Center

20 Highway 14A East

May 7, 2013 7-9 pm 23

Billings Hampton Inn (Lewis Room)

5110 Southgate Drive May 8, 2013 7-9 pm 116
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5.5.3 Comment Analysis

The BLM received written comments by mail, e-mail, fax, and submitted/hand-delivered at the 

public meetings. Comments covered a wide spectrum of thoughts, opinions, ideas and 

concerns. BLM recognizes that commenters invested considerable time and effort to submit 

comments on the Draft RMP/EIS, and therefore, developed a comment analysis methodology 

to ensure that all comments were considered as directed by NEPA regulations. 

According to NEPA, BLM is required to identify and formally respond to all substantive public

comments. BLM developed a systematic process for responding to comments to ensure all 

substantive comments were tracked and considered. Upon receipt, each comment letter was 

assigned an identification number and logged into CommentWorks, a database that allowed the 

BLM to organize, categorize, and respond to comments. Substantive comments from each letter 

were coded to appropriate categories (Table 5-3) based on content of the comment, retaining 

the link to the commenter. The categories generally follow the sections presented in the Draft 

RMP/EIS, though some relate to the planning process or editorial concerns.

Table 5-3: Issue Categories

Category

Edits

Planning Issues and Criteria

NEPA

FLPMA

National Sage Grouse Strategy

Natural, Biological, and Cultural Resources

Air

Climate Change

Geology

Soil

Water

Vegetation (Forests and Woodlands, 

Rangelands and Shrublands, Riparian and 

Wetlands, Invasive Species and Noxious 

Weeds, Special Status Plants)

Wildlife Habitat and Special Status Species

Fisheries Habitat and Special Status Species

Wild Horses 

Cultural and Heritage Resources

Paleontological Resources

Visual Resources

Fire Ecology and Management

Wilderness Characteristics

Resource Uses

Energy and Mineral Resources

Locatable Minerals

Realty, Cadastral Survey, and Lands
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Livestock Grazing

Recreation and Visitor Services

Trails and Travel Management

Renewable Energy

Transportation and Facilities

Special Designations

Pompeys Pillar National Monument and 

ACEC

ACECs

Wild and Scenic Rivers

Pryor Mountain Wild Horse Range

National Historic Trails

Social and Economic Conditions / 

Environmental Justice

American Indian Tribes

Economic Conditions

5.5.4 Comment Analysis Process

Although each comment letter was diligently considered, the comment analysis process 

involved determining whether a comment was substantive or non-substantive in nature. In 

performing this analysis, BLM relied on the CEQ’s regulations to determine what constituted a 

substantive comment.

A substantive comment does one or more of the following:

- Questions, with a reasonable basis, the accuracy of the information and/or analysis in 

the EIS;

- Questions, with a reasonable basis, the adequacy of the information and/or analysis in 

the EIS;

- Presents reasonable alternatives other than those presented in the Draft EIS that meet 

the purpose and need of the proposed action and addresses significant issues;

- Questions, with a reasonable basis, the merits of an alternative or alternatives;

- Causes changes in or revisions to the proposed action; and

- Questions, with a reasonable basis, the adequacy of the planning process itself.

Additionally, BLM’s NEPA handbook identifies the following types of substantive comments:

- Comments on the Adequacy of the Analysis: Comments that express a professional 

disagreement with the conclusions of the analysis or assert that the analysis is 

inadequate are substantive in nature but may or may not lead to changes in the Proposed 

RMP/Final EIS. Interpretations of analyses should be based on professional expertise. 

Where there is disagreement within a professional discipline, a careful review of the 

various interpretations is warranted. In some cases, public comments may necessitate a 

reevaluation of analytical conclusions. If, after reevaluation, the manager responsible 

for preparing the EIS (authorized officer [AO]) does not think that a change is 

warranted, the response should provide the rationale for that conclusion.
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- Comments That Identify New Impacts, Alternatives, or Mitigation Measures: Public 

comments on a draft EIS that identify impacts, alternatives, or mitigation measures that 

were not addressed in the draft are substantive. This type of comment requires the AO 

to determine whether it warrants further consideration. If it does, the AO must 

determine whether the new impacts, new alternatives, or new mitigation measures 

should be analyzed in the Final EIS, a supplement to the Draft EIS, or a completely 

revised and recirculated Draft EIS.

- Disagreements with Significance Determinations: Comments that directly or indirectly 

question, with a reasonable basis, determinations regarding the significance or severity 

of impacts are substantive. A reevaluation of these determinations may be warranted 

and may lead to changes in the Final EIS. If, after reevaluation, the AO does not think 

that a change is warranted, the response should provide the rationale for that conclusion.

Comments that failed to meet the above description were considered non-substantive. Many

comments received throughout the process expressed personal opinions or preferences, had 

little relevance to the adequacy or accuracy of the Draft RMP/EIS, or represented commentary

regarding resource management without any real connection to the document being reviewed. 

These comments did not provide specific information to assist the planning team in making a

change to the Preferred Alternative, did not suggest other alternatives, and did not take issue 

with methods used in the Draft RMP/EIS, and are not addressed further in this document. 

Opinions, feelings, and preferences for one element or one alternative over another, and

comments of a personal and/or philosophical nature were all read, analyzed, and considered, 

but because such comments are not substantive in nature, BLM did not respond to them. It is 

also important to note that while all comments were reviewed and considered; comments were 

not counted as “votes.” The NEPA public comment period is neither considered an election nor 

does it result in a representative sampling of the population. Therefore, public comments are 

not appropriate to be used as a democratic decision-making tool or as a scientific sampling

mechanism.

5.5.5 Summary of Public Comments: Personal Opinions/Preferences and 

Outside the Scope of this Document

This section provides a summary of those expressions of personal opinion/preference or 

comments that were outside the scope of the Billings and Pompeys Pillar National Monument 

RMP/EIS.

Cultural Resources

 Requests for several sites along the Nez Perce NHT (not located on BLM managed 

public land) to be protected and nominated to the National Register.

 Requests for additional protection (beyond the ACEC) for Weatherman Draw ACEC
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Fire Ecology and Management

 Disagreement with proposed fire suppression tactics, suggests lawsuits against BLM

Fisheries Habitat

 Statements requesting increased protections for Blue and Red Ribbon streams

Federal Land Policy and Management Act

 Thought the DRMP did not meet the requirement of the Federal Land Policy and 

Management Act (FLPMA). 

 Stated that BLM is not meeting its multiple use mandate.

 Oil and gas (and other mineral development) is a crucial part of the BLM’s multiple use 

mandate

Fluid Minerals

 Thought oil and gas activity should be more carefully restricted.

 Felt that specific areas should be closed to oil and gas development

 Felt that the practice of hydraulic fracturing warranted more regulation

 Stated that the Preferred Alternative would further limit use, including industrial uses 

such as electric and gas distribution and transmission lines on BLM administered lands

in the planning area.

Realty, Cadastral Survey, and Lands

 Requests for certain lands be available for disposal

 Opinions for and against exclusion and avoidance areas for resource management

 Thought that the restrictions placed on new energy infrastructure and facilities would 

potentially increase costs for industry and ultimately consumers

Lands with Wilderness Characteristics

 Requests for certain areas (Weatherman Draw, Castle Coulee, etc.) to be considered as 

containing wilderness characteristics

Livestock Grazing

 Requested grazing be modified or eliminated

 Felt riparian areas not adequately protected from livestock grazing

 Stated that there was not an adequate range of alternatives for livestock grazing (no 

reduction/elimination)

National Environmental Policy Act

 Requested environmental reviews should BLM change WEMs (Waivers, Exceptions, or 

Modifications) on oil and gas stipulations

 Stated that the NEPA process and DRMP should carefully consider and incorporate the 

best available science on climate change, and impacts to wildlife species

 Did not feel that the DRMP provides the balanced land management required by law

 Did not support any of the alternatives as drafted

 Received requests to extend the public comment period an additional 45-120 days
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 Disliked Open House format meetings held for DRMP comments, requested that BLM 

hold public hearings instead

 Stated BLM failed to comply with various Acts, laws, and regulations, 

Recreation and Visitor Use

 Requests supporting target shooting closures and suggesting additional closures

 Statements against target shooting closures, stating BLM did not document why 

closures were proposed

 Recreation section lacking in accuracy with regards to how people have historically 

accessed these lands for the activities listed

 Statements that BLM designations (ERMA/SRMA) would result in land ownership 

adjustments

Social/Economics and Environmental Justice

 IMPLAN modeling system does not generate any form of reliable output

 The BLM failed to conduct the necessary economic analysis to determine the impacts of 

sage grouse management on the local customs and culture

Special Designations

 Too much private land in Grove Creek area for an ACEC designation

 Nothing significant about Grove Creek area to warrant an ACEC designation

 Proposed ACEC too small for designation

 Requests for protection of Meeteetse Spires ACEC from nonrenewable energy 

development

 Disagreement with proposed acreage of Pryor Foothills RNA ACEC (suggested several 

alternatives with larger acreages)

 Disagreement with proposed acreage changes/management of East Pryor ACEC 

Trails and Travel Management

 Requests for more roads open for motorized travel

 Requests for more roads closed to motorized travel

 Requests for trails identified for non-motorized travel

 Statements that limiting access to OHV trails would limit social and economic 

development to local communities 

 Requests for development of specific mountain bike trails

 BLM puts too high an emphasis on non-motorized recreation

 Requests for no seasonal closures on Sykes Ridge Road or Burnt Timber Road

 Stated that travel management in areas managed for sage-grouse protection will lead to 

fewer OHV opportunities and promote more wilderness designation

 Requests for better labeled route maps 

 BLM proposed travel management will not allow the State of Montana to manage 

wildlife
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Vegetation

 Stated that motorized vehicle use in the Pryors would increase the spread of invasive 

and noxious weeds

Wildlife 

 Inflating importance of wildlife/wildlife habitat instead of the importance of access

 Inflating the concerns about sage-grouse to the detriment of energy development 

 Statements of belief that predators are cause of sage-grouse decline

 Would like BLM to propose a more pro-wildlife and sportsmen friendly alternative in 

the FEIS

 BLM should delay RMP until Montana finishes the Governor’s Sage-grouse plan 

 Disagreement with proposed sage-grouse management

Outside scope

 No description/analysis of how BLM would implement E.O. 13443

 No more horse gathers, no use of pzp, 

 Requests for removal of exclosures in Pryor Mountain Wild Horse Range

 Requests for reintroduction of the Sorenson Extension (NPS land) to the PMWHR

 Requests for opening Tony Island and Tony Island Spring (USFS land) to the PMWHR

 Requests for removing the USFS fence on the PMWHR

 Request for protection of Cloud’s Family

 Requested BLM purchase private land in PMWHR for continued wild horse use 

 Requests that BLM should purchase mineral rights in Meeteetse Spires ACEC

 Surprised about the number of government jobs associated with the management of this 

area and lack of information gathered from the employees

 Comments on the B&PPNM DRMP that referred to pages/volumes of the Miles City 

DRMP and HiLine DRMP

 Requests to include development of private minerals BLM economic analysis

 Lack of BLM use of science based information to support statement

 Felt the RMP failed to acknowledge the basic needs of the U.S. and the world’s 

population for food

 Requests to consider environmental justice at the implementation level NEPA analysis

 Stated BLM was not in compliance with the NHPA as no Class III cultural inventory 

was done before writing this document

5.5.6 BLM Review and Response to Comments

The comments have been categorized by issue headings and include excerpts and/or entire 

portions of comments received, along with BLM’s response to the comment. After careful 

review and consideration of the comment, BLM prepared a response to address the comments. 

The BLM response indicates whether or not the commenters’ points resulted in a change in the 

document. As a result of public comments, changes were made to the Draft RMP/EIS and 

reflect consideration given to public comments. Table 5-8 includes the comments and the 

BLM response, with a statement as to whether or not the document was changed.
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Comments citing editorial changes to the document were reviewed and incorporated. The 

Proposed RMP/Final EIS has been extensively technically edited and revised to fix typos,

missing references, definitions, and acronyms, and other clarifications as needed.

During the public comment period, the BLM received a total of 771 comment letters or emails, 

of which 463 were unique comment documents and more than 276 were form letters. 

Comments submitted by the public represented the full range of issues and concerns during the 

comment period. The BLM received comments from a range of entities, as listed below: 

Comment Documents by Affiliation (excluding form letters). The BLM affiliated comment 

documents with a government agency or non-governmental organization if the comment 

document was received on official letterhead or was received through an official agency or 

organization e –mail address. The BLM classified all other comment documents as unaffiliated 

individuals. The BLM received the most comment documents from unaffiliated individuals.

Comment Documents by Affiliation (excluding form letters)

 American Motorcyclist Association

 Avian Power Line Interaction Committee

 Bike Net

 Billings Motorcycle Club

 Boone and Crockett Club 

 Campfire Club of America 

 Carbon County Commission

 Citizens for Balanced Use 

 Congressional Sportsmen’s Foundation 

 Families for Outdoor Recreation 

 Fidelity Exploration and Production Co.

 Gordon F. Lee Group

 Junction City Ranch Co.

 Magic City 4x4

 Montana Association of Grazing Districts 

 Montana Attorney General

 Montana Audubon and Audubon Rockies

 Montana-Dakota Utilities Co. 

 Montana Dept of Environmental Quality

 Montana Dept of Natural Resources and Conservation – NELO

 Montana Dept of Transportation

 Montana Environmental Information Center 

 Montana Fish, Wildlife, and Parks 

 Montana House of Representatives, Kerry White

 Montana Land Reliance 

 Montana Petroleum Association

 Montana State Historic Preservation Office

 Montana Public Lands Council 

 Montana Wilderness Association

 Montana Trail Vehicle Riders Association
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 Montana Wool Growers Association

 National Rifle Association 

 National Shooting Sports Foundation

 North American Bear Foundation

 NorthWestern Energy 

 Northwest Mining Association 

 Northern Plains Resource Council

 Our Montana

 Pawnee Nation of Oklahoma

 Pheasants Forever

 Phillips County 

 Prairie County

 Public Lands/Water Access Association 

 Sierra Club

 Signal Peak Energy 

 The Base Camp

 The Cloud Foundation

 The Pryors Coalition

 Theodore Roosevelt Conservation Partnership

 Trout Unlimited

 Western Environmental Law Center 

 Western Watersheds Project

 Wheatland County/Lund Law

 World Wildlife Fund Northern Great Plains Program & Audubon Rockies

 US Forest Service Nez Perce National Historic Trail

 US Environmental Protection Agency

 US National Park Service Lewis and Clark National Historic Trail

5.5.6.1 Commenter Index

The following list in Table 5-4 displays the names of the individuals, groups, organizations, 

businesses, and governmental agencies that submitted substantive comments on the Draft 

RMP/EIS and the corresponding comment letter number. Letters and emails (including formtype letters and emails) that did not contain substantive comments are not included in the index 

or in the Reponses to Public Comments section below (Table 5-8).

Table 5-4: Commenter Index

Commenter Name Comment Letter Number

lmugshee1969@aol.com 0001

Abram, Carl and Georgia 0002

Allen, Fawn 0003

American Motorcyclist Association – Sean 

Hutson

0004

Anderson, Vonnie 0005

Auguston, Susan 0006
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-26 Chapter 5: Consultation and Coordination

Auren, Nancy 0007

Avery, Shira 0008

Bahr, Richard 0009

Bailey, Helen 0010

Bailey, Toni 0011

Bailey, Mickey 0012

Barbrey, Tom 0013

Barker, Georgia 0014

Barnard, Grant 0015

Barthuly, Joe 0016

Bateman, Guy Dean 0017

Bauer, Kathleen 0018

Beland, Sue 0019

Bennett, Donna 0020

Bennett, Suzanne 0021

Bennett, Jim 0022

Barard, David 0023

Berardo, Lin 0024

Berg, Mary 0025

Biddle, Belinda 0026

Bishop, Norman 0027

Bishop, Matt 0028

Bk1492@aol.com 0029

Blackburn, Victoria 0030

Blair, Allen and Karen 0031

Keewaydin Ranch, Francis Blake 0032

Bland, Marsha 0033

Blank, Dee 0034

Bike Net – Jeff Bollman 0035

Borbone, Beth 0036

Brabant, Darlene 0037

Bragg, Vicky 0038

Brengle, Blaine 0039

Briggs, Steve 0040

Brown, Denise 0041

Montana Wool Growers Association – Jim 

Brown

0042, 0428

Brown, Mikayla 0043

Brown, Patty 0044

The Base Camp – Scott Brown 0045

Brunner, Linda 0046

Bruns, Mark 0047

Buhr, Susan 0048

Buley, Sara 0049

Buttrell, Maggi 0050
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-27

Campbell, Allison 0051

Canoe, Alcona 0052

Cassario, Judith 0053

Ceci, Cathy 0054

Center, Dean 0055

Chadwick, Lark 0056

Cheverton, Erica 0057

Citizens for Balanced Use – Kerry White 0058

Clay, S. 0059

ccl.ppl@telus.net 0060

Clouse, Pan 0061

Coate, Julie 0062

Collier, Jane 0063

Conder, Cary A. 0064

Corzine, Diana 0065

Creedon, Janet 0066

Cubel, Judy 0067

Cumin, Cal 0068

Cunningham, Bill 0069

Curnel, Karen 0070

Custard, Lindalee 0071

Soloman, Cynthia 0072

Dahl, Frank 0073, 0074 (dup), 0075

Dailey, Carson 0076, 0077(dup), 

Davey, Bill and Ann 0078

Davis, Clarice 0079

Davis, Pat 0080

Dector, Mike and Sarah 0081

Deutsch, Donna 0082

Devlin, Todd 0083, 0084, 0085(dup), 0086, 0087, 0088, 

0089, 0090, 0091, 0092, 0093, 0094, 0095, 

Dickerson, Donna 0096

DiMarco, Jerry 0097

Dixon, Lisa 0098

DNRC – NELO – Barny Smith 0099

Dodot, Holy 0100

Dombeck, Linda 0101, 0102

Donnes, Charline 0103

Dowling, Kristi 0104

McCracken, Clayton 0105

Billings Motorcycle Club – Mark Lenhardt 0106

Dronkers, Pete 0107

Elmore, Sandra 0108

US EPA – Suzanne J. Bohan 0109

US EPA – Amy Platt 0110
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-28 Chapter 5: Consultation and Coordination

Evans, Ann 0111

Evans, Jude 0112

Evans, Heather 0113

Exley, Jack 0114

Farnes, John 0115

Felton, Jim 0116

Ferrell, Doug 0117, 0118

Fidelity Exploration and Production Co. 0119, 0120(dup), 0121

Finnegan, Marian 0122

Northern Plains Resource Council – Rebecca 

Fischer

0123

Fish, Pat 0124

Fitzpatrick, Sena 0125

Flood, Renee 0126

Forehand, Dick 0127

Foulger, David 0128

Montana Attorney General – Tim Fox 0129

Funk, Wendell 0130

Fuselier, Marilyn 0131

Garagnani, Carla 0132

Garvey, Lydia 0133

Gasbarro, Donna 0134

Trout Unlimited – Michael Gibson 0135

Gierach, Paul 0136

Gilbertz, Susan 0137

Good, Mark 0138

Goolsby, Jen 0139

Gordon F. Lee Group 0140

Graham, Lori 0141

Grams, Rick 0142

Greenwood, Laurie 0143

Grenchi, Ann 0144

Guido, Frank 0145

Gulbrandson, Dave 0146

Haas, Claudia 0147

Hanick, Vic and Linda 0148

Hannon, Cathy 0149

Hanson, Greg 0150

Hantz, Carlin 0151

Harney, Maureen 0152

Harrison, Susan 0153

Hayben22@aol.com 0154

Hazher, Jerica 0155

Hehn-Bradley, Jean 0156

Montana Association of Grazing Districts and 0157
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-29

Montana Public Lands Council – Jay Bodner

Western Environmental Law Center, Montana 

Environmental Information Center, and Sierra 

Club – Shiloh Hernandez

0158, 0409, 0456 (dup), 0457 (dup), 0458

(dup)

Theodore Roosevelt Conservation Partnership 

– Hal Herring

0159, 0354

Higgins, Gail 0160

Hopwood, Valerie 0161

Horan, Tim 0162

Horne, Nancy 0163

Howard, Lynn 0164

Hudeck, Dorothy 0165

Hudson, Hank 0166

Jackson, Sharon 0167

Jaquith, Phil 0168

Jay, Vickie 0169

Johannesen, Judi 0170

Lund Law – Wheatland County Community 

Members – Breeann Johnson

0171

Junction City Ranch Co. 0172, 0173(dup)

Kamps, Steve 0174

Karnos, David 0175

Magic City 4x4 – Doug Kary 0176

Keenen, Elizabeth 0177

Keiper, Kenneth 0178

Kerr, Chuck 0179

Kilmer, Tom 0180

Kilzer, Edward 0181

King, Paula 0182

Kinn, Katie 0183

Liddick, Pamela 0184

Kligerman, Jack 0185

Knapp, Ralph 0186

Knight, B. 0187

Kobinger, Joachim 0188

Kopec, Len 0189

Kraus, Jim 0190

Kreidler, Jeffrey 0191, 0192, 0193(dup)

Kriegel,Henry 0194

Kronmiller, Bill 0195

Krouse, Susan 0196

Taylor, Trevor 0197

Landsgaard, Paul 0198

Lapis, Ted 0199

Lashaway, Lisa 0200
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-30 Chapter 5: Consultation and Coordination

Lavallee, Kris 0201

Leasure, Karen 0202

Lesica, Peter 0203, 0204

redacted 0205

Longo, Cynthia 0206

Lyman, Thomas 0207

Lyman, Jennifer 0208

Lynch, Janet 0209

Mackin, Bob 0210

reacted 0211

Mahon, Michael 0212

Makara, Mike 0213

Marchand, Diane 0214

Margaret 0215

Marianne 0216, 0217

Markham, Ann 0218

Marshall, Amelia 0219

Martin, Stella 0220

Mattmroczka@sbcglobal.net 0221

McCracken, Clayton 0222, 0223, 0224, 0225, 0226

Mcguire, Molly 0227

McIlhatten, Sharon 0228, 0229

Families for Outdoor Recreation – Ed Melcher 0230, 0422, 0423(dup)

Meloy, Tim 0231

Messenich, Jodi 0232

Messersmith, Kymber 0233

Miller, Neil and Jennifer 0234

Our Montana – Lee Miller and Mike Penfold, 

Public and Water Access – John Gibson

0235

Mize, Stacy 0236

USFS, NPNHT – Julie Molzahn 0237

Mom & Pop Products - Donald and Dolores 

Kaleta

0238, 0239(dup)

Montagne, Joan 0240

Montenegro-Long, Elena 0241

Moseman, Karen 0242

Moseman, Scott 0243

Montana Petroleum Association – David A. 

Galt

0244, 0245, 0426, 0427(dup)

Montana Fish, Wildlife, and Parks – Jeff 

Hagener

0246, 0249

Montana Attorney General – Tim Fox 0247

Montana Dept of Environmental Quality –

Bonnie Lovelace

0248

Mulvey, Phil 0250
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-31

Myers, David 0251

Nelson, Michael 0252

Nemes, Joe 0253

Neria, Meredith 0254

Newbold, Alison 0255

Newell, Susan 0256, 0257

Newton, Anita 0258

Nguyen, Anh 0259, 0429

Nichols, Yonnie 0260, 0261(dup)

Norton, S.R. 0262

Nye, Barbara 0263

Ockey, Mark 0264

Omen, David 0265

Orr, Taylor 0266

Orr, William 0267, 0268(dup)

Orser, Effie 0269

Oz, Kristal 0270

Pacini, Paul 0271

Parson, Wayne D. and Cynthia A. 0272

Patten, Eva 0273

Pawnee Nation of Oklahoma 0274

Peddy, Jan 0275

Perron, Julie Anderson 0276

Pfister, Ellen 0277

Phariss, Daniel 0278

PHarrin120@aol.com 0279

Pierce, Nancy A. 0280

Pizzo, Don 0281

Platt, Amy 0282, 0283

Public Lands/Water Access Association –

John Gibson

0284

Polick, Melissa 0285

Pollock, Diane 0286

Powers, Larry 0287

Pubic, Jean 0288, 0289, 0290, 0291

Raber, Katie 0292

Redfield, Alan 0293

Montana Trail Vehicle Riders Association 

Reierson, Bruce 

0294, 0295, 0438

Rhodes, Peggie 0296

Richardson, Gail 0297

Ridgway, James 0298,0299, 0300, 0301, 0302, 0303, 

03040305, 0306, 0307

Rjsj9840@aol.com 0308

Robb, Cheryll 0309
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-32 Chapter 5: Consultation and Coordination

Rosema, Sharon 0310

Ryan, Richard and Jacqueline 0311

Salmonsen, Susan 0312

Montana Wilderness Association – Cameron 

Sapp

0313

Schappek, Marianne 0314

Scheffer, Paul 0315

Scranton, Eric 0316

Sentz, Gene 0317

Sessions, Addison 0318

Sheffman, Sara 0319

Avian Power Line Interaction Committee –

Sherry Liguori

0320

Shields, Zia 0321

Shores, Karen Cheney, Eric and Anni 0322

Montana State Historic Preservation Office –

Kathryn Ore

0323

Sievers, Jack 0324

Simmons, John P. 0325

Sindelar, Mona 0326

Singh, Susan 0327

Sloanebiking@yahoo.com 0328

Smeets, Erna 0329

Smith, Stephanie 0330

redacted 0331

Starmer, Michael 0332

Starshine, Dorothy 0333

Stein, Julie 0334

Steinmuller, Patti 0335

Steinmuller, David 0336

Stribling, Barbara 0337

Strong, David 0338

Stroombeek, Carolyn 0339

Strouf, Dale 0340

Suminski, Rita 0341

Swank, Gene 0342

Talbert, Linda 0343

Tatz, Janet 0344

Taylor, Mark 0345

Tettenburn, Lindsey 0346

Thunstrom, Gerald 0347

Tibbettts, June 0348, 0349(dup)

Montana Dept of Transportation –

MichaelTierney

0350

Tighe, Dennis 0351
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-33

Tillett, Jeri 0352

timabby@windstream.net 0353

Trigg, Ashley 0355

Carbon County Commissioner – Doug Tucker 0356

Turner, Larry 0357

Verderosa, Danielle 0358

Voeller, Marian 0359

Vojtko, Martha 0360

Walker, Amanda 0361

The Pryors Coalition - Dick Walton 0362, 0363

Wells, Joanne 0364

White, Sally 0365

Montana House of Representatives – Kerry 

White

0366

Whitney, Annie 0367

Wideman, Roger 0368

Wiet, John and Dee 0369

Wilson, Marilyn 0370

Winslow, Susan 0371

Worthington, Alycia 0372

Wright, Jo Ann 0373

Wyberg, Bryan 0374

Wyss, Dianne 0375

York, Leonard 0376

Yuz, Lin 0377

Zaccagnini, Robert and Stephanie 0378

Anderson, Chris 0379

Beh, Ty 0380

Western Environmental Law Center –

Matthew Bishop

0381

Blakely, Gail 0382

Blayer, Cynthia 0383

Bornus. Michael 0384

Brcic, Linda 0385

Western Watersheds Project – Travis Bruner 0386

Pheasants Forever – Yellowstone Valley 

Chapter #434 - Michael J. Bullock

0387

Buskin, Helaine 0388

Cardy, Cindy 0389

American Bird Conservancy – Daniel Casey 0390

Cearley, Susan 0391

Cruz, April 0397

Dakota Coal Company – Robert Bartosh 0398

Davey, Bill and Ann 0399

Littlebear9641@yahoo.com 0400
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Proposed Resource Management Plan and Final Environmental Impact Statement

5-34 Chapter 5: Consultation and Coordination

Deveraux, Jody 0401

Doze, Steve 0402

Montana Audubon and Audubon Rockies –

Janet Ellis

0403

Enk, Michael 0404

NPS L&CNHT – Miki Griffen, Mark 

Weekley

0405

Griffith, Lisa 0406

Harding, Rita 0407

Hathaway, Susan 0408

Western Environmental Law Center – Shiloh 

Hernandez

Prairie Hills Audubon Society – Nancy 

Hilding

0410

Joerndt, Judith 0412

World Wildlife Fund Northern Great Plains 

Program – Martha Kauffman (Mara Johnson)

Audubon Rockies – Daly Edmunds 

0413

Judice, Phyllis 0414

Kamps, Steve 0415

Montana-Dakota Utilities Co. – Abbie 

Krebsbach

0416

Loftin, Elizabeth 0417

Mabee, Carolyn 0418

McCracken, Meredith 0419

McCollister, Lori 0420

McFarland, Jenne 0421

Miller, Anthony 0424

Montana Land Reliance – Kendall Van Dyk 0425, 0447

National Rifle Association, National Shooting 

Sports Foundation, North American Bear 

Foundation, Congressional Sportsmen’s 

Foundation, Campfire Club of America, 

Boone and Crockett Club 

0430

Petty, Dean 0431

Phillips County 0432, 0433

Posey, Chris 0434

Prairie County 0435

The Pryors Coalition – Dick Walton 0436

Quinby, Sharon 0437

Russis, Kathy 0439

Salvo, Mark 0440

Shuster, Lloyd 0441

Signal Peak Energy – John DeMichiei 0442

Northwest Mining Association – Laura Skaer 0443
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-35

NorthWestern Energy – Mary Gail Sullivan 0444

Urban, Lesa 0445

Vancos, Joy 0446

The Cloud Foundation – Lauryn Wachs 0448, 0449, 0450, 0451, 0452, 0453

Walton, Dick 0454

Webster, Margaret 0455

Wheatland County 0459

Winkler-Bluhm, Patricia 0460

Hilding, Nancy 0461

Lee, Christy 0462

Ford, Becky 0463

Form Letter A – Americans for Economic 

Freedom (98 letters)

See 0062 or 0262 for example of letter

Form Letter B – Wild Horse/Pryor Mountain 

Wild Horse Range (165 letters)

See 0022 or 0448 for example of letter

Form Letter C – County Protest (13 letters) See 0171 for example of letter

A summary of major changes between the Draft RMP/EIS and the Proposed RMP/Final EIS 

can be found in Chapter 2, Section 2.3.4, Changes between the Draft RMP/EIS and the 

Proposed RMP/Final EIS.

5.5.6.2 Form Letters

The BLM received approximately 276 form letters. Form letters are standardized and

duplicated letters that contain the same text or portions of text and comments. The BLM

reviewed the form letters and extracted and analyzed any comments unique and supplemental 

to the form letter; however, the BLM considered comments with the same text as one comment. 

The BLM designated the first form letter from each originating entity as the “master” comment

document and reviewed each subsequent form letter to ensure the content was identical to the

master comment document. The BLM received form letters from 

 Americans for Economic Freedom (98)

 Wild Horses or PMWHR letters (165)

 Montana Counties (13)

When form letters included additional text, the BLM reviewed and processed them if they

contained substantive individual comments.

5.5.7 Other Public Involvement

On June 22, 2013, at the request of (and organized by) some Grove Creek residents, members 

of BLM staff met with11 members of the public at the Belfry School to answer questions about 

travel management, ACECs, and fire management in the Grove Creek area. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-36 Chapter 5: Consultation and Coordination

5.5.7.1 Newsletters

Periodic newsletters have been developed and distributed to keep the public informed of the

Billings and Pompeys Pillar National Monument RMP revision. In total, one newsletter has

been e-mailed and mailed to individuals on the Billings and Pompeys Pillar National 

Monument RMP mailing list. The newsletters have also been made available for download on 

the Billings and Pompeys Pillar National Monument RMP website.

5.5.7.2 Website

The Billings and Pompeys Pillar National Monument RMP website can be found at: 

http://www.blm.gov/mt/st/en/fo/billings_field_office/rmp.html . The website serves as a virtual

repository for documents related to the development of the RMP, including announcements, 

newsletters, and documents. The documents are available in PDF format to ensure they are

accessible to the widest range of interested parties. The website provides the public current 

status and project contact information. 

5.5.7.3 Future Public Involvement

Public participation efforts have and will be ongoing throughout the remainder of the process of

revising the RMP and developing the EIS. The Proposed RMP and Final EIS considered all

substantive comments received during the 90-day public comment period for the Draft RMP 

and EIS. Members of the public with standing will have the opportunity to protest the content 

of the Proposed RMP and Final EIS during the specified 30-day protest period. The Record of 

Decision will be issued by the BLM following the Governor’s Consistency Review and protest 

resolution.

5.5.8 List of Preparers

An interdisciplinary team of resource specialists from the BLM Billings Field Office, the BLM 

Montana State Office (MSO), and the Miles City Field Office (MCFO) prepared this Draft 

RMP/EIS (Table 5-5). 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-37

Table 5-5 Billings and Pompeys Pillar National Monument RMP/EIS Preparers

Billings and Pompeys Pillar National Monument RMP/EIS Preparers

Name

Education

Years of Experience

Professional Discipline Responsibility

Jim Sparks

B.S. Rangeland Ecology

28 years

Field Manager

Reviewer

Craig Drake

B.S. Natural Resource Management, emphasis in 

Watershed Management (Hydrology)

19 years

Assistant Field Manager

Reviewer

Irv Leach Fire Management Officer Reviewer

Jeff Kitchens

B.S. Psychology and Environmental Science

M.S. Forest Sciences

15 years

Pompeys Pillar National Monument Manager

Reviewer

Susan Bassett (MSO)

B.S. Chemical Engineering, B.A. English

20 years

Physical Scientist (Air)

Air, Climate

John Bown (MSO)

(deceased)

B.S. Geology, M.S. Geology & Geophysics

34 years

Geologist

Fluid Minerals

Jared Bybee

B.S. Environmental and Natural Resource Sciences: 

Range Management emphasis

14 years

Rangeland Management Specialist / State Wild Horse 

and Burro Specialist

Wild Horses, 

Pryor Mountain Wild Horse Range

Sheila Cain 23 years

GIS Specialist GIS

Tom Carroll

(deceased)

B.A. History

22 years

Realty Specialist

Realty, Cadastral Survey, and Lands

Dave Coppock (MSO) 

(retired) Geologist

Locatable Minerals,

Mineral Materials,

Coal

Dustin Crowe

B.S. Natural Resource Ecology and Rangeland 

Management

3 years

Rangeland Management Specialist

Soil, Air, Vegetation (rangelands), 

Livestock Grazing

Chad Cullum Wildfire Ecology and Management

Gregory Fesko (MSO)

B.S., M.S. Geology

17 years

Coal Program Coordinator

Coal, Geology

Tim Finger

B.S. Zoology and Wildlife Management

32 years

Outdoor Recreation Planner

Lands with Wilderness Characteristics, 

Visual Resources, Cave and Karst 

Resources, Recreation and Visitor 

Services, Transportation and Facilities, 

Trails and Travel Management, Wild 

and Scenic Rivers, WSAs
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-38 Chapter 5: Consultation and Coordination

Billings and Pompeys Pillar National Monument RMP/EIS Preparers

Name

Education

Years of Experience

Professional Discipline Responsibility

Bob Flesch (MSO)

B.S. Social Science, B.A. Anthropology, 

M.S. Public Administration

14 years

Assistant Fire Management Officer

Wildfire Ecology and Management

Linda E. Hardy (retired)

A.A.S. Recreation; 

B.S. Business

16 years

Outdoor Recreation Planner

Lands with Wilderness Characteristics, 

Visual Resources, Recreation and 

Visitor Services, Transportation and 

Facilities, Trails and Travel 

Management, Wild and Scenic Rivers, 

WSAs

Craig Howells Wildfire Ecology and Management

Renee Johnson (MSO)

B.A. English and Anthropology (double major)

23 years

Renewable Energy Project Manager

Renewable Energy

Ernie McKenzie (term 

expired 2015)

B.S. Biology with emphasis in Aquatic Ecology

10 years

Biological Sciences Technician (Fisheries, Riparian)

Water, Riparian and Wetlands, 

Fisheries Habitat and Special Status 

Species (Fisheries),

Travel Planning

Bob Meidinger (retired)

B.S. Education with extended biology major/chemistry 

minor; 

M.A. Education Computer option

25 years

RMP/RMS; Fuels Specialist /Forestry

Air, Climate Change, Soil, Forest and 

Woodlands, Forestry and Woodland 

Products, Travel Management

Larry Padden

B.S. Range and Forest Management

23 years

Natural Resource Specialist

Rangeland Vegetation, 

Livestock Grazing,

Invasive Species and Noxious Weeds

Jay Parks

B.S. Fish and Wildlife Management with a minor in 

Range Management

34 years

Wildlife Biologist

Wildlife Habitat and Special Status 

Species (Wildlife)

Melissa Passes

(transferred to BIA in 

2012)

B.A. Environmental Studies; 

M.S. Land Resources and Environmental Sciences

10 years

Natural Resource Specialist

Invasive Species and Noxious Weeds

Michael Philbin (MSO)

B.S. Geography - Watershed Emphasis; 

M.S. Forest Resources - Watershed Emphasis

21 years

Hydrologist

Soil, Water, Air, Riparian, and Fire 

Rehabilitation Program Lead

Kimberly O. Prill (MSO)

B.S. Psychology, minor study in Economics; 

MEd. Organizational Communication

20 years

Land Use Specialist

Reviewer 

Tami Sabol (MCFO)

transferred to USFS in 

2013

B.S. Forestry

18 years

Forester 

Forest and Woodlands,

Forestry and Woodland Products

Carolyn Sherve-Bybee

B.A. German;

M.A. Anthropology with Archaeology emphasis

21 years

RMP Team Lead/Archaeologist

Cultural Resources, Paleontological 

Resources, ACECs, National Historic 

Trails
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-39

Billings and Pompeys Pillar National Monument RMP/EIS Preparers

Name

Education

Years of Experience

Professional Discipline Responsibility

Nora Taylor (MSO) 

(retired)

B.S. Wildlife Management / Range Management

31 years

Botanist

Special Status Plants

John Thompson (MSO)

(retired)

B.S. Economics/Political Science; 

M.S. Agricultural Economics (emphasis in Resource 

Economics)

36 years

Planning & Environmental Specialist/Economist

Economist/ Planning & Environmental 

Specialist

Joan Trent (MSO)

(retired)

B.A. Psychology, 

M. En. Environmental Science

30 years

Sociologist

Social

Wendy Velman (MSO)

B.A. Botany

11 years

Botanist

Special Status Plants

Charles Ward (retired)

A.S. Park Management, 

B.S. Recreation and Park Administration

34 years

RMP; BLM LEO

Lands with Wilderness Characteristics, 

Visual Resources, Cave and Karst 

Resources, Recreation and Visitor 

Services, Transportation and Facilities, 

Trails and Travel Management, Wild 

and Scenic Rivers, WSAs

AECOM (Chapter 3 and portions of Chapter 4)

Steve Graber

B.S. Natural Resources Management; B.A. Economics

6 years

Realty, Cadastral Survey, and Lands and Renewable 

Energy

Patti Lorenz

B.S. Wildlife Biology

8 years

Wildlife Habitat and Special Status Species (Wildlife) 

Melanie Martin

M.S. Environmental Policy and Natural Resource 

Management; 

B.S. Agriculture, Environmental Protection

13 years

Senior Technical Review

Kim Munson

M.A. Anthropology; 

B.A. Anthropology

18 years

Cultural Resources and Native American Concerns 

ARS (Trails and Travel Management)

Tom Folks

B.S. Recreation Park Planning and Resource 

Management

27 years

Land Use Planning Specialist

Nathan Holland

B.S. Earth Sciences

10 years

Travel Management Planning Specialist
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-40 Chapter 5: Consultation and Coordination

Billings and Pompeys Pillar National Monument RMP/EIS Preparers

Name

Education

Years of Experience

Professional Discipline Responsibility

Les Weeks

M.A. Biogeography; 

B.A. Ecosystems Analysis

20 years

Land Use Planning Specialist

Table 5-6 Montana State Office Reviewers

Name Name

Jim Albano (retired) Chris Miller

Terri Bakken (retired) Mike Philbin

Susan Bassett Kim Prill (transferred to BOR)

Jim Beaver (retired) Frances Rieman

John Bown (deceased) Mark Sant

Jared Bybee Ken Schmid

John Carlson John Simons (retired)

Greg Fesko Gary Smith

Craig Haynes (retired) Floyd Thompson

Bill Hensley John Thompson (retired)

Renee Johnson Joan Trent (retired)

Pascual Laborda (retired) Wendy Velman

Greg Liggett David Wood (NOC)

Karen Michaud
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-41

Table 5-7 Cooperating Agencies and Contacts

Agency /Organization Contact Location

Cooperating Agencies and Contacts

Big Horn County Commissioner Keith Grant Basin, Wyoming

Carbon County Commissioner Doug Tucker Red Lodge, Montana

Department of Natural Resources and 

Conservation, Northeastern Land Office

Barny Smith Lewistown, Montana

Department of Natural Resources and 

Conservation, Southern Land Office

Richard Moore Billings, Montana

Golden Valley County Commissioner David Paugh Ryegate, Montana

Bureau of Indian Affairs Rick Stefanic Billings, Montana

Montana Association of Conservation 

Districts

Jeff Tiberi Helena, Montana

Montana Fish, Wildlife, and Parks Jeff Hagener, Director Helena, Montana

Musselshell County Commissioner Larry Leske Roundup, Montana

Northern Cheyenne Tribe Leroy Spang, President

Conrad Fisher, THPO

Lame Deer, Montana

Bureau of Reclamation Dan Jewell Billings, Montana

State Historic Preservation Office 

(Montana)

Stan Wilmoth Helena, Montana

Wheatland County Commissioner Tom Bennett Harlowton, Montana

Yellowstone County Commissioner Bill Kennedy Billings, Montana

Other Interested Parties

Wyoming Game and Fish Kevin Hurley Cody, Wyoming

U.S. Fish and Wildlife Service Mark Wilson Helena, Montana

State Historic Preservation Office 

(Wyoming)

Laramie, Wyoming 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-42 Chapter 5: Consultation and Coordination

5.5.9 Responses to Public Comments

This section (Table 5-8) contains the substantive comments received from individuals, groups, organizations, businesses, and 

governmental agencies during the comment period on the Draft RMP/EIS, and the corresponding BLM responses to the comments. 

All public comments received were carefully considered. As described above, only substantive comments are addressed and received 

a response in the Proposed RMP/Final EIS. Comments such as those merely expressing approval or disapproval of a proposal without 

reason did not receive a response in the Proposed RMP/Final EIS. Gaps in the numbering letters do not represent missing 

information; rather they were determined to be form-type letters, or consisted of comments that were not substantive or outside the 

scope of this planning process.

Table 5-8: BLM Response to Public Comments 

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

DRMTDK-BL13-0004-1Travel mngt 

and 

soc/econ

The AMA has concerns that the DEIS does not fully take into account the social 

and economic costs of limiting access for responsible OHV riders. In fact, 

alternative D, the preferred alternative, limits public access on OHV trails by 

declaring nearly 200 miles of trails to be for administrative use only. This is 

contradictory to how the alternative is presented in the BLM's fact sheet which 

states only 59 miles of trails will be closed. Designating a trail for administrative 

use only is de facto closure for local riders. The AMA suggests that the Bureau 

of Land Management revisits the designation of trails for administrative use only. 

With minimal additional resources, the BLM could keep nearly 200 miles of trails 

open for public use. Without these trails I believe many local communities will 

face adverse economic affects.

n Thank you for your concerns and comments. 

DRMTDK-BL13-0010-1WILD 

HORSES,

PMWHR

I am writing to ask that you please prioritize any enclosures not currently in use 

on the above-listed range. You have used them for data collection in the past 

and right now they currently take up space. The large ones on Sykes Range 

could be a safety hazard to foals. This has actually happened in the past with 

other enclosures.

N Thank you for your comment 

DRMTDK-BL13-0010-2

PMWHR

Please do not allow target shooting on the mountaintop area from Memorial Day 

through Labor Day. It should be prohibited year round in the entire PMWHR. It 

can cause undue stress on the wild horses and other wildlife, increase the risk of 

accidental horse shooting and in an endangerment to the other visitors on the 

mountain.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

DRMTDK-BL13-0010-3WILD 

HORSES,

PMWHR

Please work with the National Park Service to reintroduce the Sorenson 

Extension into the horse range. Please work with the Forest Service to include 

the mountaintop area and open meadows, as well as Tony Island Spring.

N Thank you for your comment.

DR- ACEC The Meeteetse Spires area deserves maximum protection including no private N "Thank you for expressing your concerns. While statements of opinion 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-43

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

MTDK-BL13-0015-1mineral rights and an eventual Wilderness designation. (The adjacent Forest 

Service Research Natural Area could be included to make a large Wilderness 

area). This entire unique, beautiful area is being managed nicely as ACEC but 

will need more permanent protection as nearby oil, gas and mineral activity 

comes closer and the US puts more pressure on these lands for nonrenewable 

energy.

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS.

DRMTDK-BL13-0015-2

ACEC

The Castle Coulee area near Weatherman Draw deserves protection and will be 

a great addition to the area if protected from motor vehicle use/damage and from 

oil, gas and mineral activity. The beautiful rock formations and Native American 

cultural and archaeological sites need protection and preservation.

n

Thank you for expressing your concerns. While statements of opinion do not 

require specific responses text revisions under NEPA regulations, they have 

been considered by the Billings Field Office and Montana State Office and 

documented in the administrative record associated with the Billings and 

Pompeys Pillar National Monument RMP/EIS. 

This area has already been included in the proposed expanded Weatherman 

Draw ACEC. See table 2-6.3 – Weatherman Draw. Please table 2-6.3 for 

proposed management of Weatherman Draw.

DRMTDK-BL13-0018-1

PMWHR

Please do NOT close the Burnt Timber and Sykes Ridge Roads between April 

15 and June 15. Protect the horses and the habitat by clearly advising the public 

of penalties for off road use of the land.

n

"Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS.

DRMTDK-BL13-0020-1

lands with 

wilderness 

characteristi

cs

Manage Weatherman Draw, Bad Canyon, Yellowstone River Islands and Clark's 

Fork River Islands like the other lands identified as having wilderness qualities. 

Specifically: 1. Close the areas to oil and gas leasing, or allow leasing only with 

a "no surface occupancy" stipulation with no exceptions, waivers, or 

modifications. 2. Designate as areas where rights-of-way for powerlines and 

pipelines are excluded. 3. Designate the areas as excluded for wind farms. 4. 

Close these wildlands to the construction of new roads. 5. Close all identified 

wildlands to mining. 6. Close lands with wilderness characteristics to motorized 

recreation. 7. Restrict construction of new structures and facilities unrelated to 

the preservation or enhancement of wilderness characteristics.

n

"Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS.

DRMTDK-BL13-0020-2

Travel mngt

 Close the Demijohn Flat route (Pryor Mountains) to motorized use to protect a 

culturally sensitive area. The 1 1/2 mile route would also make a good, quiet, 

non-motorized trail and create a seamless boundary between the Burnt Timber 

Canyon Wilderness Study Area and adjacent lands identified by the BLM as 

having wilderness characteristics. Close the two-track leading into Bear 

Canyon (Pryor Mountains) to motorized use beyond Manage all lands with 

wilderness value... the mouth of the canyon. Two parallel motorized routes in the 

area already provide motorized access into this part of the Pryor Mountains. 

Now the BLM proposes to open a third, Graham Trail, to motorized use. What is 

needed is a quiet, non-motorized trail. Designate quiet, non-motorized trails as 

part of the travel management plan. The plan designates 130 miles of motorized 

n

"Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-44 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

routes, but fails to designate any quiet, non-motorized trails in the Pryor 

Mountains and most other parts of the district.

DRMTDK-BL13-0021-1

lands with 

wilderness 

characteristi

cs

Please manage Weatherman Draw, Bad Canyon, Yellowstone River Islands + 

Clark's Fork River Islands like the other lands identified as having wilderness 

qualities.

n

"Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS

DRMTDK-BL13-0023-1ACEC, 

Travel 

Mngt, Fire

I reside at 47 Horny Toad Trail, Belfry MT 59008, which is included in your Draft 

Resource Management Plan. My property description is: TR 32 COS 938. My 

home is 3200 square feet and is powered solely by 24 solar panels and 2 wind 

turbines. My home sits on 20 acres. My home was built in 2006, so I have lived 

here for seven years. The direct access to my home is South of Belfry on MT 

Hwy 72, to West on Grove Creek Road. Passing through the main gate of the 

Grove Creek Ranch I bear left on public access for approximately 1.2 miles to 

turn West on the Meeteetse Trail. I pass through one chained (not locked) BLM 

cattle gate on the public access road before turning on the Meeteetse Trail. It is 

my understanding in the Draft Resource Management Plan that BLM is 

considering closing the access road at the main gate of the Grove Creek Ranch 

at the end of Grove Creek Road. Designating the area where I live as an ACEC 

area would adversely impact myself and the other property owners in my 

immediate vicinity, particularly with fire management and road improvements. 

[There is too much private land to consider this change to an ACEC area.] A 

point in hand regarding fire safety: a year and a half ago, during the Hole in the 

Wall fire, the National Park Service dispatched a ranger to my home to warn me 

about possible evacuation and to have myself and my family, ready to evacuate, 

bags packed. The next day a Carbon County Sheriff's Deputy came to my home 

to reiterate the fire hazard being caused by the Hole in the Wall fire and to

underscore the possible danger and the threat of immediate evacuation. There is 

no phone service at my home (because there are no telephone poles within 

three miles) so it is not possible for fire safety personnel to contact me any other 

way than directly traveling to my home. Re-routing traffic to the Chance Bridge 

and locking out direct evacuation routes from my home is a serious concern, 

when SECONDS COUNT in a raging Montana forest fire. Please do not adopt 

Alternative D, shutting off my connection to Grove Creek Road. Alternative D 

blocks direct access and evacuation routes. For safety's sake, please allow me 

continued direct access to my home and allow fire safety personnel direct 

access to my house, along with direct evacuation routes. My home site borders 

BLM land on two sides. My family and I appreciate everything BLM does to 

preserve and protect Federal Lands. Please allow me direct ingress/egress to 

my by not adopting Alternative D.

N

"Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-45

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

DRMTDK-BL13-0030-1

Coal

The northern portion of the Big Horn Basin in Montana and Wyoming is well 

known for its mineral resources including oil, gas and coal. Contained within this 

Basin is the Ft Union Geologic Formation extending from Wyoming into 

Montana. The Montana portion of the basin contains proven underground coal 

fields in the Red Lodge, Bear Creek & Grove Creek areas. Scant mention or 

discussion of these private resources is mentioned in the plan. The Bear Creek 

coal fields have produced 30 to 40 million tons of coal since mining began in the 

1880's. They still contain over a billion tons of coal along the face of the 

Beartooth Mountains. Township 8 and 9 South, Range 20 and 21 East, the area 

of our greatest concern is included on the map from plan appendix M Figure M3. We are all primarily concerned with maintaining the value of our mineral rights 

in the area known as Red Lodge Area, Bearcreek Area, and the Grove Creek 

Area. The coal resource has been documented by geologic reports extending 

over 100 years from professional geologists who have published their findings 

dating from 1907 to 2010. We can provide references if you desire. Incidentally, 

the subject location is not in the scenic mountains or river bottoms that

fisherman, sportsman, and recreationists enjoy. It is a dusty, barren, sagebrush 

area where vegetation struggles to grow. This coal would be mined by 

underground methods with minimal surface disturbance. Because the coal does 

not follow ownership lines, the mine area will encompass several mineral 

ownerships. The coal mine(s) would produce significant economic impact 

amounting to 100s of millions of dollars for Carbon County, the state of Montana 

and the nation by creating well-paying jobs for hundreds of miners and related 

personnel.

N

The text describing the coal development potential of the Red Lodge-Bearcreek 

coalfield has been enhanced in the Chapter 2, Solid Minerals-Coal section.

DRMTDK-BL13-0030-2

coal

The northern portion of the Big Horn Basin in Montana and Wyoming is well 

known for its mineral resources including oil, gas and coal. Contained within this 

Basin is the Fort Union Geologic Formation extending from Wyoming into 

Montana. The Montana portion of the basin contains proven underground coal 

fields in the Red Lodge, Bear Creek & Grove Creek areas. Scant mention or 

discussion of these private resources is mentioned in the plan. In review of the 

BLM RMP as proposed, it is clear your agency is not adequately considering the 

economic impact of the decision in any of the alternatives presented in the plan. 

For over 80+ years many companies have leased oil/gas mineral rights in this 

area, several have drilled deep test holes. Area oil/gas leasing on BLM would be 

abolished or severely restricted by this plan with direct effect on adjacent taxable 

lands which would be closed to leasing. This action would result in $0 income for 

the BLM and ultimately the general population in the United States.

n

Thank you for your comment. The text describing the coal development 

potential of the Red Lodge-Bearcreek coalfield has been enhanced in the 

Chapter 2, Solid Minerals-Coal section.

DRMTDK-BL13-0030-3

NEPA

The CEQ has directed agencies to gather data from reliable sources such as 

interviews and information from local residents which the BLM has failed to do. 

You did hold the open meetings, but refused to allow public comment at those 

meetings. How can they be considered public meetings if no public discussions 

N

Thank your for your comment. The BLM Billings Field Office held 5 Open 

House style public meetings in which the public could ask specialists questions 

about the draft RMP/EIS. In order to and the public comment period on the 

draft RMP/EIS was open for 90 days. Also, at the request of members of the 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-46 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

are allowed? I suggest you reschedule the meetings and allow them to be public 

meetings as required.

public, the BLM attended a meeting on June 22, 2013 in Belfry, Montana to 

answer questions regarding proposed management in the Grove Creek area.

DRMTDK-BL13-0031-1

ACEC, Fire, 

First, and foremost, I would disagree with this area being classified as an ACEC. 

This area is very small and not significant enough to warrant critical 

environmental concerns. The impact on the areas environment would be 

minimal. Instead the area could remain under current management plans. 

Management of this area under ACEC would adversely effect private property 

owners, as this area is greatly mixed with private property that is being 

developed. Recently, Beartooth Electric Coop and Nemont telephone company 

extended service lines into this area in order to service permanent year round 

residences. Managing this area as an ACEC would effect BLMs policy on wildfire 

management. The preferred plan of allowing naturally started fires to burn would 

not be acceptable in this area, as much of the BLMs property closely borders 

private parcels, some with structures and dwellings already on them. Not 

allowing mechanized ground firefighting vehicles to contain or suppress these 

types of fires could be detrimental to these structures, and may result in 

subsequent legal battles for the BLM. Additionally, the winds are much to strong 

in this area to permit an " ignore type policy" of fire management.

N

"Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS.

DRMTDK-BL13-0032-1

Recreation 

I am commenting on the Billings & Pompeys Pillar National Monument Draft 

Resource Management Plan Revision and specifically as it relates to Section 28, 

2N, 15E. This section has been badly abused for years - trash dumped 

everywhere, water tanks shot up, dirt bike tracks all over the land, fences onto 

my land cut as well as locks shot off gates going onto my land. A stolen car was 

even pushed into one of the ravines. A few years ago the section was shut off to 

vehicular traffic and this has helped, but it is still abused - the fence has been cut 

and shot going onto the land, the signs stating that the land is off limits to 

vehicles is nearly unrecognizable because there are so many shell holes in it. 

There are shell casings scattered everywhere outside the section and on the 

section. The lock on the gate going into the land has now been shot off three 

times. Besides these problems it is sometimes seriously dangerous for us as the 

lessors to travel on the land. We never know exactly when someone is shooting 

out there and several times when we have been out checking water, fences or 

cows we have heard shells ricocheting off rocks nearby. More than once I have 

appeared over the hill only to find myself nearly directly in the line of fire! Luckily 

no personal mishaps so far and none of our cattle have been shot, but it worries 

me that this is a ticking time-bomb waiting to explode. My feeling is that the BLM 

needs to pay much more attention to this section, police it better and if it is to 

continue as a shooting range, make it much safer for Keewaydin Ranch. I am 

not sure anyone who uses it is really aware that we lease it and are out there on 

a somewhat regular basis.

n

"Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS.

DR- lands with Please manage Weatherman Draw, Bad Canyon, Yellowstone River Islands and n "Thank you for expressing your concerns. While statements of opinion 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-47

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

MTDK-BL13-0034-1wilderness 

characteristi

cs

Clark's Fork River islands for wilderness, and also areas identified as having 

wilderness characteristics.

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS

DRMTDK-BL13-0035-1

Recreation

Four Dances Natural Area: We strongly support your preferred alternative to 

develop non-motorized recreational opportunities Four Dances Natural Area. We 

request that you make specific mention that biking would be allowed or, at 

minimum, that a feasibility study would be conducted. Four Dances has the 

unique potential to be connected to the Billings trail system. One idea that is 

being explored is the creation of a bike/pedestrian facility on a proposed new 

bridge for Interstate 90 across the Yellowstone River. This would have the 

potential of connecting the existing bike/pedestrian trail at Coulson Park with the 

northern end of Four Dances and further increase bike and pedestrian use in 

Four Dances. We encourage you to make an expressed decision to work with 

local partners to pursue federal/state funding sources, to connect the City of 

Billings to public lands (e.g. Paul Sarbanes Grant/Federal Lands Access 

Program/Recreation Trail Program).

N

"Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS. 

DRMTDK-BL13-0035-2

Recreation

Lewis and Clark Corridor : Bike Net is also supportive of the preservation of the 

Lewis & Clark River Corridor along the Yellowstone River. Bike Net has 

partnered with the Billings Chamber of Commerce and Yellowstone River Parks 

Association to develop a trail corridor analysis for a future connection between 

Riverfront and Mystic Parks. The preferred location of this connection would be 

along the Yellowstone River. Bike Net supports the establishment of a 

management corridor along the Yellowstone River and the proposed actions to 

protect the scenic values and limit development within the corridor. We also 

strongly support the decision to work with willing sellers to acquire 

easements/acquisitions along the Yellowstone River to provide for public access 

to a future trail corridor that would radiate out from Billings and allow for 

expansion of the existing trail network along the Yellowstone River.

n

Thank you for your comments. Please see Appendix J for land acquisition 

criteria. 

DRMTDK-BL13-0035-3

Recreation

Acton Recreation Area : We know that BLM has been exploring opportunities to 

develop bike trails in this area. We request that you include specific language 

that confirms your commitment to developing bike trails in the area. Suggested 

language could be: "Develop mountain biking opportunities for a range of skill 

levels. Include cross-country and gravity fed (downhill) trails with appropriate 

facilities."

n

"Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS.

DRMTDK-BL13-0035-4

Recreation

Shepherd Ah-Nei Recreation Management Area: We also see the Shepherd 

area as having an enormous potential for future bike trail development. We ask 

that you add language to specifically include the intention to develop mountain 

bike trails in this area. We support your active management of OHV uses in this 

area and feel that it would be equitable and would help prevent conflict if bike 

n

"Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-48 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

trails were provided. RMP/EIS.

DRMTDK-BL13-0035-5

Recreation

South Hills Motorcycle Area: We support responsible and sustainable 

management of motorized uses and believe that there should be opportunities 

for these uses. However, we are concerned with the impacts that are evident at 

the South Hills area. The numerous motorized hill climbs are not only an impact 

to the natural resources, but are also an impact to the aesthetics of the riverfront 

trail, particularly from Riverfront Park. We request that you limit motorcycle use 

to designated trails, with an emphasis on restoring the landscape visible from the 

riverfront trail system to meet the visual resource objectives in your preferred 

alternative.

n

Thank you for your concern and comments. The Visual Resource Objectives in 

the preferred Alternative and carried forward in the decision are to manage for 

VRM Class III, which provides for this kind of activity. The RMP decision is also 

to continue to manage the lands as an “open”, (cross-county) Motorcycle-only

use Area. 

DRMTDK-BL13-0045-1

Travel Mngt

I urge you to designate non-motorized trail routes in the final Resource 

Management Plan to provide recreational outdoor opportunities for parts of the 

Pryors. I ask that the Big Sky Trail and Bear Canyon Creek Trail and the 

Demijohn Flat route be designated for only non-motorized use. These three 

areas would provide people on foot a chance to hike without worries of 

motorized vehicles.

n

"Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS

DRMTDK-BL13-0045-2

Travel Mngt

BLM's preferred alternative authorizes motor vehicle use of Graham Trail up the 

southwest slope of Big Pryor Mountain. That makes three redundant parallel 

motor vehicle routes within less than three miles. One of the three routes should 

be designated for non-motorized use. Of the three routes, Bear Canyon, through 

an Audubon Important Bird Area, would be the best non-motorized route. There 

would still be abundant motorized access to Big Pryor Mountain with four more 

motor routes up the west slope

n

"Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS. The decision to establish a non-motorized trail in Bear Canyon has 

been made and will be in the final RMP.

DRMTDK-BL13-0049-1

lands with 

wilderness 

characteristi

cs

You have identified 12 areas in the South-Central Management Plan as 

wilderness-quality lands but have proposed to manage only 9 of these areas. 

Please commit to a more balanced management of wildlands to safeguard the 

last unprotected wildlands in South-central Montana. I urge you to manage 

Weatherman Draw, Bad Canyon, Yellowstone River Islands and Clark's Fork 

River Islands like the other lands you have identified as having wilderness 

qualities by closing the areas to oil and gas leasing, designating the areas as 

excluded for wind farms, closing these wildlands to the construction of the travel 

management plan.

n

"Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS. The management emphasis for some of the lands is ACEC, which is 

a priority identified in FLPMA, and which the BLM has established appropriate 

management prescriptions. Other units are managed as SRMA, with similar 

considerations given to them. 

DRMTDK-BL13-0054-1WILD 

HORSES,

PMWHR

I encourage the BLM to work with the National Park Service and reintroduce the 

Sorenson Extension into the horse range. Adding the mountaintop areas and 

including the open meadows and Tony Island Spring would be a huge step 

forward in repairing the public's mistrust of the BLM's wild horse and burro 

mistreatment.

N Thank you for your comment

DRMTDK-BL13-0054-3

PMWHR, 

Recreation

We also support BLM's decision to not allow target shooting on the mountain top 

area during the summer months but add that it should be prohibited throughout 

the entire PMWHR area! It causes undue stress not only to the wild horses, but 

to all other wildlife, increases the risk for accidental shootings of animals and 

n

"Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-49

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

other public visitors on the mountain. Again, enforcement is key! record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS.

DRMTDK-BL13-0058-1

Social/econ

In review of the BLM RMP being proposed it is clear your agency is not 

adequately considering the social and economic impact of the decision in any of 

the alternatives presented in the DEIS. It is common practice to use the IMPLAN 

modeling system for analysis of social and economic impacts but this modeling 

analysis is highly dependent on the accuracy of the data input in order to 

generate any form of reliable output. It is clear your agency has used input data 

which is based on "assumptions, estimates, predictions, potentials, could be, 

may be, expected, approximately, and about" as all of these words are used 

hundreds of times throughout the DEIS. The DEIS is full of these words and 

lacks sufficient supportable facts to make a justified decision to close vast 

amounts of federally managed BLM land in Montana to resource development, 

grazing, active forest management and multiple use recreation.

n

Opinion: Response: No text revision necessary (Thanks for the comment. 

Resource outputs are the amount of a resource (e.g., AUMs, recreation visits, 

tons of locatable minerals, etc.) that would be available for use under each 

alternative. Resource specialists projected annual resource outputs based on 

the best available information and professional judgment. Based upon public 

comments, resource specialists have reviewed assumptions used in this 

analysis to see if they need to be changed or updated. These revised 

assumptions have been incorporated into the analysis contained in the DEIS. 

The purpose of the economic analysis is to compare the relative impacts of the 

alternatives and should not be viewed as absolute economic values. Previous 

modeling experience has shown that the data contained in the IMPLAN 

modeling system for the various sectors are accurate representations of 

impacts. )

DRMTDK-BL13-0058-

10

Social/econ

The recreation analysis is lacking in accuracy as the spending of users is not 

accurate. On page 4-409 of the DEIS it states that "for every 1000 visitor days, 

there would be a corresponding change of .15 jobs and 3,804 in labor income." 

Further statements include impact from non local-overnight and local overnight 

jobs and income. We know by the visitor use survey conducted by the Forest 

Service that spending per visitor user day is much higher than the $3.80 value 

included in your DEIS and the overnight value of $14.06 you used. The numbers 

used by the Forest Service are more than $100 per local visitor day and $300 

per non-local visitor day. These numbers were from several years ago when fuel 

prices were less than a third of what they are today. Adjusted for inflation the 

cost per user day has risen substantially. I request you take a hard look at your 

user day expenditures included in your DEIS and adjust them to better reflect the 

true economic impact of recreation in your DEIS and present a true reflection of 

recreational spending to the public.

n

Labor income is not equivalent to visitor spending. If a BLM visitor spends $100 

at a hotel, only a fraction of that will translate directly to local income. Therefore, 

the division of labor income by visitor days to determine visitor spending is not 

appropriate. Indeed, this analysis uses the best available estimates of visitor 

spending from Stynes and White 2010, as cited on pg. 4-597 of the DEIS. 

These are the same data as used by the Forest Service. These data indicate 

that non-local day visitors spend $65/day, non-local overnight visitors spend 

$366/day, local day visitors spend $34/day, and local overnight visitors spend 

$177/day.

DRMTDK-BL13-0058-

11

Social/econ

On page 3-159 of the DEIS it states that jobs in agriculture make up 18 percent 

and on page 3-160 of the DEIS it states that employment in recreation and 

tourism make up another 42 percent of the jobs. This total of 60 percent shows 

the large majority of jobs in the planning area are from agriculture and 

recreation. On page 3-163 of the DEIS the matrix chart reflects the usage types 

for recreation. Your conclusion from this table reflects more than 60 percent of 

the use is driven by fish and wildlife. You use this determination to bolster your 

conclusion of the importance of wildlife and does not accurately reflect the 

importance of access. I believe your analysis of the information in the chart on 

page 3-163 is flawed.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

DRMTDK-BLTravel Mngt In the planning area of the DEIS I would submit that all of the uses described on 

page 3-163 require motorized access of roads to achieve enjoyment of these n

Thank you for your comments and your concern. We appreciate the interest in 

management of public lands. While statements of opinion (including agreement 
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12

activities. You have not clearly identified the way people have historically 

accessed these lands for the activities listed. I request you address this 

discrepancy in your analysis to reflect how people really access these areas. 

The planning area is vast and without adequate access of roads, the planning 

area will become void of human activity.

or opposition) do not require specific responses or text revisions under NEPA 

regulations, they have been considered by the Billings Field Office and 

Montana State Office and documented in the administrative record associated 

with the Billings and Pompeys Pillar National Monument RMP/EIS

DRMTDK-BL13-0058-

13

wildlife

I am also astounded by the number of government jobs associated with the 

management of this area. Over 150 BLM jobs and the DEIS has little information 

gathered from these employees and incorporated into the DEIS. Most of the 

work on the DEIS was subcontracted and little if any ground truth information on 

bird or animal populations was provided by the BLM. Bird populations have 

skyrocketed in this area and now predator populations are following historic 

trends of increasing during times when the food source is increasing. Your 

analysis and conclusions are flawed in proposing that human presence and 

surface occupancy is the cause of possible Sage Grouse extinction. Clearly 

history shows that both food source and predator populations cycle historically. 

Low food source results in a die off of predators from starvation and the predator 

die off results in a slow increase of food source animal populations. The increase 

of food source animals, results is a slow increase of predator population, until 

the predators kill the food source and reach unsustainable levels and begin to 

die off because of lack of food source and this cycle continues and will continue 

through all of time. The DEIS fails to mention this important fact and I request 

the BLM include an analysis and science based information regarding trends in 

food source animal populations in comparison to predator populations.

n

Thank you for the comment. Predator control was not included as a threat in 

the FWS’s listing decision; however, the BLM and the Forest Service 

acknowledge that localized predation may be a factor in the conservation of 

greater sage-grouse in some areas. In these areas, the states possess primary 

authority and responsibility for managing the wildlife within the state and the 

BLM and the Forest Service are responsible for managing habitat. 

Montana Fish, Wildlife and Parks manage wildlife within Montana, while the 

BLM and Forest Service focus on managing habitat. Consistent with a 

Memorandum of Understanding between the BLM and the US Department of 

Agriculture, Animal and Plant Health Inspection Service-Wildlife Services, the 

BLM and Forest Service will continue to work with Montana Fish, Wildlife and 

Parks to meet state wildlife population objectives. Predator control is allowed on 

BLM- and Forest Service-administered lands and is regulated by the MT FWP 

and Animal Plant and Health Inspection Service (APHIS). APHIS conducts 

environmental analyses in accordance with the National Environmental Policy 

Act (NEPA). The BLM and Forest Service will continue to work with agencies to 

address current predation of greater sage-grouse, and BLM and Forest 

Service-administered lands in the planning area will remain open to predator 

control under state laws. Additionally, the BLM and the Forest Service will 

continue to work with the involved states to meet state wildlife population 

objectives. 

While adding management actions specifically to manage predators is outside 

the scope of the amendment, the BLM and the Forest Service have authority to 

manage the habitat and have provided numerous management actions across 

the range of alternatives. Altering the sagebrush habitat of the greater sagegrouse can create an influx of predators into an area and lead to a population 

decline. Roads, fences, power lines, trails and other disturbances may make 

access easier for potential predators and increase risks to the species. The 

Draft EIS calls for measures that will substantially reduce disturbances in the 

bird’s habitat, thus reducing predation risk. The Draft EIS also calls for careful 

monitoring of grazing allotments within sage-grouse nesting habitat to ensure 

suitable grass and forb cover is reserved so we can minimize the associated 

predation risks.

In addition, predator control is described in “Management Common to all 

Alternatives”, Table 2.6.1, page 2-69.
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BLM also has a Memorandum of Understanding (MOU) with APHIS –Wildlife 

Services (WS) that describes responsibilities of each of the agencies. WS is 

responsible for preparation of the NEPA documentation, annual Animal 

Damage Management Work Plan, and implementation. BLM cooperates with 

review and approval of their plans on public lands.

DRMTDK-BL13-0058-

14

Social/Econ

The major problem with your use of the IMPLAN system is this system uses data 

and information from major urban areas and no information from small 

communities are gathered or included. Clearly the statement in the DEIS that 

"very small towns dependent on agriculture" shows your agency acknowledges 

the negative impact your decision will have on their communities but through the 

IMPLAN system this information and fact is lost. Take a hard look at these two 

statements and do further analysis on the impacts your decision will have as this 

directly relates to the environmental justice of the decision.

n

The IMPLAN data are comprehensive - it includes data from both metropolitan 

and non-metropolitan areas. It is neither feasible nor desirable to conduct 

economic impact analyses on very small scales (e.g., zip code level) due to the 

economic linkages between communities. A small-scale IMPLAN analysis 

would fail to capture the labor and trade flows between communities and the 

economic consequences would be underestimated. As a result, consequences 

particular to small communities are addressed in the social analysis. The social 

analysis addresses environmental justice considerations on pg. 4-590, which 

describe the potential for disproportionately adverse effects on low income 

individuals and communities.

DRMTDK-BL13-0058-

15

Wildlife 

On page 4-398 the DEIS states:" Because the long-term decline in wildlife 

habitat would continue under this alternative" The BLM has no sound science 

based information or facts to support this statement. The no action alternative 

must be attacked by your agency and seen as not acceptable in order for the 

BLM to justify changing management direction. Please take a hard look at this 

statement and provide me with the information and science used in your 

determination that this statement is true.

n

Thank you for your comment. This comment refers to the Miles City draft 

RMP/EIS, not the draft Billings and Pompeys Pillar National Monument 

RMP/EIS. 

DRMTDK-BL13-0058-

16

Recreation 

4.3.3.3.11 states:" Recreation management actions, including designation not 

SRMAs and ERMAs, could result in land ownership adjustments " I question the 

direction of the BLM in making designations which would adversely affect private 

property ownership that would reduce the ability of a person to enjoy full use and 

expected return on their capital invested. This action could be viewed as a 

violation of one's constitutional rights of property ownership and would result in 

litigation brought against the BLM. 4.3.3.3.11 also states: "Proposed facilities, 

such as power lines, may need to be mitigated to minimize the impacts to 

recreational setting and experiences....." This could mean that because the BLM 

is putting high priority on non-motorized recreation, public facilities such as 

power line construction would be denied on the false basis of an adverse effect 

on non-motorized recreation. While power lines would not be adverse to 

motorized recreation and could actually enhance additional motorized recreation 

opportunities, the BLM would deny public benefit services on the basis of their 

possible effect on the BLM's preferred recreation activity. This action could be 

viewed as prejudice in nature and action. I request the BLM take a hard look at 

whether a preferred activity by employees of BLM, without consideration of 

science based information, would reflect a prejudice within the agency towards a 

particular segment of the population. This action would not be based on relative 

n

Thank you for your comments. In regards to the statement regarding adverse 

impacts of BLM decisions on private property, all decisions have 

consequences. However; 

Please see FLPMA, the Code of Federal Regulations, etc. BLM is charged with 

managing these lands and is directed to develop this RMP. 

In regards to the specific comment on SRMA/ERMA designation, the BLM RMP 

has extensive discussions throughout the document regarding mitigating 

measures and nowhere does the text state or imply that public facilities or 

access to private lands would be denied solely on the basis of establishment (or 

not) of a Recreational Management Area designation. 

Please see FLPMA, the Code of Federal Regulations, BLM Recreation 

Management Manual, etc. 

Regarding the statement of closures of vast public lands tracts currently open 

for OHV use, please see the RMP for actual acreages closed 
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facts and information but rather on emotion and prejudice. Multiple use 

recreation including motorized segments has increased by 156 percent in the 

last few years and provides substantial economic and social benefits. Ignoring 

this increased demand for access in the formulation of the Billings RMP would 

show complete disregard for the public needs. Vast areas of BLM land in the 

Billings RMP are targeted to be closed to the majority of Americans. Ignoring the 

facts of desired access opportunities in making the decision to close these public 

lands is completely contrary to the mission and goals of the BLM agency. This 

decision would be arbitrary and capricious in not considering the benefits of 

multiple use access for recreation, active forest management and responsible 

resource development.

Regarding the closure of large tracts of public land specifically due to the 

closure of access routes, please see the Travel Management sections 

throughout the RMP, Appendix O, and the associated Travel Management 

maps. No main access routes are closed. Routes that are closed have specific 

resource concerns, which are identified in the vehicle route inventories, 

available for review at the BLM office. Please see also BLM Manual 1626, 

Transportation and Travel Manual, for the process by which BLM manages its 

travel system. 

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17

Social/econ

3.32.2.3 states on page 3-249: "Oil and gas production in Montana is not subject 

to ad valorem, or property taxes; rather it is subject to production taxes". This 

statement ignores the fact that oil and gas producers do pay property taxes. 

Some of these taxes are Class 9, centrally accessed; and some are locally 

accessed as value based on Class 8, industrial personal property; or Class 4, 

real property; or Class 9, personal property; or Class 15, pipelines; or numerous 

other taxes including vehicle taxes, fuel taxes, etc. These oil and gas companies 

also employ thousands of people who also contribute to the overall local, county 

and state tax base through payment of property and income taxes. The IMPLAN 

system being used by BLM to estimate the economic impact of these businesses 

is flawed in the lack of adequate consideration of these additional contributions 

by the supporting businesses and employees in the taxes paid and this support 

for government services.

N 

The IMPLAN data are comprehensive - it includes data from both metropolitan 

and non-metropolitan areas. It is neither feasible nor desirable to conduct 

economic impact analyses on very small scales (e.g., zip code level) due to the 

economic linkages between communities. A small-scale IMPLAN analysis 

would fail to capture the labor and trade flows between communities and the 

economic consequences would be underestimated. As a result, consequences 

particular to small communities are addressed in the social analysis. The social 

analysis addresses environmental justice considerations on pg. 4-590, which 

describe the potential for disproportionately adverse effects on low income 

individuals and communities. Previous modeling experience has shown that 

the data contained in the IMPLAN modeling system for the various sectors are 

accurate representations of impacts. )

DRMTDK-BL13-0058-

18

Travel Mngt

4.3.3.3.14 states: "Upon completion, roads used for commercial and 

administrative access would be reclaimed, unless the route provides benefits for 

public access, which would be determined through subsequent analysis." This is 

concerning to CBU because of the previous statement above of possible 

prejudice within the BLM agency. It looks as though the BLM will obliterate road 

and trail facilities upon completion and decision of the RMP. Ripe, slash and 

seed contracts will be issued and infrastructure will be destroyed. The Billings 

RMP is lacking in specifics of road and trail identification as to properly inform 

the public on which facilities are to be closed. The statement that these facilities 

will be specifically addressed later on a case by case basis is clearly not true. 

There will be no effort made at a later date to address specific roads and trails 

when the current RMP document fails to identify these facilities. These access 

roads and trails are critical to the health, safety and welfare of the people in 

Montana and as such must have careful consideration before closing them. 

Local engagement in identifying these important facilities and the coordination 

between local governments and the BLM in the decision is critical. Clearly the 

BLM failed in coordinating with local governments as the DEIS does not list a 

n

The RMP provides general direction. The Travel Plan is a separate document 

being prepared at the same time as the RMP, (it has a separate decision) and it 

clearly states that the Travel Management Areas (TMAs) would have individual 

implementation plans. These plans would address actions of this type. If 

additional routes are constructed (for whatever reason) through the life of the 

RMP, these would have individual and specific NEPA analysis. 

In regards to coordinating with local governments, please refer to the document 

for details of public and interagency coordination efforts which have been done. 
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single coordinating local government. A decision that ignores the required local 

government coordination is both arbitrary and capricious.

DRMTDK-BL13-0058-

19

Recreation, 

Social/Econ

3.32.2.4 states: "Nature-related recreation activities on BLM lands, e.g. fishing, 

hunting, and other wildlife related recreation use accounts for 30 percent of total 

use; non-motorized related recreation, e.g. backpacking, bicycling, camping, 

caving, hiking, horseback riding, photography, and picnicking account for about 

60 percent, and motorized-related recreation, e.g. driving for pleasure and OHV 

use account for about 10 percent of total use." This statement is false, 

misleading and distorted to further an agenda within the agency. All of the listed 

non-motorized activities above require motorized access. The BLM lands subject 

to this decision are far removed and in most cases remote. Surveys show an 

average nonmotorized user travels 2 to 4 miles in their activity e.g. hiking, 

backpacking, etc. I request the BLM further analyze non-motorized use profiles 

in their analysis. Surveys also show that less than 3 percent of people recreate 

in wilderness areas which restrict all forms of motorized and mechanized use. 

More than 97 percent recreate in multiple use areas that allow motorized and 

mechanized use. This fact supports the need for multiple use roads and trails for

people to enjoy the opportunities available on federally managed public lands. 

The belief and statement in the DEIS that non-motorized recreation accounts for 

"about 60 percent" is not supported by fact. Most use of public lands requires 

motorized transportation to access these areas. Motorized recreation is the most 

popular sport of leisure and the fastest growing activity. To ignore this fact and to 

distort the preferred recreation activity in the BLM RMP and CBU believes this 

misinformation presented in the RMP is clearly intentional on the part of the BLM 

ID Team. Prejudice against a particular social segment of the population is a 

violation of federal law as it relates to environmental injustice. Environmental 

injustice includes both social and economic impacts. Please consider revising 

the RMP to include the importance of motorized recreation opportunities and the 

importance of vehicle access to these lands for enjoyment of nonmotorized 

activities mentioned in the RMP. Refusal to take a hard look and include this 

analysis of the importance of motorized access and a correction of user 

percentages in the RMP will result in a decision that is both arbitrary and 

capricious.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

Please be aware that the BLM recently issued its Travel and Transportation 

Management Manual (BLM Manual 1626) which provided detailed policy, 

direction, and guidance for the BIFO staff to establish a comprehensive

program for travel and transportation.

The Manual is an interdisciplinary approach to travel and transportation 

planning and implementation guidance for management actions that addresses 

resource uses and associated access to public lands and waters, including 

motorized and non-motorized, mechanical and even animal powered modes of 

travel. The first section of this Manual lists all the applicable legal Authorities 

(FLPMA, Omnibus Public Land Management Act, NEPA, ESA, Antiquities Act, 

etc.) which BLM is required to follow and which the BIFO staff has adhered to in 

the development of the Travel Management Section decisions of the RMP. 

DRMTDK-BL13-0058-2

NEPA

Page 4-628 states that BLM lands are managed to "foster" multiple uses yet all 

of the alternatives including the preferred alternative propose to close large 

areas of BLM managed land to multiple uses. This action is contrary to the 

management propose and goals of the BLM agency.

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS. The BLM is required to manage the public lands on the basis of 

multiple use and sustained yield and to meet the needs of present and future 

generations. As the human population continues to increase and social values 
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evolve, resource conflicts are likely to increase. More importantly, the 

American public is increasingly aware of the importance of the public lands to 

its well-being and is demanding a larger voice in resource management 

decisions (H-1601-1). Land use plans ensure that the public lands are 

managed in accordance with the intent of Congress as stated in FLPMA (43 

U.S.C. 1701 et seq.), under the principles of multiple use and sustained yield. 

As required by FLPMA and BLM policy, the public lands must be managed in a 

manner that protects the quality of scientific, scenic, historical, ecological, 

environmental, air and atmospheric, water resource, and archaeological values; 

that, where appropriate, will preserve and protect certain public lands in their 

natural condition; that will provide food and habitat for fish and wildlife and 

domestic animals; that will provide for outdoor recreation and human 

occupancy and use; and that recognizes the Nation’s need for domestic 

sources of minerals, food, timber, and fiber from the public lands by 

encouraging collaboration and public participation throughout the planning 

process. Land use plans are one of the primary mechanisms for guiding BLM 

activities to achieve the mission and goals outlined in the Department of the 

Interior (DOI) Strategic Plan. (H-1601-1)

DRMTDK-BL13-0058-

20

Social/Econ

3.32.2.4 also states on page 3-250: "This is less than one tenth of one percent of 

Yellowstone County employment and income." This reflects information and 

analysis done through the IMPLAN modeling. IMPLAN only uses information on 

economic impacts collected from large metropolitan areas and ignores the 

economic impact to small communities. The closure of large areas of BLM land 

to surface occupancy will devastate small towns and communities and this fact is 

being ignored. A reduction in Yellowstone County of less than one tenth of one 

percent does not reflect the direct impact to small towns dependent on federally 

managed public lands. Many times these small towns and communities depend 

on these public lands for the majority of their income and economic stability. 

Surveys conducted by CBU have shown that some small communities receive 

60 percent of their income as a result of people using and enjoying these public 

lands. Not only hunters, fishermen, campers and others, these communities are 

highly dependent on these lands for continued agriculture operations and energy 

development. All these uses are highly dependent on both motorized access and 

surface occupancy. To analyze the economic effect of this decision based on 

only large populated areas and the effect on the economics of only these 

populated areas is clearly a lack on the part of BLM to provide a complete and 

factual picture of the effects this RMP will have on small communities. I request 

further analysis be done to address these deficiencies in the Billings RMP.

N 

The IMPLAN data are comprehensive - it includes data from both metropolitan 

and non-metropolitan areas. It is neither feasible nor desirable to conduct 

economic impact analyses on very small scales (e.g., zip code level) due to the 

economic linkages between communities. A small-scale IMPLAN analysis 

would fail to capture the labor and trade flows between communities and the 

economic consequences would be underestimated. As a result, consequences 

particular to small communities are addressed in the social analysis. The social 

analysis addresses environmental justice considerations on pg. 4-590, which 

describe the potential for disproportionately adverse effects on low income 

individuals and communities.

DRMTDK-BL13-0058-

Travel Mngt

3.22 states on page 3-197: "ATVs and motorcycles" "increased by 156 percent 

from 1990 to 1998" and "OHV use is one of the fastest growing activities in 

Montana." The Billings RMP acknowledges the growth of this industry and yet 

N

Thank your for your comment. 

We appreciate the interest in management of public lands. While statements of 
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21 the RMP proposes to close much of the BLM managed land to this use. The 

decision should reflect the desire and preference of motorized use yet the BLM 

is ignoring these facts and putting forth instead an agenda driven decision. Our 

questions regarding this decision posed to the agency reveal the excuse and 

reasoning behind this plan as nothing more than their response to litigation on 

sage grouse listing. The BLM is being driven by court decision rather than best 

available science which are in direct conflict and violation of laws and regulation 

that guide this agency. If motorized recreation is increasing, and non-motorized 

is declining or stagnant, then why is the preferred alternative ignoring these facts 

unless the decision is indeed being driven by a litigation response rather than 

factual based information. The BLM has indicated they must restrict more land to 

access and surface occupancy and the analysis reflects only information to 

justify the decision rather than true, science based information that would 

contradict the reasons being used for closures. This is clearly an effort on the 

part of BLM to use selective science and information that supports a decision 

that the BLM has already made. The no action alternative would allow a growth 

of recreation opportunity, a growth of responsible energy development of benefit 

to people and communities, a growth of ability to actively manage these lands, 

but instead because of the preconceived agenda of closures, the BLM is only 

including analysis, science, and information in support of their decision. I request 

the BLM address this issue of predetermined outcome and analyze the 

possibility that this decision was predetermined and if the DEIS is truly an effort 

to engage the public or just a dog and pony show to comply with NEPA. In the 

eyes of CBU it is clearly the latter.

opinion (including agreement or opposition) do not require specific responses or 

text revisions under NEPA regulations, they have been considered by the 

Billings Field Office and Montana State Office and documented in the 

administrative record associated with the Billings and Pompeys Pillar National 

Monument RMP/EIS. Regarding the closure of large tracts of public land 

specifically due to the closure of access routes, please see the Travel 

Management sections throughout the RMP, Appendix O, and the associated 

Travel Management maps. No main access routes are closed. Routes that are 

closed have specific resource concerns, which are identified in the vehicle route 

inventories, available for review at the BLM office. Please see also BLM 

Manual 1626, Transportation and Travel Manual, for the process by which BLM 

manages its travel system. Also refer to BLM’s direction under the principles of 

“Multiple Use” and “Sustainability” 

DRMTDK-BL13-0058-

22

Recreation

Adequate recreational opportunity for all visitors is the supreme issue that must 

be addressed by this action. The relative importance of recreation on a national 

basis is demonstrated by the Bureau of Economic Analysis statistics for 

spending on recreation. In 1979 the index for recreation spending was 32.537 

(year 2000 = 

100,).http://www.bea.govinational/nipaweb/TablePrint.asp?FirstYear=1979&Last

Year=2004&Freq=Year&SelectedTable=33&ViewSeries=NO&Java=no&MaxVal

ue=155.606&MaxChars=7&Request3Place=N&3Place=N&FromView=YES&Leq

a1=Y&Land=In 2004, the index was 113.695 for an increase of 349%. No other 

sector has increased this dramatically. Clearly, the public wants and needs 

adequate recreational opportunity and this should be the overarching theme of 

this evaluation and decision. Many federal actions have led to the continual 

closure of motorized recreational opportunities and access while during this time 

the number of OHV recreationists has grown to 50 million and at the same time 

other outdoor activities have declined 18 to 25% (Journal of Environmental 

Management 80 (2006) 387-

393,).http://www.redrockinstitute.org/uploads/PNAS.pdfandhttp://www.msnbc.ms

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 
Billings and Pompeys Pillar National Monument

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n.com/id/22998037/

DRMTDK-BL13-0058-

23

Wildlife

Northeast Montana has the healthiest, most diverse grassland ecosystem in the 

world. We have so many sage grouse that the Montana Department of Fish, 

Wildlife & Parks is transplanting some of them to Canada. This region's sage 

grouse production is in good shape due to decades of cooperation between 

ranchers and the BLM. The DEIS must adequately acknowledge this condition. 

The DEIS is focused on habitat and reflects no acknowledgement of healthy 

Sage Grouse populations.

n

Thank you for your comment. Using long term averages of male counts on 20 

leks from 1981-2007, the average male count was 672. The 2008 count was 

19.5 percent below the long term average or about 542 males. ( page 3-86, 

Billings RMP)

DRMTDK-BL13-0058-

24

Travel Mngt

The 3-State OHV decision and National OHV rule require site-specific data and 

analysis to be used in any actions that could affect OHV recreation. It also 

required all OHV use to remain on designated trails. 3.22 on page 3-198 states: 

"Overall, a small percentage of the total recreational OHV use in the planning 

area occurs cross country, suggesting a low frequency of motorized wheeled 

cross country travel." This indicates a high compliance with the 3-state OHV 

Rule which is only briefly mentioned in the DEIS. Compliance with the rules and 

regulations by OHV users shows the willingness for these folks to help in the 

protection of the resource. Yet also in 3.22 on page 3-197 it states: "Limited and 

closed designations help protect natural resources and minimize conflicts among 

various public land users." This statement is made despite the statement made 

on page 3-198 which I referred to in the previous paragraph and also with no fact 

based information in the DEIS that refers to user conflict reports. The fact is that 

no resource damage occurs where motorized use remains on designated roads 

and trails and with no information in the DEIS being presented that shows user 

conflict, the BLM is making false statements. I request the BLM document user 

conflict and provide reports of user conflicts that are documented by names, 

dates, and places these user conflicts occurred.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

The request for documentation of user conflicts is beyond the scope of the RMP 

– it is a compliance issue. Please contact the BLM for the details on the 

process to acquire this information. 

DRMTDK-BL13-0058-

25

Travel Mngt

If the DEIS states there is little if any off trail and road riding that is occurring, 

then one would expect little if any resource damage has been experienced. With 

little if any specific road and trail evaluation being done prior to the DEIS being 

released it is reasonable to assume the BLM has absolutely no information to 

support the resource damage or user conflict statement. A decision based on 

little or no information would surely be considered to be arbitrary and capricious. 

I request the BLM take a hard look at the information used to make these 

statements and provide valid information to the public so as we can review this 

information and comment.

n

The BIFOI conducted an extensive route inventory These inventories also 

specifically noted evidence such as erosion scars which the BIFO then used in 

designating its route system. 

The Travel Management Appendix O provides an extensive impact analysis 

discussion on each of the Alternatives and their proposed route system 

segments. 

DRMTDK-BL13-0058-

26

Wildlife 

Next in line affecting sage grouse populations are natural conditions including 

weather and fires and induced conditions such as wolves and predators. Sage 

grouse populations are significantly impacted by natural conditions including 

drought. The benchmark for evaluation of impacts on sage grouse by OHV 

recreation should be established by comparison to these natural conditions and 

hunting regulations. The evaluation and subsequent decision-making must be 

n

Thank you for your comment. As natural conditions can have a major effect on 

wildlife habitat and populations, population trends were documented over a 

relatively long time-frame of 26 years within the Billings Field Office. “Mitigation 

Measures and Conservation Actions for Greater Sage-grouse Habitat” 

Appendix AA (section F) discusses measures for mitigating impacts from OHV, 

recreation, and other surface disturbing and disruptive activities.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-57

Comment 

Number Topic Comment Text

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based on comparison to these real world conditions.

DRMTDK-BL13-0058-

27

Soils, 

recreation, 

wildlife

An adequate sense of magnitude must be employed within the analysis and 

decision-making. For example, the total naturally occurring loss of soil from the 

Cibola National Forest is estimated to be on the order of 1,577 acre-feet per year 

(1,892,000 acres total forest area times a depth of 0.008 feet of soil loss per 

year). The loss associated with OHV use is on the order of 52 acre-feet (5,200 

acres of roads and trails times a depth of 0.01 feet of soil loss per year). 

Therefore, the soil erosion associated with OHV recreation is relatively 

insignificant compared to the naturally occurring erosion rate and acceptable for 

multiple-use lands. Moreover, there are many mitigation measures that can be 

employed to reduce soil erosion on roads and trails while still allowing the public 

to enjoy them. Other examples that should be part of the evaluation include the 

naturally occurring mortality rate of sage grouse compared to the mortality rate 

associated with OHV recreation. The evaluation and disclosure to the public 

must include the analysis and a comparison of the magnitude of OHV impacts to 

naturally occurring impacts for all resource areas used to assess impacts based 

on site-specific data. Lack of the comparison of impacts to naturally occurring 

levels combined with the lack of site-specific data could allow inaccurate 

statements and opinions due to the lack of an adequate sense of magnitude.

N

Thank your for your comment. 

We appreciate the interest in management of public lands. While statements of 

opinion (including agreement or opposition) do not require specific responses or 

text revisions under NEPA regulations, they have been considered by the 

Billings Field Office and Montana State Office and documented in the 

administrative record associated with the Billings and Pompeys Pillar National 

Monument RMP/EIS

DRMTDK-BL13-0058-

28

wildlife

Examples of the popularity and magnitude of the lek viewing activity include: 

http://www.craigdailypress.com/news/2011/mar/01/local-environmental-qroupsorqanizing sage-grouse-/ http://www.siskadee.org/view.htm 

http://www.gorp.com/parks-guide/travel-ta-birdwatching-la-junta-comanche-andcimarronnationalqrasslands-golden-spike-national-historic-site-sidwcmdev 

055433.html http://coIoradobirdinqsociety.net16.net/zsbirdingspots.htm 

http://www.naturescapes.net/phpBB3/viewtopic.php?f=9&t=150579 

http://gf.state.wy.us/wildlife/wildlife management/sagegrouse/index.asp 

http://www.blm.govinstc/library/pdf/TN424.pdf 

http://wildlife.state.co.us/Viewinq/Events Festivals/PagesNiewingEvents.aspx 

http://billinqsqazette.com/lifestyles/recreation/b1m-wgf-holds-saqe-qrouselekviewinqtrip/article d3f3abe0-d2ec-56b1-9eb9-3cfad0a1d561.html?print=1

n Thank you for the comment.

DRMTDK-BL13-0058-

29

Social/econ

Agriculture is the number one industry in Montana. Sage Grouse populations 

have flourished because of the benefit of agriculture to their habitat. These 

improvements include grains and seeds from agriculture production, water 

facilities and haystacks for feeding and cover. All these benefits must be 

recognized and the Sage Grouse strategy must include a cost benefit analysis of 

the restrictions or potential removal of agriculture on the landscape.

n Opinion: Response: No text revision necessary (Thanks for the comment. 

DRMTDK-BL13-0058-3

NEPA, 

The CEQ has directed agencies to gather data from reliable sources such as 

interviews and information from local residents which the BLM has failed to do. I 

request your agency follow the CEQ requirement and gather more reliable 

information in completing the BLM RMP. Failure to gather true data on the social 

N Thank your for your comment. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-58 Chapter 5: Consultation and Coordination

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and economic impacts of this decision and to incorporate this information into 

the document would result in the decision being arbitrary and capricious.

DRMTDK-BL13-0058-

30

Social/econ

, NEPA

Any removal of energy development opportunities must also consider the 

potential loss of job opportunities. Economic benefits from energy production to 

communities, counties and the state must be considered as required by both 

MEPA and NEPA. Social and economic analysis is critical. A strong social and 

economic environment is critical in preserving wildlife habitat and wildlife 

populations.

N Opinion: Response: No text revision necessary (Thanks for the comment. 

DRMTDK-BL13-0058-

31

Wildlife

Private property rights must be protected and preserved. There should be no 

actions on the part of BLM to diminish private property rights in regards to Sage 

Grouse strategies proposed. Any proposed restrictions or regulations on land 

use must only apply to federally managed public land and must follow both 

MEPA and NEPA requirements in publication of proposed rules and in the 

consideration of public comments. Many times government agencies ignore the 

value of private property rights in their decision. CBU requests the BLM consider 

private property rights as vital to the survival of Sage Grouse and the protection 

of these rights to support the economies of local communities.

n

Thank you for your comment. Valid existing rights are protected in the 

document (pages 1-13, 16, 18).

DRMTDK-BL13-0058-

32

NEPA

There are some recent developments in Montana which the BLM should be 

made aware of. These recent actions should be considered by the BLM as valid 

reasons to delay this action. Several people and organizations have requested 

an extension of the comment period on this action and with these latest actions 

by the Montana 63rd Legislature, I would request an extension on the comment 

period of all 3 BLM RMP proposals. The legislature passed and the governor 

signed HB 169. This will become law on October 1, 2013. HB 169 codifies in 

state law, Title 76, the use of a Growth Policy as the legal document a local 

county may use to coordinate with federal agencies on land planning action that 

affect their county. Most of the counties in Montana have growth policies 

including most if not all of the counties affected by the 3 BLM RMPs. In the list of 

participants in this proposal there are many cooperating and collaborating 

agencies but not one coordinating agency. Coordination is required by federal 

agencies if local governments wish to engage and have a resource plan in place. 

HB 169 makes the Growth Policy the legal document the county can use to 

coordinate. The BLM must contact all counties affected by these 3 RMPs and 

ask if they wish to coordinate. Failure to make this effort on the part of the BLM 

would be in violation of several federal laws and acts.

N

Thank you for your comment.

Please see Chapter 4 for the environmental consequences and Section 1.5 for 

consistency between the Proposed RMP and county or local plans.

This planning area contains habitat for Greater Sage-Grouse. When BLM 

announced the National Greater Sage-Grouse Planning Strategy in 2011, we 

emphasized that we would be working under a very restricted time schedule in 

order to meet the court-ordered deadline for the U.S. Fish and Wildlife Service 

to reach a final determination on listing the Greater Sage-Grouse under the 

Endangered Species Act (ESA). At that time, we laid out an ambitious 

schedule. We remain committed to maintaining that schedule. Given the 

critical and time-sensitive nature of planning issues related to Greater SageGrouse priority habitat, we feel we will be unable to extend the 90-day public 

comment period, which closes on June 28, 2013 for the Billings and Pompeys 

Pillar National Monument draft RMP/EIS. We recognize that much is at stake in 

the sagebrush habitat across the West, including energy development, 

recreation, livestock grazing and fire management. We will continue to 

incorporate the most current information we have available as we complete our 

planning document. We remain committed to implementing the right policies 

and conservation measures now that will reduce long-term regulatory burdens 

on our stakeholders and to addressing the threats posed to the species so we 

can, ideally, help eliminate the need to list the species under the ESA. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-59

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

Throughout the development of the Billings and Pompeys Pillar National 

Monument draft RMP/EIS, the management team and specialists considered 

the public scoping comments as well as worked with the tribes, and the BLM’s 

cooperating agencies and local Resource Advisory Councils. In an effort to 

facilitate public outreach for the release of the Billings and Pompeys Pillar 

National Monument draft RMP/EIS, we prepared a series of communication 

tools, including comprehensive websites, and fact sheets to complement the 

draft plan. Several public open houses were scheduled within the planning 

area for the public to attend at least one event.

We will consider substantive and timely filed comments and respond to them in 

the Final EIS. All substantive comments received after the 90-day draft 

comment period and before a final decision is made will be considered to the 

extent feasible.

Finally, our management staff and planning team leaders are available upon 

request for one-on-one briefings, and we encourage you to take advantage of 

that offer.

DRMTDK-BL13-0058-

33

Wildlife

The Governor of Montana has set up a task force to study the Sage Grouse 

issue and formulate a plan to enhance their habitat and range. This task force 

seems worthless and a waste of time if the BLM develops and implements a 

plan without first considering the outcome of the task force. People on this task 

force are more familiar with the landscape, the resources, the surface owners, 

the issues related to habitat and animal populations, local economies and 

economic drivers, and the DEIS states on page 4-414 : The mineral revenues 

distributed to the state would be reduced by approximately $1 million." The $1 

million dollar reduction in revenue to the state of Montana is clearly an indication 

that the state has a very large stake in what the BLM does in their decision. For 

this reason the BLM should slow this process down and consider input into this 

plan from the recommendations of the task force set up by the Governor

n

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS.

DRMTDK-BL13-0058-

34

NEPA

The 63rd Legislature passed SJ15 which is a study bill. This study will analyze 

the current management practices on federally managed public land in Montana 

during the interim and the possibility of changes to these management practices. 

The study will look at the relationship between federal land management 

agencies and the state of Montana. I believe it is premature for the BLM to 

complete the 3 BLM RMPs before the Montana Environment Quality Council 

(EQC) has a chance to complete their work in regards to SJ15. I request the 

BLM delay their decision until such time as the EQC provides recommendations 

to the BLM on the proposed plan and subsequent implementation of this plan. 

The first meeting of the EQC is scheduled for June 19-20, 2013.

N Thank your for your comment. 

DR- Social/Econ 4.5.1.5 Environmental Justice states: "no alternative considered would result in n Editorial: Response: No text revision necessary (Thanks for the comment. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-60 Chapter 5: Consultation and Coordination

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MTDK-BL13-0058-4any identifiable disproportionate effects specific to any minority or low income 

population or community." This statement is false. The DEIS does not take a 

hard look at the impact this decision will have on small communities. Because 

the IMPLAN modeling system only uses large population areas for input data 

into the model, small communities of low income and limited economic diversity 

are not represented and no effort on the part of the BLM to adequately 

incorporate data from small communities was done. This lack of data from low 

income small communities is in violation of NEPA and consequently will result in 

a decision that is arbitrary and capricious.

Resource outputs are the amount of a resource (e.g., AUMs, recreation visits, 

tons of locatable minerals, etc.) that would be available for use under each 

alternative. Resource specialists projected annual resource outputs based on 

the best available information and professional judgment. Based upon public 

comments, resource specialists have reviewed assumptions used in this 

analysis to see if they need to be changed or updated. These revised 

assumptions have been incorporated into the analysis contained in the DEIS. 

The purpose of the economic analysis is to compare the relative impacts of the 

alternatives and should not be viewed as absolute economic values. Previous 

modeling experience has shown that the data contained in the IMPLAN 

modeling system for the various sectors are accurate representations of 

impacts. )

DRMTDK-BL13-0058-5

Social/econ

4.5.2.2 states: "While the alternatives have the potential to affect local 

businesses and individuals, the changes in BLM lands and minerals would not 

change enough to affect economic diversity or dependency." This statement 

would only be true if your analysis were to use economic data from a modeling 

program that relies on information and data collected from large communities 

with a diversity of economic drivers. The IMPLAN modeling system only uses 

data from the larger communities and therefore ignores the impact to small 

communities. The DEIS lacks sufficient information from small communities in 

the analysis and because the small community data is missing, the DEIS 

document is flawed in its assumption of no impact

N 

The IMPLAN data are comprehensive - it includes data from both metropolitan 

and non-metropolitan areas. It is neither feasible nor desirable to conduct 

economic impact analyses on very small scales (e.g., zip code level) due to the 

economic linkages between communities. A small-scale IMPLAN analysis 

would fail to capture the labor and trade flows between communities and the 

economic consequences would be underestimated. As a result, consequences 

particular to small communities are addressed in the social analysis. The social 

analysis addresses environmental justice considerations on pg. 4-590, which 

describe the potential for disproportionately adverse effects on low income 

individuals and communities.

DRMTDK-BL13-0058-6

Social/Econ

The DEIS on page 4-600 refers to a study by Rasker, Alexander, venden Noort 

and Carter as to the benefit of open space. This study is flawed by the 

incomplete and excluded data which was not used in this study. The study is not 

definitive and was done in response to increased subdivision activity in high 

density areas of western Montana. Rasker is the founder of Headwaters 

Economics and works with and for environmental groups to stop residential 

development. He was the executive director of Sonoran Institute, an 

environmental group well known for their attacks on private property rights. 

Headwaters Economics has a desired outcome and through this agenda they 

input incomplete and many times false data in an effort to reach a predetermined 

outcome. Any reference to this study in justification of your decision renders the 

decision arbitrary and capricious.

N Opinion: Response: No text revision necessary (Thanks for the comment. 

DRMTDK-BL13-0058-7

Social/Econ

The DEIS makes reference to some people would be adversely affected by the 

decision while others would benefit. The people mentioned that would benefit 

would not benefit directly or economically but would benefit by their desires and 

feelings being enhanced. The folks dependent on multiple use management of 

these lands for income and continued operation of their business would suffer 

while the feelings of some would be enhanced. Is it within the expertize of the 

BLM to analyze the mental feelings of people in order to determine their mental 

n

Opinion: Response: No text revision necessary (Thanks for the comment. 

Resource outputs are the amount of a resource (e.g., AUMs, recreation visits, 

tons of locatable minerals, etc.) that would be available for use under each 

alternative. Resource specialists projected annual resource outputs based on 

the best available information and professional judgment. Based upon public 

comments, resource specialists have reviewed assumptions used in this 

analysis to see if they need to be changed or updated. These revised 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-61

Comment 

Number Topic Comment Text

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Document 

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state of accepting a decision? The DEIS does not supply any supporting 

documentation relative to mental feelings arising from selection of any alternate. 

The BLM is assuming without science based information or studies resulting in a 

decision that is both arbitrary and capricious.

assumptions have been incorporated into the analysis contained in the DEIS. 

The purpose of the economic analysis is to compare the relative impacts of the 

alternatives and should not be viewed as absolute economic values. Previous 

modeling experience has shown that the data contained in the IMPLAN 

modeling system for the various sectors are accurate representations of 

impacts. )

DRMTDK-BL13-0058-8

Travel Mngt

4.5.1.8 makes the following statement which is quite concerning. "Recreation 

management under Alternative D would enhance experiences for people who 

prefer non-motorized opportunities while maintaining quality opportunities for 

those desiring a motorized experience, which could enhance the quality of life for 

both of these groups." This statement is completely false. Closure of large areas 

and many trails currently open to motorized use would adversely affect both 

motorized and non-motorized users. Your assumption of benefit is clearly 

flawed. Because access to BLM managed land depends on people being able to 

access these lands, any removal of established roads would adversely affect all 

users. People are not going to walk from Billings to the public lands. People are 

not going to walk large distances across BLM managed land to access their 

preferred destination. Opportunities for nonmotorized recreation are enhanced 

by the motorized road and trail facilities. Removal or closure of any of these 

facilities will adversely affect everyone.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

DRMTDK-BL13-0058-9

Travel Mngt

In regard to the road and trail facilities, the DEIS is not sufficient in conveying to 

the pubic a clear picture of what roads and trails are proposed to be closed or 

remain open. The maps associated with the DEIS do not indicate road and trail 

numbers which are necessary for the public to provide substantive comments on 

specific roads and trails. The large maps provided to the public did not have the 

road and trail numbers associated with them. The maps provided on the 

computer website were not able to be copied and enlarged to provide the 

required information to the public as required by NEPA. When BLM 

representatives were asked about the lack of road and trail identification at the 

open house events we were told these maps were "a work in progress". How 

can the BLM expect the public to make an intelligent comment or even comment 

at all on the closure or use of a specific road or trail if these facilities are not 

identified on the map provided to the public? I request the comment period be 

extended until such time as adequate information is provided to the public in the 

form of maps with roads and trails identified with their corresponding numbers. A 

record of decision to implement the BLM RMP before this information is provided 

is contrary to the requirements of NEPA and would be in violation of NEPA. 

Such a decision would be both arbitrary and capricious.

n

Thank you for your comments and your concern. We appreciate the interest in 

management of public lands. While statements of opinion (including agreement 

or opposition) do not require specific responses or text revisions under NEPA 

regulations, they have been considered by the Billings Field Office and 

Montana State Office and documented in the administrative record associated 

with the Billings and Pompeys Pillar National Monument RMP/EIS.

The Maps have route numbers on them and Appendix O has detailed 

explanations of the inventory and designation process. Individual route 

inventory data is also available for the public. 

DRMTDK-BL13-0065-1lands with 

wilderness 

characteristi

Manage AS WILDERNESS: > > 1. Weatherman Draw > 2. Bad Canyon > 3.

Yellowstone River Islands > 4. Clarks Fork River Islands > n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-62 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

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Document 

(Y/N)

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cs and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

DRMTDK-BL13-0065-2

Travel Mngt

1. Close Demijohn Flat route (Pryor Mtns) to motorized use > 2. Close the Bear 

Canyon (Pryor Mtns) road to motorized use > 3. Keep Graham Trail for foot and 

horse travel only >

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

Several changes have been made to the final RMP, which includes closing 

Bear Canyon And Demi John Flats to motorized use except for administrative 

needs. Refer to map 146

DRMTDK-BL13-0067-1

PMWHR, 

Recreation

Do not allow target shooting on the mountain top area should be prohibited year 

round in the entire PMWHR. It can cause undue stress to the wild horses and 

other wildlife. Target shooting can increase the risk for a wild fire. Target 

shooting could result in an accidental horse shooting and is an endangerment to 

the other visitors on the mountain.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

Please note that on page 2-172 safety is noted as a specific concern and that 

the closure is only during the period of peak visitation and only in the area 

where people and horses congregate in close proximity with a potential for both 

vegetation and topography screening.

DRMTDK-BL13-0067-2WILD 

HORSES,

PMWHR

Reintroduce the Sorenson Extension into the horse range N Thank you for your comment.

DRMTDK-BL13-0068-1

Travel Mngt Bear Canyon Trail and all beyond the entrance should be closed to motorized 

traffic. n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed to motorized use” to the public with motorized administrative access 

for Agency staff. 

Refer to map 146

DRMTDK-BL13-0069-1

lands with 

wilderness 

characteristi

cs

I urge that wilderness management be applied to Weatherman Draw 

(exceptional cultural values), Bad Canyon, and all BLM-administered islands in 

the Clark's Fork and Yellowstone Rivers.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

Please see the end of Table 2.6.1 for Lands with Wilderness Characteristics 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-63

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management prescriptions and then refer to other sections in the table for the 

specific areas and their management prescriptions – many have the same 

regardless of designation

DRMTDK-BL13-0069-2

Cultural, 

lands with 

wilderness 

characteristi

cs

I strongly support the following specific motorized closures: 1) the Demijohn Flat 

route in the Pryors in order to protect sensitive cultural values. This 1-1/2 mile 

closed route would be wonderful quiet trail and would also unify the Burnt Timber 

Canyon WSA with contiguous lands identified by BLM as possessing wilderness 

characteristics.2) the two-track route leading into Bear Canyon in the Pryors 

beyond the canyon mouth. With two parallel motorized routes nearby and a third 

proposed (Graham Trail) a quiet non-motorized trail is needed.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed” to vehicle use and as a non-motorized trail.

Refer to map 146

Also note that BLM Manual 1626 (Travel and Transportation) specifies that 

BLM establish a comprehensive program for both motorized and non-motorized 

travel. This will be done in this RMP

Please note that the goal for the Pryor Mtn TMA is to protect wilderness values, 

cultural assets, visual characteristics, sensitive plants, fragile and erosive soils, 

wild horses and wild horse habitat.

Also note that BLM Manual 1626 (Travel and Transportation) specifies that 

BLM establish a comprehensive program for both motorized and non-motorized 

travel. This will be done in this RMP. 

DRMTDK-BL13-0076-1

Travel Mngt

Myself and several friends along with landowners have property within the Grove 

Creek TMA know as Block COS936, While looking at the proposals' that are 

currently being listed I am very concerned that the BLM is supporting (D). This 

proposal (D) has the most effect not only on myself as a land owner but also 

ranchers, homeowners, public recreation, and 15 other landowners in the 

Beartooth Valley Ranch group. By supporting (D) the BLM and Planners are 

taking away our rights as US citizens to access our land. Also this (D) proposal 

will take away from all citizens the opportunity to access the recreational area. 

Many people use the area for hiking, hunting, camping, ranch land, and many 

other legal use. The Carbon County Commission has adopted thru legal means

(1987) 25 years ago thru commission meeting the roads of Robertson Draw and 

Ruby Creek. This action is in the records of the Carbon County Commission. 

Robertson Draw and Ruby Creek were taken over by Carbon County so that the 

public (US citizens) have the access to the area for recreational purpose but also 

for landowner access and use. You will find on the Carbon County web site 

under county road priority maintenance that the county has claimed Robertson 

N

Thank you for your comment.

Your comments have been considered by the Billings Field Office and Montana 

State Office and documented in the administrative record associated with the 

Billings and Pompeys Pillar National Monument RMP/EIS. Please know that 

BLM does not establish route determinations on private lands and can only 

make route determinations on BLM managed roads located on public lands.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-64 Chapter 5: Consultation and Coordination

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Draw Road as a Priority 1 with regular scheduled maintenance and snow 

plowing. With Carbon County being the source for road maintenance and having 

legally claimed Robertson Draw and Ruby Creek as county roads closing off any 

access cannot be an option as in proposal (D). The closing of Robertson Draw 

Road will firmly go against the Alaska National Interest Lands Conservation Act 

(Public Law 96-487-DEC 2. 1980 94 STAT 2371 110(B) giving US Citizens the 

guaranteed access to private owned land thru and across federal land. This not 

only Public Law but Federal Law also. As a US Citizen and owner of public lands 

have the right to access thru nominal and reasonable actions the access to my 

private land. The BLM Proposal (D) denies me of this right as a landowner. A 

reasonable action will be to have the Carbon County Road remain open as a 

public road as the wishes of the 1987 Carbon County Commission.

DRMTDK-BL13-0078-1

Travel Mngt

It is also a very small task to include the impacts to private property owners in 

the adverse consequences of the Travel Management Plans and in each 

alternative as it also relates to Land Realty and ROWS. These private property 

owners in the Robertson Draw, Ruby and Gold Creek subdivisions are a unique 

group of people who have been given absolutely no consideration in this 

planning process. We are recommending that private property owners deserve 

to be notified of these above concerns with a form letter explaining how their 

rights to own property in this unusual situation will be negatively impacted and 

specific recommendations as to how they might compensate for this sudden 

threat of no motorized vehicle access and ROW exclusion, and full disclosure 

made of the known and perceived future threats to their rights to own private 

property in these unique areas, so that these informed people will have had 

ample opportunity to decide how to proceed to minimize their unforeseen social 

and economic losses.

N

Thank your for your comment. Due to the concerns raised in the Grove Creek 

area, an the BLM attended an additional meeting with those interested publics 

in Belfry on June 22, 2013. 

DRMTDK-BL13-0080-

FLAMaster-1

Social/econ

I believe the BLM has underestimated the cost of hampering energy 

development in my state while overestimating the social benefits of blocking 

human activity on expansive tracks of land for the sage-grouse. We are still 

struggling in a weak economy. Chocking off oil and natural gas development 

would not only hurt the wages and employment prospects of the workers in that 

industry, but it would also drain money out of local communities. Decelerating 

the economic development of such an important industry would have an overall 

effect of reducing wages, employment, and entrepreneurship across all other 

industries within the region. Limiting the supply of energy can make electricity 

generation more expensive and therefore increases the utility costs and financial 

burdens on all Montanan households, families, and businesses. The intangible 

social benefits of freezing land use for a bird are highly questionable when 

compared to the costs of distorting economic decisions and outcomes for 

American families and businesses. I urge you not to adopt the preferred 

resource management proposal and keep Montana land open for productive 

N Opinion: Response: No text revision necessary (Thanks for the comment. 
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use.

DRMTDK-BL13-0082-1

lands with 

wilderness 

characteristi

cs

To properly protect and manage the 12 areas that have wilderness 

characteristics the following needs to happen:-Close all identified wild lands to 

mining and construction of new roads or new structures-Closing the areas to oil 

and gas leasing-Designate the areas where R/W for power lines & pipelines are 

excluded, this includes wind farms-Close the Demi john Flat route to motorized 

use-Close the two-track leading into Bear Canyon to motorized use-Designate 

quiet, non-motorized trails as part of the plan-Close all Sage Grouse Priority 

Protection Areas to oil & gas leasing Thanks for keeping Montana's Prairie and 

Plaines water, air and wildlife intact.

Y 

Thank your for your comment. 

While statements of opinion (including agreement or opposition) do not require 

specific responses or text revisions under NEPA regulations, they have been 

considered by the Billings Field Office and Montana State Office and 

documented in the administrative record associated with the Billings and 

Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed”

Refer to page ***

Also note that BLM Manual 1626 (Travel and Transportation) specifies that 

BLM establish a comprehensive program for both motorized and non-motorized 

travel. This will be done in this RMP.

DRMTDK-BL13-0083-1

NEPA

The position of Prairie County is that BLM should manage the properties 

assigned to them with "multiple use" directive of FLPMA of 1976. In your DRMPs 

you should have addressed all Environmental Issues for not just Ecosystems, 

but also Economics, Heritage, History, etc. Environmental Consequences of the 

Draft(s) RMP/EIS never even addressed these issues.

N

Thank you for your comment.

The BLM’s multiple-use mission and the BLM’s obligation to comply with the 

Federal Land Policy and Management Act of 1976 (FLPMA) and all other 

applicable laws, regulations and policies are addressed in Chapter 1 of the 

RMP/EIS.

The topics referenced are discussed in the Cultural Resources, Economic, and 

Social sections of Chapters 3 and 4 of the RMP/EIS.

DRMTDK-BL13-0084-1

Livestock 

Grazing

Allotments in Greater - Sage Grouse Habitat areas or area that leks or nesting 

are found would be more restrictive for use of "Cooperative Range 

Improvement" dollars that come from the Range Improvement Fund which is 

generated from Permit fees of livestock AUMs; which they, the permittees, are 

contributers. That being said, it is discriminatory against permittees that have 

allotments within Greater - Sage Grouse area(s) because of severe restrictions 

on putting in REA, Windmills, Fences, etc. ... that USFWS concluded are 

detrimental to the bird in question's habitat. Since those allotment holders do not 

have the same opportunity to use the Range Improvement Funds, how is the 

BLM going to compensate for the discrimination?

n

None of the alternatives discuss or contemplate avoiding range improvements 

on grazing allotments within greater sage grouse PPH. On Table 2-6.2 (pg. 2-

116 of the DRMP) under management common to all alternatives “Structural 

range improvements would be considered where necessary to facilitate 

changes in grazing management changes.” Additionally, in said table on pg. 2-

118 of the DRMP under alternatives B and D, allotments within or containing 

Sage-Grouse PHMAs would be designated as Category I or improve. Under 

this designation, BLM would be able to channel more of the range improvement 

funds towards these allotments to improve management practices. Therefore 

this would not be discriminatory.

DRMTDK-BL13-0086-1

Livestock 

Grazing

Allotments in Greater - Sage Grouse Habitat areas or area that leks or nesting 

are found would be more restrictive for use of "Cooperative Range 

Improvement" dollars that come from the Range Improvement Fund which is 

generated from Permit fees of livestock AUMs; which they, the permittees, are 

contributors. That being said, it is discriminatory against permittees that have 

n

On Table 2-6.2 of the DRMP under management common to all alternatives 

“Structural range improvements would be considered where necessary to 

facilitate changes in grazing management changes.” Additionally, in said table 

on pg. 2-118 under alternatives B and D, allotments within or containing SageGrouse PHMAs would be designated as Category I or improve. Under this 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-66 Chapter 5: Consultation and Coordination

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allotments within Greater - Sage Grouse area(s) because of severe restrictions 

on putting in improvements: REA, Windmills, Fences, piplelines, etc. ... that 

USFWS and BLM concluded are detrimental to the bird in question's habitat. 

This in turn could be detrimental to the allotment passing all standards. Since 

those allotment holders do not have the same opportunity to use the Range 

Improvement Funds (under the same guidelines), how is the BLM going to 

compensate for the discrimination? If the management of BLM then decides that 

they should be more lenient to the use of range improvement funds on 

allotments within Greater - Sage Grouse Habitat, then does that not put the 

permittee not in Greater - Sage Grouse Habitat to a disadvantage?

designation, BLM would be able to channel more of the range improvement 

funds towards these allotments to improve management practices. By policy, 

the BLM has prioritized investments in range improvements since 1987 when 

the allotment categorization process was started with the issuance of BLM 

Manual Handbook 1740-1. As conditions and information changes, allotment 

categories may change under alternatives B and D—see page 2-118 of the 

DRMP. 

DRMTDK-BL13-0087-1

NEPA

Prairie County is notifying the BLM now, that any changes after Record of 

Decision must first be addressed with the our county. Even if these 

modification(s) happen outside our jurisdictional boundaries, Prairie County 

realizes that the impacts of intensity and change of use of federal land affects 

can cross county lines as well and BLM district lines. We expect a detailed EIS 

and a statement of Environmental Consequences.

N

Thank your for your comment. Prairie County has been added to the B&PPNM 

RMP/EIS mailing list.

DRMTDK-BL13-0088-1

Wildlife

There is only one conclusion to increasing GSG populations: "Greater-Sage 

Grouse will adapt and florish in about any part of eastern Montana or western 

North Dakota with aggressive predator control."

n

Thank you for your comment. The BLM and the Forest Service describe the 

effects of predation on sage-grouse in the Draft EIS; the information used here 

and in the affected environment was taken from the Baseline Environmental 

Report (the BER) and note that [summarize what the discussion was, 

specifically noting any reference the commenters make to an particular issue or 

topic; include page number references from the BER]. The BLM and the Forest 

Service have authority to manage the habitat and have provided analysis to 

describe how the numerous management actions across the range of 

alternatives could affect the habitat and indirectly the effects of predation. 

Altering the sagebrush habitat of the greater sage-grouse can create an influx 

of predators into an area and lead to a population decline. Roads, fences, 

power lines, trails and other disturbances may make access easier for potential 

predators and increase risks to the species. The Draft EIS calls for measures 

that will substantially reduce disturbances in the bird’s habitat, thus reducing 

predation risk. The Draft EIS also calls for careful monitoring of grazing 

allotments within sage-grouse nesting habitat to ensure suitable grass and forb 

cover is reserved so we can minimize the associated predation risks. This 

information can be found in Chapter 3 - Wildlife of the EIS.

DRMTDK-BL13-0091-2

NEPA

40 CFR 1502.16 (CEQ)[The environmental consequences section of the EIS] 

shall include discussions of...(c) Possible conflicts between the proposed action 

and the objectives of Federal, regional, State, and local (and in the case of a 

reservation, Indian tribe) land use plans, policies and controls for the area 

concerned.40 CFR 1506.2 (CEQ)

N

Thank you for your comment. Please see Chapter 4 for the environmental 

consequences and Section 1.5 for identification of inconsistencies between the 

Proposed RMP and county or local plans.

DRMTDK-BLNEPA To better integrate environmental impact statements into state and local 

planning processes, statements shall discuss any inconsistency of a proposed N Thank your for your comment. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-67

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13-0091-3 action with any approved state or local plan or laws (whether or not federally 

sanctioned). Where an inconsistency exists, the statement should describe the 

extent to which the agency's would reconcile its proposed action with the plan or 

law

DRMTDK-BL13-0095-5Livestock 

Grazing, 

Social/Econ

Furthermore, Range Improvement Funds used for Cooperative Range 

Improvements would be discriminatory against those ranchers and permittees in 

Greater - Sage Grouse Habitat because they can't use them for as broad a 

spectrum as those outside. This is not right. By taking away those tools, you also 

affected the economics of my county, other counties, and surrounding business 

hubs. The local contractors, hardware stores, well drillers and repairman etc. 

You have affected the amount of taxes paid to the state and feds. You have 

affected the local tax burden due to possible lower yearly income. None of this 

was even considered in your "Environmental Consequences" section.

n

None of the alternatives discuss or contemplate avoiding range improvements 

on grazing allotments within greater sage grouse PPH. On Table 2-6.2 (pg. 2-

116) under management common to all alternatives “Structural range 

improvements would be considered where necessary to facilitate changes in 

grazing management changes.” Additionally, in said table on pg. 2-118 under 

alternatives B and D, allotments within or containing Sage-Grouse PHMAs 

would be designated as Category I or improve. Under this designation, BLM 

would be able to channel more of the range improvement funds towards these 

allotments to improve management practices. 

Please see the economics section regarding response to your economics 

comment. See the description of social, economic and environmental justice 

conditions and trends on pages ... and the description of social, economic and 

environmental justice impacts on pages ...which describes changes in 

employment, income, in various private sectors and changes to social 

conditions; table ...(...)shows impacts to public revenues to state and counties. 

Discussion on effects to local governments and community infrastructure have 

been added to the FEIS. In addition an appendix has been added to the FEIS 

describing the IMPLAN modelling tool and inputs used. 

DRMTDK-BL13-0102-1WILD 

HORSES,

PMWHR

1) Under Alternative D: It states "Manage wild horses on approximately 27,094 

acres of BLM administered lands (39,994 acres all ownerships). Designate the 

closed portions of the Herd Area known as the Administrative Pastures to be 

included in the Herd Management Area. Due to private property conflicts, the -

 ̃buffer' area would remain closed. “I am extremely pleased that the 

"Administrative Pastures" idea is being seriously considered, and urge those 

concerned to pursue the accomplishment of that with vigor. However, I am under 

the impression that there have not been a lot of "private property conflicts", other 

than the case of Exhilaration’s propensity to mix with domestic horses (which 

has been corrected), to necessitate reducing the area available for forage even 

by that encompassed in the "buffer” area. I feel that since ranchers are allowed 

to drive cattle across the Range when needed, and since cattle sometimes stray 

onto the Range by mistake from time to time, having an isolated incident or two 

with the wild horses really shouldn't constitute a serious problem. Therefore, I'd 

like to see that particular subject in Alternative D changed to the wording from 

both Alternatives C and D, as follows: "Manage wild horses on approximately 28, 

622 acres of BLM-administered lands (44,855 acres all ownerships). Designate 

the closed portions of the Herd Area known as the Administrative Pastures to be 

N

Thank you for your comment. Please refer to chapter two alternatives C and D 

as what is being called the buffer; it is not the administrative pasture, but rather 

the area between the county road and the external boundary fence. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-68 Chapter 5: Consultation and Coordination

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included in the Herd Management Area. Designate the entire Herd Area as the 

Herd Management Area". However, if having the "buffer" area issue prevent the 

use of the rest of the Administrative Pasture area for the horses, I would, of 

course, want to compromise on that point.

DRMTDK-BL13-0102-2WILD 

HORSES,

PMWHR

2) Under Alternative D: It states, Same as Alternative A-"Within an HMAP, herd 

structure would be managed for all representation in the herd, not allowing 

specific colors or bloodlines to dominate from management manipulation." It was 

the fact that these horses carried very "old bloodline" genes and the majority in 

this herd exhibited those unique characteristics, along with the varied beauty and 

ruggedness of the terrain, that drew me to begin visiting the PMWHR instead of 

any of the other places where one can see "wild horses". As I learned more 

about it, I had to applaud the efforts of the people who recognized the historical 

as well as esthetic beauty and importance of these horses and their ancestry---

REALLY, applaud them. I recognize that it hasn't been easy. I've been a 

supporter of retaining as much of our historical connections in this country of 

ours as is possible, and this herd of horses and the range they live on have a 

prominent place on my list of important places and things (comparable to "oldgrowth trees" in our national forests). Therefore, I naturally believe that it is 

VITAL that the more primitive colors (dun/grulla/grullo) be considered the most 

important factor, second ONLY to genetic viability, in managing the herd. As a 

horse lover, as well, I do love ALL the horses, but my instincts tell me that there 

are many "pretty" horse colors everywhere and in many different breeds---such 

as pintos, palominos and roans, but the variety of duns, grullas and grullos hold 

a special place in the nature of this breed, and this herd, and should be 

especially treasured. So, in conclusion on this issue, I prefer that Alternative D 

be altered to include wording from C on this subject, and more descriptive 

language about primitive markings, to read as follows: "Within an HMAP, herd 

structure would be managed first for genetic viability, and secondly for and to 

promote the public perception of the quintessential Pryor horse that is Dun or 

Grulla/Grullo with any variation of primitive markings" i.e., dorsal stripes, leg 

stripes, wither stripes, black-rimmed ears, twotone manes/tails or the "webbing" 

on the faces of "coyote duns".

N

Thank you for your comment, however detailed objectives are addressed within 

implementation level documents such as Herd Management Area Plans

DRMTDK-BL13-0103-1

Travel Mngt

ALL Big Sky Trail and Bear Canyon Trail must be designated as nonmotorized: 

both are premier birding and mediation trails and the disturbance, disruption and 

intrusion of machinery is unacceptable.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 
Billings and Pompeys Pillar National Monument

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as “closed” for public use as a motorized trail and will be designated as a nonemotorized trail.

Refer to map 146

DRMTDK-BL13-0103-2

Cultural, 

Travel Mngt

The route from Crooked Creek Road to Demijohn Flat needlessly fractures 

culturally two sensitive areas: the Burnt Timber Canyon WSA and the Burnt 

Timber Canyon LWC.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

DRMTDK-BL13-0103-3

Travel Mngt

How many motorized trails (within three miles!) are necessary on the SW slope 

of Big Pryor Mountain? Surely Bear Canyon Trail (beyond the canyon's mouth) 

can be spared: it's an Audubon Important Bird Area, the best place in the Pryors 

to see avian species

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed”

Refer to map 146

DRMTDK-BL13-0105-1

SS Plants, 

ACEC

In the draft RMP page E-28, ACEC Nomination Evaluation for the Pryor Foothills 

RNA/ACEC, it states that, "The area contains sites of seven bureau sensitive 

plant species." I can locate only six sensitive species within the proposed ACEC. 

All references are to the proposed Alternative D that is basically four sections. 

Which plant(s) does BLM list that I do not? Could my list and BLM's list of 

sensitive plants within the proposed ACEC differ in other ways? Though not 

critical for making comments on the draft RMP, it is important that we start out 

with the same list of sensitive plants to be conserved by the proposed ACEC. I 

am sharing my observations and findings about the proposed ACEC with Peter 

Lesica. I am assuming that the only survey for sensitive plants within the 

boundaries of the proposed ACEC was done by Peter Lesica and Peter Achuff in 

May and June, 1991. My list below is based on the data presented in their final 

report made to BLM in 1992. The list of plants in the table is taken from the 

Montana Native Plant Society's South Pryors Important Plant Area list. I have 

compared that list with the list of BLM sensitive plants. My copy of that list dates 

to 2009. I acknowledge the differences. In the appendix of their report Lesica 

and Achuff gave the locations of the plants by township, section, and quarter 

section. I used that data to determine which plants were located within the four 

sections of the proposed ACEC. Of the eleven recommended sensitive plants 

found in Townships T95 R26E and T9S R27E in 1991 by Lesica and Achuff, six 

were located in the proposed RNA/ACEC Alt. D. Species of Concern found in 

the Montana Native Plant Society's South Pryor Important Plant Area [Table 

n

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS.

Please refer to Appendix E. Areas Of Critical Environmental Concern in the 

Draft RMP/EIS for a discussion of ACEC Nominations for East Pryor ACEC 

(BLM nomination), Pryor Foothills Research Natural Area/ACEC (public 

nomination), and Sykes Ridge Rare Plant ACEC (nomination by Peter Lesica). 

Please see the 1998 ACEC Assessment and Proposed amendment to the 

Billings, Powder River and South Dakota RMPs here:

http://www.blm.gov/style/medialib/blm/mt/blm_programs/

planning/billings_rmp/amendments.Par.94086.File.dat/acecEA.pdf

pages 74-76 are the nominations evaluations for the Billings RMP and page 

103 shows the map of the nominated vs. recommended ACEC.
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1]Name/Present in T9S R26E and T9S R27E west of Crooked Creek/Present in 

proposed RNA/ACEC Alternative D Astragalus aretioides N N Astragalus geyeri 

Yes Yes Astragalus oreganus Yes Yes Boechera demissa Yes N Camissonia 

andina Yes N Camissonia parvula N N Cleome lutea N N Erigeron allocotus Yes 

N Eriogonum salsuginosum Yes N Grayia spinosa Yes Yes Leptodactylon 

caespitosum Yes N Malacothrix torreyi Yes Yes Mentzelia pumila Yes Yes 

Nama densum Yes N Penstemon caryi N N Physaria lesicii N N Shoshonea 

pulvinata N N Stipa lettermanii N N Sullivantia hapemanii N N Townsendia 

spathulata Yes Yes Townsendia spathulata Was removed from the SOC list. 

The species' viability in the state does not appear to be at risk due in part to its 

relatively widespread distribution in southwest and south-central Montana and its 

overall abundance. Eriogonum salsuginosum was not found within the 

boundaries of the proposed ACEC, but based on its description it may turn up in 

the proposed ACEC. SOC Present in T9S R26E, T9S R27E west of Crooked 

Creek but not found in the proposed Pryor Foothills RNA/ACEC, Alternative D. 

Based on Lesica and Achuff, 1992. [Table 2]Boechera demissa Lesica found in 

the foothills of the Pryor Mtns and in BCNRA in canyon bottoms and outwash 

plains with Juniperus osteosperma. Reported 1998. Camissonia andina One site 

in R26E, others are east of Crooked Creek. Erigeron allocotus At 4000 -“6200 

feet with Cercocarpus ledifolius. All sites are east of Crooked Creek. Eriogonum 

salsuginosum One site in R26E. Another location is near bentonite deposits. 

Look for in the proposed RNA/ACEC. Leptodactylon caespitosum North and east 

facing slopes of Chugwater sandstone in which gypsum is embedded. Locations 

appear to be east of Crooked Creek.

DRMTDK-BL13-0107-1

Travel Mngt

A major concern regards the road that connects Robertson Draw Road to Ruby 

Creek Road, marked on the attached maps as "connector". This route provides 

essential access to block 936 and should not be closed to public use as currently 

proposed in alternative D. This route must remain open to avoid future conflicts 

with as many as 16 lot owners on block 936. Another concern regards existing 

vehicle access to my lot. This is shown on the attached Google Earth imagery 

from 2009; a field check to the area will confirm the viability and existence of this 

route as well. This road has likely existed for multiple generations. Indeed, the 

southwest corner of my property has a gate which predates subdivision and 

likely served necessary ranch functions, just as it should continue to offer access 

for me. The gate is the dividing line between public and private land and is 

fenced perpendicularly from the gate to the east and north. In assessing the 

Grove Creek TMA in the RMP, BLM should include this 500 foot piece of 

unimproved route as a publicly open route. This is consistent with the access 

rights of previous land owners, and it should remain accessible by current 

landowners, granted no improvements are required, which they are not.

n

Thank you for your comments. In reviewing the circumstances of this issue, it 

appears that neither the Ruby Creek road (GC 1003) nor the mentioned 

connector route (GC 1009 and GC 1010 route segments) actually provide 

access to the private property parcels. There are a number of other minor 

vehicle routes apparent from aerial analysis but the 500 foot long route 

mentioned has been considered and documented as an unauthorized route in 

previous correspondence between you and the BLM. 

DR- Travel Mngt In addition, lot #5 has similar access which can be also be seen on the attached n Thank you for your comments. In reviewing the circumstances of this issue, it 
Billings and Pompeys Pillar National Monument

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Chapter 5: Consultation and Coordination 5-71

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MTDK-BL13-0107-2maps. That spur route accesses a water tank (labeled as "RI" for range 

improvement on the map) which is fed by an up gradient spring. This route is 

well traveled yet also does not appear on any of the DRMP maps. This route 

adjoins with the private easements on block 936 which allows land owners to 

travel to their own properties once inside the block. Like the route that accesses 

my property, this route has no need for modifications or improvements, and the 

inclusion of this route and the route into lot #13 in the RMP should therefore 

require no additional paperwork, permitting, or administrative hurdles. These 

routes exist now and are essential for accessing private lands, and no one is 

proposing physical changes of any type to these routes. They are arid gravel 

soils, not prone to further erosion and therefore I believe the continued public 

use of these routes in the final RMP is environmentally sustainable and poses no 

potential for resource degradation.

appears that several routes, which are readily identifiable on aerial photography 

from previous vegetation clearing, are actually pipeline ROWs and are not 

vehicle roads and thus are not included in the Travel and Transportation 

network. 

DRMTDK-BL13-0109-1

Air

Disclosure of Current SO2 Conditions and Potential Impacts Chapter 3, Figure 

3-2 provides ambient air quality concentrations in the Planning Area for years 

2009-2011. Although data are included for the 1-hour and 24-hour SO2 National 

Ambient Air Quality Standards (NAAQS), footnotes 13 and 14 seem to indicate 

that 3-hour and annual data are also available. We recommend including the 3-

hour and annual data in this Figure. In addition, the 1-hour SO2 concentration 

presented in Figure 3-2 is at 105% of the NAAQS. On p. 3-9, it is noted that the 

Montana Department of Environmental Quality (MDEQ) reported high monitored 

1-hour SO2 concentrations during 2010 due to "events that are not likely to be 

repeated in future years." We recommend expanding this discussion to explain 

these "events" and why they would not be repeated. BLM conducted near-field 

modeling to disclose potential impacts to the NAAQS in the Planning Area. 

However, it appears that the 3-hr SO2 NAAQS analysis was omitted from the 

near-field modeling runs for the Draft RMP/EIS although it was included in the 

modeling protocol agreed to through the AQTW. Given the presence of the 

Laurel SO2 Nonattainment Area within the Planning Area, it is particularly 

important that BLM disclose potential impacts to the 3-hr SO2 NAAQS.

Y

The footnotes have been revised and data have been updated to reflect years 

2010-2012. The BLM refers readers to the MDEQ for additional information 

concerning SO2 events associated with industrial sources permitted by the 

MDEQ. Modeling results for the 3-hour SO2 NAAQS have been included in 

Section 4.1.1.3.1.

DRMTDK-BL13-0109-

10

Water

The Draft RMP/EIS states that no current, comprehensive quantification or 

quality measurements have been made for groundwater in the Planning Area. 

Page 3-39 notes that "the following guidance" sets forth foundations for BLM 

management of aquatic resources, but no discussion of such guidance follows. 

We recommend the Final RMP/EIS include disclosure of any future plans for 

gathering groundwater data in the Planning Area and discussion of the 

referenced guidance.

n

The BLM does not plan to gather comprehensive planning area ground water 

data. If a Plan Of Development is submitted that would warrant data collection, 

it would occur. 

The “guidance” is referring to a number of plans and recommendations from 

BMPs to state and federal water quality standards. To clarify, the paragraph 

referred to will be written as:

“Best management practices, state and federal guidance concentrate on 

protecting water resources, which sets the foundation for BLM management of 
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both surface and groundwater resources.”

DRMTDK-BL13-0109-

11

Water

The EPA recommends that the Final RMP/EIS analyze potential impacts to 

groundwater quality and quantity related to oil and gas well drilling, including 

leaks and spills; associated production and disposal of produced water, including 

potential use of pits, underground injection control (UIC) wells, and evaporation 

ponds; impacts associated with production wellbore integrity and pipeline use; 

and impacts associated with restimulation and abandonment of existing wells. 

The EPA also recommends that the Final RMP/EIS discuss measures the BLM 

will require at the project level to minimize the potential for these impacts to 

occur. Appropriate groundwater protection measures can vary depending on 

hydrologic conditions and the presence of drinking water resources. Depending 

on the level of oil and gas development, lease stipulations may be necessary 

due to the disproportionate effect on water resources from such development. 

Specifically, the EPA recommends that BLM analyze and disclose potential 

groundwater protection, monitoring and mitigation measures, including: BMPs 

and other mitigation measures such as closed loop drilling, monitoring of water 

quality and water levels, closure and monitoring of reserve pits, and lining and 

monitoring of evaporation ponds; Setback stipulations, such as No Surface 

Occupancy (NSO), to minimize the potential for impacts to potential drinking 

water resources, including domestic water wells and public water supply wells. 

EPA recommends a minimum 500-foot setback for private wells. Setbacks are 

effective health and environment protection tools because they provide an 

opportunity for released contaminants to attenuate before reaching a water 

supply well. They may also afford an opportunity for a release to be remediated 

before it can impact a well, or for an alternate water supply to be secured. We 

note that the North Dakota Oil and Gas Commission has adopted a 500-foot 

setback from occupied dwellings (and by default, the associated domestic well); 

A mitigation plan for remediating future unanticipated impacts to drinking water 

wells, such as requiring the operator to remedy those impacts through treatment, 

replacement, or other appropriate means; and A general production well 

schematic that depicts the following: casing strings; cement outside and between 

the various casing strings; and the relationship of the well casing design to 

potentially important hydro-geological features such as confining zones and 

aquifers or aquifer systems that meet the definition of a USDW. Discuss how the 

generalized design will achieve effective isolation of USDWs from production 

activities and prevent migration of fluids of poorer quality into zones with better 

water quality.

y

Thank you for your comment. Depending on the level of oil and gas 

development, lease stipulations may be necessary due to the disproportionate 

effect on water resources from such development.” Relevant to this, the BLM 

cannot address every potential specific issue that may arise throughout the field 

office in a programmatic document such as this RMP. The impacts mentioned 

will be, if scoping identifies them, analyzed at the project level during NEPA 

analysis. A series of stipulations are available to managers to minimize impacts 

to water resources. 

Additionally, since this draft was produced, a new stipulation has been 

developed to conserve water quality in Source Water Protection Areas (SWPA). 

An NSO for all SWPAs is stipulated. SWPAs were identified by MT DEQ data.

Concerning municipal water supplies, MT DEQ regulates activities with 

potential to affect municipal water supplies. The BLM works under an MOU to 

follow MT DEQ guidelines in these circumstances. 

DRMTDK-BL13-0109-

Water

Surface Water Resource Characterization According to the Draft RMP/EIS, the 

BiFO manages approximately 1,000 miles of perennial, intermittent, and 

ephemeral streams. The EPA recommends the Final RMP/EIS describe the 

Y

The BLM uses its own data, as well as MT DEQ data, to evaluate water quality 

of given water bodies when needed. Riparian evaluations and MT DEQ 303d 

lists are used in conjunction to determine management needs for various water 
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12 current water quality conditions, if available, for each surface water body in the 

Planning Area, including perennial, intermittent and ephemeral streams, rivers, 

lakes, reservoirs, and surface water drinking water sources. The EPA also 

recommends the Final RMP/ EIS disclose the following information: A map and 

list of Clean Water Act (CWA) impaired or threatened water body segments 

within, or downstream of, the Planning Area, including the designated uses of 

the water bodies and the specific pollutants of concern; A map of municipal 

watersheds and designated source water protection zones; and Maps and 

descriptions of topography and soils, specifically steep slopes and fragile or 

erodible soils, especially near surface waters and intermittent/ephemeral 

channels. We recommend that the Final RMP/EIS be updated to reference 

Montana's 2012 Clean Water Act (CWA) Section 303(d) Impaired Waters List, as 

approved by the EPA, and discuss water quality trends to more fully describe 

current conditions in, and downstream of, the Planning Area. We recommend 

this discussion include a description of any Total Maximum Daily Loads 

completed by MDEQ for streams in the Planning Area. In addition, if MDEQ has 

not assessed the water quality in all water bodies within the Planning Area, then 

we recommend that the Final RMP/EIS list such water bodies and indicate that 

the water quality condition has not yet been assessed by MDEQ.

resources.

A list of impaired water bodies is present in Chapter 3 of the draft document. 

The MT DEQ 303d list, easily accessible on their website, has maps and 

descriptions depicting available information regarding water quality and 

impaired water resources throughout the Billings Field Office, and the state of 

MT. 

Source water protection areas (including municipal watersheds) have been 

identified. A new stipulation places an NSO within an SWPA to protect drinking 

water resources in the planning area.

A steep slope and erodible soil layer has been developed for the field office with 

a new “sensitive soil” stipulation that places a CSU on areas with sensitive 

soils. The CSU requires an approved plan to avoid or mitigate impacts to 

resources from development on sensitive soils.

Impacts from soil disturbance, especially near surface waters, is covered by 

three stipulations, including the new sensitive soils CSU, the 300’ CSU for 

riparian and water setbacks, and the water/ riparian NSO. 

TMDLs and subsequent monitoring are controlled by MT DEQ, with BLM 

contributing data as available. When NEPA analysis of proposed projects 

identify issues pertaining to water quality, the BLM determines assessment and 

monitoring needs to maintain or improve water quality. 

DRMTDK-BL13-0109-

13

Water

Sediment Load Analysis The Draft RMP/EIS notes that increased sediment from 

surface disturbance may degrade water quality. Because sediment loading has 

already caused impairment of water bodies in the Planning Area, and future 

activities that may be authorized under this RMP, including oil and gas 

development, livestock grazing and use of off-highway vehicles (which is 

expected to double by 2015), would result in surface disturbance that may 

contribute to erosion impacting watersheds, it is important the Final RMP/EIS 

include additional information about this concern. It is difficult to determine from 

the Draft RMP/EIS, Chapter 3, Affected Environment, whether the Planning Area 

contains sensitive soils, but it does note that some soils in the Planning Area 

have high susceptibility to erosion. Because erodible soils could represent a 

source of pollutants in the Planning Area, we recommend the Final RMP/EISEIS 

include a map depicting areas of steep slopes and fragile or erodible soils and 

proximity to surface waters.

y

A Sensitive Soils layer has been developed and a new sensitive soils 

stipulation, a CSU, has been drafted. The description of the sensitive soils will 

be inserted into the soils section in Ch. 3. 

In BiFO, a large proportion of sensitive soils are in arid regions with distant 

proximity to any surface waters, minimizing the impact these disturbances 

would have on water resources. 

Threats to water quality from sedimentation, due to various activities, is 

addressed on the project level through NEPA analysis. For oil and gas 

development, stipulations help minimize these impacts. For livestock grazing, 

Land Health Standards and Guidelines are used to promote water quality 

through protecting riparian health.

Comprehensive travel management is being conducted and analyzes and 

addresses impacts from OHV travel to water quality.
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14

Water

Surface Water Impacts and Mitigation Contaminants from surface events such 

as spills, pit and pipeline leaks, and nonpoint source runoff from surface 

disturbance have the potential to enter and impact surface water resources if 

these events occur in close proximity to water bodies. If surface activities are set 

back from the immediate vicinity of surface water, wetlands, and designated 

source water protection zones, then there is an opportunity for accidental 

releases to be detected and remediated before impacts reach water resources. If 

accidental releases are not detected, the setback provides a safety factor and 

some possibility of natural attenuation. Setbacks also help prevent nonpoint 

source pollutants such as sediments from impacting surface waters. Oil and Gas 

Leasing Stipulations to Protect Water Resources: The Draft RMP/EIS includes 

two different descriptions of the water resource protections provided by the 

Preferred Alternative through oil and gas leasing stipulations. Specifically, the 

Draft RMP/EIS Chapter 2, p. 2-49, and Chapter 4, p. 4-101, describe the 

Preferred Alternative to include a NSO stipulation within 300 feet of riparian 

areas, wetlands, 100 year floodplains, water bodies and perennial streams. 

However, Appendix C, Oil and Gas Stipulations, indicates that the Preferred 

Alternative proposes the following stipulations: NSO - "Surface occupancy and 

use is prohibited within perennial or intermittent streams (as indicated by 

obligate wetland species or hydric soils); lakes, ponds, and reservoirs; 

floodplains; wetlands; and riparian areas." In addition, a Controlled Surface Use 

(CSU) stipulation is proposed to ensure that special operating procedures are 

required within 300 feet of riparian and/or wetland areas. We recommend that 

the inconsistency be resolved in the Final RMP/EIS and also suggest several 

modifications to enhance and clarify the water resource protections. If the 

Appendix C proposed stipulations are the intended version: We recommend 

against using "obligate wetland species or hydric soils" as indicators for 

intermittent streams, since this will result in an unnecessarily narrow definition of 

intermittent stream that would likely result in excluding many of these streams 

from protection. We recommend further clarification of the "streams" language 

by including ephemeral streams in the list of water resources to be protected by 

the NSO stipulation. This is important because the Draft RMP/EIS identifies 

1,002 miles of perennial, intermittent, and ephemeral streams in the Planning 

Area. We recommend clarifying the NSO language to be applicable to "100-year 

floodplains" in order to provide certainty for operators. We recommend removing 

the exceptions clause from the NSO stipulation given the importance of 

preventing disturbance within water bodies and wetland areas. In reviewing 

numerous oil and gas leasing stipulations contained in other BLM EISs, we have 

not seen an exception process to allow drilling within water bodies or wetlands. It 

is our understanding that a "no exceptions approach" within a water body or 

wetland is BLM's standard procedure. In addition, the EPA recommends BLM 

y

The consistency for water and riparian stipulations have been addressed and 

are represented accurately in the text of the document and in Appendix C, 

where stips are described. There will be a water/riparian/floodplain NSO and a 

300’ CSU. 

When parcels are nominated for leasing, resource specialists conduct GIS 

investigations and if necessary site visits to determine what resources may be 

impacted if the lease is developed. During these investigations, the drainages in 

the area will be classified as perennial, intermittent or ephemeral, depending on 

many characteristics. If a riparian obligate species is present in a dry channel, it 

will be classified as intermittent. Soil surveys indicating hydric soils will also 

result in intermittent classification. Office personnel, with local expertise often 

times have knowledge of flow regimes in drainages as well, which can 

supplement on the ground investigations and data queries. 

Ephemeral drainages are runoff channels, only flowing in direct response to 

precipitation events and/or snowmelt. Except in gentle terrain, ephemeral 

drainages are simply too numerous and rarely active to afford the same 

protections as intermittent and perennial streams. During the permitting 

process, ephemeral drainages that are recognized as a potential problem for 

water quality issues will be identified and conditions will be put on the permit to 

minimize issues that may arise due to the proximity of development to the 

ephemeral channel.

100 year floodplains will be used in place of “flood plains”. 

The WEMs for the water and riparian resources stipulation were developed with 

regard to “protecting the unique biological and hydrological features and 

functions associated with perennial and intermittent streams, lakes, ponds, 

reservoirs, floodplains, wetlands, and riparian areas.”

Resource managers have discussed the appropriateness of NSO vs CSU for 

these riparian/water setbacks. Within the MT/Dakota BLM, it was decided that 

the 300 foot CSU would meet resource objectives. The MT DEQ 303d list of 

impaired waters shows only two streams that are impaired with oil and gas 

development as the causal factor. There is very little reference material 

supporting specific setback distances as most effective at mitigating impacts 

from oil and gas development. With the minimal impact documented in the 

state, and the CSU stipulation requiring a development plan that ensures 

resource objectives will be met, a CSU is deemed acceptable in protecting 

water resources. 
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consider revising the Appendix C Preferred Alternative CSU setback for riparian 

and wetland areas to a 500 foot NSO setback for perennial, intermittent and 

ephemeral streams, lakes, ponds, reservoirs, riparian and wetland areas. Other 

BLM Field Offices have required a 500 foot setback to minimize potential 

deterioration of water quality and to maintain natural hydrologic function of 

stream channels, stream banks, floodplains, and riparian communities (e.g., see 

Grand Junction Field Office Draft RMP/EIS, NSO-1, Major River Corridors; NSO2, Streams/Springs). We also recommend adding "springs" to the list of water 

resources protected by these stipulations in order to maintain proper function of 

these susceptible resources (e.g., see Grand Junction Field Office, NSO-4, 

Lentic Riparian Areas -” which includes springs, seeps and fens).If the Preferred 

Alternative NSO stipulation proposed in Draft RMP/EIS Chapters 2 and 4 is the 

intended version, then we support this more protective proposal. We recommend 

expanding it to a 500 foot NSO setback for perennial, intermittent and ephemeral 

streams, lakes, ponds, reservoirs, riparian and wetland areas, as described in 

the paragraph above and as has been done in other BLM Field Offices.

DRMTDK-BL13-0109-

15

Livestock 

Grazing,

Water

Potential Measures to Protect Water Resources from Impacts Due to Grazing: 

Grazing has the potential to adversely impact water resources, including surface 

and ground waters, wetlands, streams, springs and riparian areas. BLM's 

Standards for Rangeland Health and Guidelines for Livestock Grazing 

Management for Public Lands Administered by the BLM for Montana and the 

Dakotas underwent NEPA analysis in 1997 and are incorporated into the 

relevant RMPs, including the BiFO RMP. We understand from conversations 

with the BLM Miles City Field Office that BLM's process is to prepare 

environmental assessments to assess the effects of alternatives developed to 

ensure that Rangeland Health Standards are met through grazing allotment 

goals and objectives. If livestock grazing levels or practices are a significant 

factor in failing to meet Rangeland Health Standards, the BLM has committed to 

take action no later than the start of the next grazing year to initiate progress 

toward meeting the Standards. Since such action must be taken quickly, we 

recommend that the Final RMP/EIS include a list of potential measures that 

could be implemented at the project level to meet Rangeland Health Standards. 

This list could include measures that the BiFO has taken in the past, as well as 

the following suggestions: Require special protections for high quality wetland 

resources such as springs and fens. Such protections might include 

development of alternative water sources, fencing to exclude livestock from a 

spring source, and redirection of spring water to a trough for watering; To avoid 

possible infiltration of groundwater with contaminants resulting from 

congregation of livestock, require adequate separation between a livestock 

water well and a water trough or tank; Specify steps to protect and/or repair any 

existing exclusions and upland water developments, and develop new range 

n

Grazing does have the potential to impact water resources, and BLM is 

committed (required by regulation) to take action before the start of the next 

grazing season if it is determined that an allotment is failing to achieve one or 

more of the standards, and livestock grazing has been determined to be a 

causal factor. Guidelines (Volume III, Appendix I) have been developed to 

address many of the common causal problems associated with land health 

standards and livestock grazing. These guidelines are typically selected, 

analyzed, and if appropriate implemented following site specific NEPA analysis 

at the appropriate level (pasture, allotment, area, or watershed). These 

guidelines may be used independently and/or in conjunction with others. The 

existing guidelines incorporate many of the potential remedy measures you 

suggest as well as others. Because site specific conditions may vary widely 

among allotments, there is no comprehensive list approach that will address 

problems in all situations. In addition “Other Terms and Conditions” are 

commonly applied to grazing authorizations to facilitate site specific 

management and unique circumstances.

The use of adaptive management is commonly implemented on a site specific 

basis and has been addressed in this document. 

Monitoring and evaluation is typically scheduled based on the management 

category of an allotment. The current management category of specific 

allotments can be found in Volume III, Appendix S. Proposed changes to 

management category by alternative can be found in Volume I, Table 2-6.2, Pg. 

2-118 of the DRMP. As directed by existing policy, should an allotment be 
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improvements to protect water resources; Monitor impacts from grazing 

adjacent to high value water resources; Adjust the timing of grazing by delaying 

Spring turnout, increasing rotation, and focusing grazing on areas less intensely 

used in the previous year; and Develop a monitoring plan and schedule to 

assess effectiveness of range improvements in protecting aquatic resources. In 

addition, we recommend the Final RMP/EIS identify the general features of an 

effective adaptive management plan that could be employed at the project level, 

including the following: Decision tree with achievable and measurable objectives 

to provide accountability and guide future decisions; Specific decision 

thresholds with identified indicators for each impacted resource; Targets that 

specify a desired future condition; Commitment to implement and fund a 

monitoring plan with protocols to assess whether thresholds are being met; 

Commitment to use monitoring results to modify management strategies as 

necessary; and Designated timeframes for completion of necessary 

management modifications.

determined to not be meeting the water quality standard and livestock grazing 

is determined to be a causal factor, the allotment would be re-categorized to an 

“I” management category which would prioritize that allotment for monitoring 

and evaluation.

DRMTDK-BL13-0109-

16

Travel Mngt

Potential Measures to Protect Water Resources from Impacts Due to 

Implementation of Travel Management Plans: Appendix 0, Billings Field Office 

Travel Management Plan, notes that within 3-5 years of issuance of the ROD for 

the RMP/EIS, Travel Management Plans will be developed for each of the Travel 

Management Areas identified through this RMP/EIS process. Based on 

discussion between our staffs, we understand that these Travel Management 

Plan decisions will be based on additional site specific NEPA analyses. We 

recommend clarifying Appendix 0 and the Final RMP/EIS, Section 1.4.1.1, 

Travel Management Planning, to confirm that site-specific NEPA analyses will be 

conducted for individual Travel Management Plans.

n

Please refer to Section 1.4.3.1.1 in the draft RMP/EIS for a discussion of 

Implementation level NEPA analysis regarding Travel Management.

In response to your comment, please refer to “Text changes” for Appendix O 

and Chapter 1.4.1.1 changes. The text has been altered to better reflect that 

site specific NEPA Analysis will be done.

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17

Water

Public Drinking Water Supply Source Characterization In order to ensure that 

public drinking water supply sources (e.g., surface water sources, including 

groundwater under the direct influence of surface water (GWUDISW) sources, 

and groundwater sources) are protected from potential impacts associated with 

BLM-authorized activities in the Planning Area, it is important to identify where 

these sources are located. Therefore, the EPA recommends that the Final 

RMP/EIS include a map delineating source water protection areas for public 

water supply wells. Please contact Joe Meek, MDEQ, via the contact information 

below for a map of the Public Water Supply Inventory Regions in the BiFO. We 

also recommend identifying reservoirs that are drinking water sources and 

disclosing potential impacts to these sources.

y

A SWPA stipulation has been developed. It stipulated NSO within SWPAs, with 

the objective to: “To protect human health by minimizing the potential 

contamination of public water systems. Source water is untreated water from 

streams, rivers, lakes, or aquifers used to supply public water systems. 

Ensuring that source water is protected from contamination can reduce the 

costs of treatment and risks to public health. This stipulation would protect the 

State-designated Source Water Protection Areas that protect public water 

systems from potential contamination.”

Oil and Gas leasing EAs (NEPA) will identify SWPAs with regard to proposed 

parcels, making developers and resource managers aware of potential issues. 

The EA will analyze the impacts of leasing parcels to SWPAs. 

DRMTDK-BL13-0109-

18

Water

Public Drinking Water Supply Source Mitigation In order to ensure public 

drinking water supply sources (e.g., surface water sources, including GWUDISW 

sources, and groundwater sources) are protected from potential impacts 

associated with oil and gas leasing, the EPA recommends the following NSO 

y

A SWPA stipulation has been developed. It stipulated NSO within SWPAs, with 

the objective to: “To protect human health by minimizing the potential 

contamination of public water systems. Source water is untreated water from 

streams, rivers, lakes, or aquifers used to supply public water systems. 
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language: Municipal Supply Watersheds1 - NSO within any of the following 

areas, as deemed appropriate by the BLM: The entire watershed; or Local 

Source Water Protection Planning Areas where delineated in a Source Water 

Protection Plan; or Surface Water Spill Response Region or Groundwater 

Inventory Region defined by Source Water Assessments that have been 

delineated or evaluated by the State Surface Water Spill Response Regions are 

1/2-mile-wide zones (on both sides of rivers or streams, upstream of drinking 

water intakes. They include the water body with the surface water intake and 

significant tributaries, for 10 miles upstream of the drinking water intake. For 

lakes and reservoirs, they include a 1/2-mile-wide zone around the water body 

Groundwater Inventory Regions are based on a three-year time of travel or a 

fixed radius of 1,000 feet (concentric buffer) around the public water supply well. 

For surface water sources, if the Municipal Supply Watersheds NSO stipulation 

is not deemed feasible by the BLM, then at a minimum we recommend a 1000-

foot NSO or CSU setback on both sides of the river or stream, for 10 miles 

upstream of the intake. For lakes and reservoirs, this would include a 1000-foot 

NSO or CSU setback around the water body. For groundwater and GWUDISW 

sources, if the Municipal Supply Watersheds NSO stipulation is not deemed 

feasible by the BLM, we recommend a minimum 1,000-foot CSU concentric 

buffer for these sources. We make this recommendation based on consultation 

with Joe Meek, the Source Water Protection Program Manager with the MDEQ. 

He may be contacted for additional information at 406-444-4806 or 

jmeek@mt.gov.The EPA also recommends the BLM include a commitment in 

the Final EIS and ROD to provide notice to lessees regarding these important 

areas in the Planning Area. Lease notices for drilling within Source Water 

Protection (SWP) Zones of public water supplies are now being used for all wells 

drilled under BLM authority within SWP Zones in Utah.1. Forest Service Manual 

(FSM2542) defines Municipal Supply Watersheds to include: "surface supply 

watersheds, sole source aquifers, and the protection zones around wells and 

springs." In Montana, protection zones are known as Inventory Regions

Ensuring that source water is protected from contamination can reduce the 

costs of treatment and risks to public health. This stipulation would protect the 

State-designated Source Water Protection Areas that protect public water

systems from potential contamination.”

Oil and Gas leasing EAs (NEPA) will identify SWPAs with regard to proposed 

parcels, making developers and resource managers aware of potential issues. 

The EA will analyze the impacts of leasing parcels to SWPAs. 

DRMTDK-BL13-0109-

19

Riparian/ 

Wetlands

(5) Wetlands, Riparian Areas and Springs The Draft RMP/EIS indicates that 

although only 3.5% of the Planning Area is comprised of riparian and wetland 

areas, the importance of the riparian zone to water quality and quantity is 

recognized. With this in mind, we recommend clarifying p. 3-55 to describe "the 

following guidance" that is referenced for setting the foundation for BLM 

management of riparian habitat, function and water quality. In addition, the Draft 

RMP/EIS identifies the southern portion of the Planning Area as containing a 

small desert region that includes several springs supporting an "invaluable" 

riparian zone. Springs often contain rare or unique plant and animal species in 

addition to being important contributors to hydrologic function. Therefore, the 

EPA recommends that the RMP include a commitment for further analysis of 

n

The “guidance” is referring to a number of plans and recommendations from 

BMPs to state and federal water quality standards. To clarify, the paragraph 

referred to will be written as:

“Best management practices, state and federal guidance concentrate on 

protecting water resources, which sets the foundation for BLM management of 

both surface and groundwater resources.”

Impacts to springs are identified and analyzed during project level NEPA 

analysis. Springs are delineated and identified on maps. Springs are treated as 

a wetland and/or riparian area in BiFO, affording the same protections. They 
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springs at the project level, including evaluation of function or condition prior to 

authorizing any activities in these areas. To ensure that springs, as well as 

perennial seeps and wetlands, are identified to facilitate their protection, we 

recommend delineation and marking of perennial seeps, springs and wetlands 

on maps and on the ground before development. Also, we note that Appendix B, 

Best Management Practices, identifies potential measures to protect springs. We 

recommend expanding the Final RMP/EIS Chapter 4 discussion of potential 

mitigation measures that may be applicable at the project level for oil and gas 

construction, drilling and production activities to prevent adverse impacts to 

these aquatic resources. These could include silt fences, detention ponds and 

other stormwater control measures. Other potential mitigation measures, 

including oil and gas leasing stipulations and measures to protect water 

resources from grazing impacts, are discussed above under Surface Water 

Mitigation.

are classified as lentic or lotic, depending on the discharge and flow 

characteristics. 

The mitigation measures used to minimize impacts to riparian areas and water 

resources are described in Appendix B. There are a number of measures that 

are implemented when and where appropriate. The Oil and Gas development 

“Gold Book” also describes a number of mitigation measures used to protect 

and conserve riparian function

DRMTDK-BL13-0109-2

Air

The Air Resources Technical Support Document (ARTSD), p. 6, states that Tier 

4 emission standards were assumed in the Draft RMP/EIS near-field modeling 

analysis in order to demonstrate compliance with the 1-hr NO2 NAAQS. We note 

that the ARMP, Section 6.1, initial mitigation requirement for diesel drill rig 

engines >200 hp to meet Tier 4 emission standards for non-road diesel engines 

indicates that "oil and gas operators may use drill rig engines that exceed Tier 4 

emission standards if modeling demonstrates compliance with the NAAQS and 

protection of AQRVs." We assume that this caveat means that additional nearfield modeling will be required at the project-level if higher-emitting engines will 

be used. We recommend the Final RMP/EIS and ROD include this commitment.

Y

See the discussion in Appendix T, Section 6.1. Text has been modified to state 

that modeling or monitoring may be used to demonstrate compliance if non-Tier 

4 engines are used. Demonstrations may be made at the project level or at a 

programmatic level.

DRMTDK-BL13-0109-

20

Water

Water Management Water demand associated with the drilling and completion of 

new wells in the Planning Area is an important consideration that will benefit 

from analysis and disclosure. Although the oil and gas reasonably foreseeable 

development (RFD) for the Planning Area is relatively low, the Draft RMP/EIS 

notes that (a) depletion of surface water in the Planning Area watersheds may 

affect major rivers, including the Yellowstone, and (b) produced water from oil 

and gas development may affect groundwater. We recommend that the Final 

RMP/ EIS include a general discussion of the following: Based on predicted well 

depths, formation characteristics, and well designs (and fracturing operations, if 

used), estimate a range of water demand per well developed in the Planning 

Area; Possible sources of water needed for oil and gas development; and 

Potential impacts of the water withdrawals (e.g., drawdown of aquifer water 

levels, reductions in stream flow, impacts on aquatic life, wetlands, and other 

aquatic resources).In addition, the EPA recommends the Final RMP/EIS include 

a general discussion of how flow back and produced water will be managed 

including: Estimated volume of produced water per well; Options and potential 

locations for managing the produced water (i.e., UIC wells, evaporation ponds, 

n

The level of development seen and forecasted in the BiFO precludes a need for 

detailed analysis of these issues. As development occurs, NEPA analysis of 

proposed projects would identify issues that may affect the environment and 

determine the impacts thereof. Attempting to analyze these impacts 

preemptively is not feasible due to the wide range of conditions coupled with 

the low forecast for development. The scenarios are too varied concerning 

geology and development location.

In the event a large development is proposed, a thorough and detailed analysis 

would be conducted of issues that are identified through internal and external 

scoping. These issues are not within the scope of this RMP level document. 
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and surface discharges); Possible target injection formations, formation 

characteristics and depth of any UIC wells; and Potential impacts of produced 

water management.

DRMTDK-BL13-0109-

21

Water

Water Resource Monitoring A general framework for implementation and 

monitoring of the RMP is provided in Appendix X, Implementation and 

Monitoring. We recommend expanding this appendix, similar to the Miles City 

Draft RMP example, to include detailed monitoring measures and identification 

of frequency, remedial action triggers and management options. In particular, the 

EPA recommends that BiF0 require all BLM-authorized oil and gas multi-well 

projects to conduct groundwater and surface water monitoring, similar to RMP 

requirements included by other BLM Field Offices, e.g., White River and Grand 

Junction in Colorado. To that end, we recommend that the Final RMP/EIS 

describe the components of water resource monitoring that will be expected of 

new projects in the Planning Area, including how water quality monitoring will 

occur prior to, during, and after such development to detect impacts to both 

surface water and groundwater resources, including private wells. The EPA 

encourages BLM to include monitoring frequency expectations to ensure water 

quality changes are detected in a timely fashion to address any increased 

pollutant levels in streams and to verify expected improvements from changes in 

management practices. Streams could be prioritized for monitoring frequency 

where some streams (e.g., 303(d) listed impaired water bodies) would receive 

yearly or seasonal monitoring and other streams would be monitored much less 

frequently. Evaluations of water quality could also follow this time schedule as 

appropriate. A recent example of a water quality monitoring plan is the "LongTerm Plan for Monitoring of Water Resources" developed by BLM for the Gasco 

Energy Inc. Uinta Basin Natural Gas Development Project Final EIS2. Also, the 

National Ground Water Association's Water Wells in Proximity to Natural Gas or 

Oil Development Brief3 provides information on the importance of baseline 

sampling for private wells and types of analysis recommended.2 

http://www.blm.gov/pgdata/etc/medialib/b1m/ut/vemalfo/planning/gasco 

eis/gasco folder 6.Par.10452.File.dat/28 Gasco%20Appendix%200.%20Longterm%20Water%20Monitoring%20Plan.pdf 3 

http://region8water.colostate.edu/PDFs/Water Wells in_proximityNGWA2011.pdf

n

This comment addresses issues that are not within the scope of this document. 

During project development, scoping identifies issues that may affect the 

environment and subsequently they are analyzed in detail and a decision is 

made regarding their significance. 

Monitoring levels of various resources are established through project level 

NEPA analysis.

DRMTDK-BL13-0109-

22

WSR

(7) Wild and Scenic Rivers Based on our review of the Draft RMP/EIS, we 

understand that the BLM uses the RMP process to identify and evaluate rivers 

for eligibility and suitability under the Wild and Scenic Rivers (WSR) Act. The 

BiFO developed an inventory of 14 potential river segments in the Planning Area 

to be considered for eligibility. Draft RMP/EIS Appendix R, Wild and Scenic 

Rivers, discloses how the eligibility analysis was conducted and how 7 of the 14 

potential segments were determined eligible. Draft RMP/EIS, Chapter 4, 

Environmental Consequences, notes that the Preferred Alternative would 

n

Thank you for your comments. The specific comment regarding the process on 

which Suitability determinations were made was added to Chapter 4, and map 

# 165 has been modified to reflect suitable river segments. 

The Preferred Alternative, page 4-442 identifies NSO within 0.5 mile of WSReligible and suitable segments, but Appendix C identifies NSO within 0.5 mile of 

WSR-eligible segments. We will use the same terminology in both sections to 

avoid any confusion.
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recommend two of the eligible segments as suitable, and the other eligible 

segments would be determined non-suitable (and no longer afforded 

management protection for wild and scenic purposes). We recommend that the 

Final RMP/EIS disclose how the suitability analysis was conducted and how the 

suitability determinations were made. In addition, we recommend revising Map 

#165, Eligible Wild and Scenic Rivers, to include identification of segments with 

proposed suitability determinations. We also recommend that the Final RMP/EIS 

ensure consistency between Chapter 4 and Appendix C, Oil and Gas 

Stipulations. Currently for the Preferred Alternative, page 4-442 identifies NSO 

within 0.5 mile of WSR-eligible and suitable segments, but Appendix C identifies 

NSO within 0.5 mile of WSR-eligible segments. We recommend using the same 

terminology in both sections to avoid any confusion.

The apparent inconsistencies between will be changed

DRMTDK-BL13-0109-

23

Environmen

tal Justice, 

NEPA

(8) Environmental Justice The Draft RMP/EIS discloses that American Indians 

represent nearly 9% of the population in the Montana portion of the Planning 

Area with a high percentage living in poverty. Depending on the county, 

percentages of persons living below the poverty level in the Montana portion of 

the Planning Area range to 24%. The Environmental Consequences chapter of 

the Draft RMP/EIS states that no alternative will result in identifiable 

disproportionate effects specific to any minority or low income population or 

community. To confirm this determination, we recommend additional 

environmental justice analysis at the project-level stage of NEPA given the 

demographics of the area and the potential impacts from oil and gas 

development.

n

Thank you for your comment. Environmental Justice is considered in all project 

level NEPA documents.

DRMTDK-BL13-0109-

24

Climate

(9) Climate Change Pursuant to draft Council on Environmental Quality (CEQ) 

guidance and Executive Order 13514, BLM has included an analysis and 

disclosure of greenhouse gas (GHG) emissions and climate change. We note 

that the GHG emissions inventory does not include oil and gas emissions from 

"downstream" activities such as refining that will occur outside the Planning 

Area. Because information on these "downstream" indirect GHG emissions from 

activities may be of interest to the public in obtaining a complete picture of the 

GHG emissions associated with BLM-authorized activity in the Planning Area, it 

may be helpful to estimate and disclose them.

N

The BLM does not have sufficient information to estimate GHG emissions from 

downstream activities. 

DRMTDK-BL13-0109-3

Air

We also note an inconsistency between the ARMP and ARTSD. The ARMP 

Section 6.1 includes an initial mitigation measures list which does not include a 

requirement for drill and completion engines >750 hp to meet Tier 4 generator 

set emission standards even though this was the emission rate used in the nearfield modeling exercise (see the ARTSD, p. E-13, for modeled drill rig emission 

calculations). Based on conversations between our staffs, we understand that 

BLM's near-field modeling analysis included the Tier 4 generator set emission 

rate for engines > 750 hp in order to be representative of what is currently 

happening in the field (based on BLM experience), and that BLM does not 

N

In response to an earlier EPA request under the MOU that larger drill rig and 

completion engines be modeled, the BLM modeled the largest engines 

expected to be operating in the planning area. Based on research and 

discussions with BLM fluid minerals staff, the BLM determined that these 

largest engines are generator set engines. Smaller non-generator set engines 

may be used for some wells. At the planning stage, the BLM cannot model 

every size/type engine combination that could conceivably be used. The BLM's 

approach is reasonable, but conservative, and predicts compliance with the 

NAAQS. Both generator set and non-generator set engines are subject to 
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believe requiring Tier 4 generator set emission standards for engines >750 hp is 

necessary to demonstrate compliance with the 1-hour NO2 NAAQS. To disclose 

BLM's intent, we recommend that the Final RMP/EIS include the following: 

Clarification regarding which mitigation measures were necessary to ensure 

compliance with the NAAQS; and An explanation as to why BLM believes 

requiring drill and completion engines >750 hp to meet Tier 4 generator set

emission standards is not necessary to demonstrate compliance with the 1-hour 

NO2 NAAQS.

EPA’s non-road diesel engine regulations. The BLM is requiring drill rig and 

completion engines to meet the most stringent EPA emission standards for both 

generator set and non-generator set engines, with the exception that future 

modeling or monitoring may demonstrate that the use of non-Tier 4 engines 

may be used if adequate air quality protection is demonstrated.

DRMTDK-BL13-0109-4

Air

In addition, the ARMP Section 6.2, Monitoring-Based Mitigation, indicates that 

prior to completion of the photochemical grid modeling (PGM) analysis, 

monitoring-based thresholds for determining enhanced mitigation would be 

based on evaluation of monitored exceedances of the NAAQS. However, in the 

discussion of modeling-based thresholds for evaluating enhanced mitigation 

(Section 6.3), it is stated that "potential future impacts" on NAAQS or Montana 

Ambient Air Quality Standards (MAAQS) will be considered. To provide clarity 

regarding the trigger and consistency within the ARMP, we recommend 

replacing this language with "NAAQS or MAAQS exceedances" predicted via 

future PGM.

Y See Appendix T. Section 6.3.1

DRMTDK-BL13-0109-5

Air

Further, Section 1.5 of the ARMP includes a detailed discussion of requirements 

for oil and gas activities that were developed through the 2008 Montana 

Statewide Oil & Gas EIS (Statewide), some of which are being integrated into 

the BiFO ARMP. We note that two of the Statewide requirements that are not 

"carried forward" into this ARMP are requirements to (1) maximize the number of 

wells connected to each compressor and (2) utilize natural gas fired or electrical 

compressors or generators. We recommend that BLM provide its rationale for 

discontinuing these emission-reducing requirements.

N

Natural-gas-fired or electrical compressors or generators are included as initial 

mitigation in Appendix T, Section 6.1. Due to the low level of development in 

the planning area and a decrease in compression throughout the area, the 

requirement to maximize the number of wells connected to each compressor 

has become a moot point. 

DRMTDK-BL13-0109-6

Air

Finally, we recommend the following edits to the Draft ARMP to clarify 

terminology and/or to reflect recent discussions of the AQTW: ARMP pp. T -” 

11-12: We understand that BLM intends to run the PGM to cover the full 20 year 

planning cycle of the RMP rather than performing an initial PGM run followed by 

periodic reassessments as described in Section 5.1.2 on p. T-12. We 

recommend revising the text to clarify this point. In addition, we recommend 

revising Table 2, p. t-11 to include time in the schedule for the AQTW to review 

results from emissions modeling. Section 6.2.3 indicates that following PGM 

completion, BLM would calculate design values for each pollutant monitored at a 

federal reference monitor within the Planning Area. For completeness, we 

suggest revising this language to include federal equivalent method monitors 

since data from these monitors could be used in an identical fashion to the data 

collected from federal reference monitors. Section 6.2.4: After the PGM is 

completed, we recommend a 1-year timeline for implementation of measures 

after selection of enhanced mitigation, similar to the timeline provided for 

Y

Suggested clarifications have been addressed in relevant portions of Appendix 

T.
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implementation of enhanced mitigation measures prior to PGM completion (see 

Section 6.2.2: "Selected mitigation measures would be implemented within one 

year after the BLM decision to apply additional mitigation").

DRMTDK-BL13-0109-7

Air

Appendix Y, Emissions Inventories Appendix Y, Emissions Inventories, provides 

slightly different emissions inventory totals as compared to those presented in 

the ARTSD. In particular, the PKÂ° and PM2.5 emissions associated with Oil 

and Gas development appear more substantive. We recommend reconciling the 

two documents or explaining the differences.

Y

Emission inventories were updated and the revised emission estimates are 

included in Sections 4.1.2.3–4.1.2.6, Appendix Y, and in the ARTSD.

DRMTDK-BL13-0109-8

Air

Air Resource Technical Support Document It is important that the emissions 

controls and mitigation measures used to develop the emissions inventory be 

included as required mitigation measures for activities under the RMP. The 

alternative specific emissions inventory includes an 84% control efficiency of 

gravel or scoria surfacing for calculating dust emissions. The ARTSD, p. 6, 

identifies assumptions used in this emissions inventory, including a 50% fugitive 

dust control efficiency but no mention of this 84% control with gravel or scoria. If 

84% surfacing control was used in the near-field modeling, then we recommend 

that this control efficiency be added to the identified assumptions on p.-6 of the 

ARTSD and that gravel/scoria surfacing be added to the initial mitigation list of 

the ARMP, Section 6.1. In addition, we have a few recommendations for 

clarification of the ARTSD, as follows: pp. 14-15 -” Figure 1 illustrates the well 

pad and receptor layout for PK() and PM2.5 modeling. Please clarify whether 

this same receptor layout was used for the other criteria pollutants. p. 19 -

Predicted criteria air pollutant concentrations were compared to the NAAQS, 

MAAQS, and Prevention of Significant Deterioration increments. For disclosure 

purposes, we recommend the annual comparisons for the NAAQS and MAAQS 

be discussed in this paragraph.

Y

The AERMOD emission inventory was based on a 50 percent fugitive dust 

control efficiency, which is a conservative estimate, while the alternativespecific emission inventories included 84% reflecting gravel or scoria surfacing 

which is standard practice in the planning area. The suggested change 

regarding receptor layout was incorporated into Section 4.1.1.3.1. Annual 

comparisons to the NAAQS and MAAQS were provided in this section for those 

pollutants with annual averaging times. 

DRMTDK-BL13-0109-9

Water

The Draft RMP/EIS, Chapter 3, Affected Environment, notes that groundwater is 

a valuable resource in Montana and is the primary source of drinking water for 

Montanans who live outside city boundaries or who use public water systems in 

smaller towns, as well as the primary source of water in streams and rivers 

during fall and winter "baseflow" periods. Given the potential and existing 

groundwater use in the region, it is important to characterize the groundwater 

resources within the Planning Area. We recommend expanding the discussion in 

the Final RMP/EIS to include the following information: A description of all 

aquifers in the study area, noting which aquifers are Underground Sources of 

Drinking Water (USDWs). Federal Safe Drinking Water Act regulations define a 

USDW as an aquifer or portion thereof: (a)(1) which supplies any public water 

system; or (2) which contains a sufficient quantity of ground water to supply a 

public water system; and (I) currently supplies drinking water for human 

consumption; or (ii) contains fewer than 10,000 mg/1 total dissolved solids; and 

(b) which is not an exempted aquifer (See 40 CFR Section 144.3); Maps 

y

Previous comment responses regarding SWPAs and the new stipulation to 

protect them address this comment. Generally, MT DEQ provides standards 

and guidance in managing activities that could impact drinking water resources, 

which the BLM complies with through various agreements/MOUs. A SWPA 

stipulation has been developed. It stipulated NSO within SWPAs, with the 

objective to: “To protect human health by minimizing the potential 

contamination of public water systems. Source water is untreated water from 

streams, rivers, lakes, or aquifers used to supply public water systems. 

Ensuring that source water is protected from contamination can reduce the 

costs of treatment and risks to public health. This stipulation would protect the 

State-designated Source Water Protection Areas that protect public water 

systems from potential contamination.”

Oil and Gas leasing EAs (NEPA) will identify SWPAs with regard to proposed 

parcels, making developers and resource managers aware of potential issues. 
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depicting the location of sensitive groundwater resources such as: municipal 

watersheds, source water protection zones (available from the Montana 

Department of Environmental Quality-MDEQ, Joe Meek, see contact information 

below), sensitive aquifers, and recharge areas; and A description of and 

locations of groundwater use (e.g., public water supply wells, domestic wells, 

springs, and agricultural and stock wells).

The EA will analyze the impacts of leasing parcels to SWPAs. The commenter 

states, “Appropriate groundwater protection measures can vary depending on 

hydrologic conditions and the presence of drinking water resources. Depending 

on the level of oil and gas development, lease stipulations may be necessary 

due to the disproportionate effect on water resources from such development.” 

Relevant to this, the BLM cannot address every potential specific issue that 

may arise throughout the field office in a programmatic document such as this 

RMP. The impacts mentioned will be, if scoping identifies them, analyzed at the 

project level during NEPA analysis. A series of stipulations are available to 

managers to minimize impacts to water resources. 

Additionally, since this draft was produced, a new stipulation has been 

developed to conserve water quality in Source Water Protection Areas (SWPA). 

An NSO for all SWPAs is stipulated. SWPAs were identified by MT DEQ data.

Concerning municipal water supplies, MT DEQ regulates activities with 

potential to affect municipal water supplies. The BLM works under an MOU to 

follow MT DEQ guidelines in these circumstances. 

DRMTDK-BL13-0111-3WILD 

HORSES,

PMWHR

I support the maximization of the available range by increasing water 

catchments to increase the available forage for the wild horses and other wild 

life. I also support working with other agencies to increase the size of the range. 

Including the elimination of the fence across the top of the mountain that limits 

the horses access to the forage they have used for years. I urge you to work with 

the National Forest Service to give the horses access to the mountaintop and 

the Tony Island Spring. In addition, I encourage the collaboration with the 

National Park Service to add the Sorenson Extension to the wild horse range.

N Thank you for your comment

DRMTDK-BL13-0116-1

Noxious 

and 

Invasive 

Species, 

Recreation

This comment is meant for the BLM land northeast of Big Timber on Big Can Hill 

(Rapelje Rd)I strongly support not opening this land for motorized vehicles. 

There is ample opportunity for target shooting along the Rapelje Road that 

passes thru this BLM ground. I support all shooting sports but there is plenty of 

room to shoot along Rapelje Road. People can and do walk into this property to 

shoot now, they don't need to drive in. Spread of noxious weeds is a huge 

reason to keep this property closed to motorized vehicles, which are proven 

spreaders of weed seeds. There is leafy spurge on this property now, but no 

knapweed. If opened to motorized vehicles it would only be a matter of time 

before knapweed was brought to this property. That would be devastating to the 

range and costly to control.

n

Thank you for your comment.

The Billings Field Office, in conjunction with the Sweet Grass County Weed 

District, has been actively treated the weed issue in this area since 2002. BLM 

plans to continue to treat the invasive and noxious weeds throughout the life of 

the plan.

 Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS.

There are a range of possible decisions that could be made. In the case of 

motorized use in the Tin Can Hill parcel, the decision has been made to 

continue to vehicle closures while allowing motorized access for administrative 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

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purposes such as weed management. 

DRMTDK-BL13-0117-1

Travel Mngt

Please designate the following areas for non-motorized use, to provide a quiet & 

natural experience for hikers and for native wildlife: Big Sky Trail, Demijohn Flat, 

and all of Bear Canyon.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed” to motorized use and as a non-motorized trail. 

Refer to map 146

DRMTDK-BL13-0121-

10

Wildlife

Another concern is how much of the information presented is based on studies 

of Sage Grouse management Zone I, which includes northeastern Wyoming and 

far western North and South Dakota. This broader scale may or may not be 

directly applicable to the Billings planning area. How does the planning arca 

compare to Zone 1? What similarities and differences exist between the zones 

and how is Zone 1 compatible with the planning area? Fidelity questions the 

validity of the proposed stipulations in the EIS if the data used comes from data 

found in an entirely different management area with no justification as to how 

applicable to the Billings/Pompey's Pillar planning area this information is

n

See page 3-85 to 90 of the DRMP for a discussion of MZ1 and MZ2 within the 

Billings Field Office.

DRMTDK-BL13-0121-

11

Wildlife, Oil 

and Gas

Much of the current oil and gas development is occurring on private lands with 

little or no mitigation efforts, which elevates ecological and conservation 

importance of sage-grouse habitat on public lands." Please provide the source of 

information stating much of the current development is on private lands.

n

Thank you for your comment. See the Bibliography reference Knick, 2011. Pg. 

3-80 - "Nearly 16 percent of Sage-Grouse Management Zone 1 is within 3 

kilometers of oil and gas wells, a distance in which ecological impacts are likely 

to occur (Knick et al 2011).

DRMTDK-BL13-0121-

12

Wildlife

The "warranted but precluded" listing of the sage-grouse has already increased 

public awareness of the need for conservation efforts. This has increased 

conservation efforts on private lands and BLM should discuss some of the 

measures already in place promoting protection of the bird.

n

Paragraph 3, page 4-288, discusses the NRCS working with grazing operators 

and range management on up to 10,000 acres in Core Area #4.

DRMTDK-BL13-0121-

13

Wildlife

BLM should include information on how the decision of the Greater Sage-grouse 

Habitat Conservation Advisory Council will affect management in the planning 

area. How does BLM plan to implement the guidance of the Council?

n

BLM intends to rely on the latest research and best available science by 

utilizing existing research and delaying final decisions until the Governor’s Sage 

Grouse Advisory Council recommendations are final, incorporating the “USGS 

Range-Wide Genetic Connectivity of Greater Sage-Grouse Populations” study 

when it is complete, and incorporating other future research through the 

“Adaptive Management” approach described in Section 2.3.4, 

DRMTDK-BL13-0121-

14

Air

BLM's proposed management routinely exceeds its authority by attempting to 

control air emissions and air quality despite the regulatory boundaries included 

in the Clean Air Act (CAA). Under the CAA, only the Environmental Protection 

Agency (EPA) and its delegates have sole authority for such regulation. Since 

MDEQ already has an approved program along with the requisite expertise to 

handle the air quality, why does BLM feel compelled to develop a separate 

Y

The Clean Air Act’s regulations impose extensive actions after ambient air 

quality monitoring indicates violations of the NAAQS and exposure of the public 

to unhealthy air quality. As explained in Appendix T, Section 1.5.3, the BLM 

operates under FLPMA and NEPA mandates to protect air resources and 

prevent violations of the Clean Air Act. As described in Appendix T, Section 

4.1, the BLM will use only quality-assured monitoring data when determining 
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program? Moreover, the CAA has already established extensive actions based 

on actual monitoring data. Clearly, BLM should only use approved design values 

prior to implementing mitigation measures on sources in the planning area.

mitigation design values and will confer with the MDEQ and EPA concerning 

these values.

DRMTDK-BL13-0121-2

NEPA

The alternatives were explained in the Draft (EIS), but useful information was not 

included in the Draft RMP. BLM's planning regulations similarly require the BLM 

to estimate the physical, biological, economic, and social impacts associated 

with each alternative in the RMP/EIS and a proper description of the alternatives 

was not provided

N

Thank you for your comment. Please see the Executive Summary, or Chapter 

2 for a description of the alternatives. 

DRMTDK-BL13-0121-3

Oil and Gas

BLM also failed to comply with the Energy Policy and Conservation Act 

requirements to use the least restrictive stipulations necessary for oil and gas 

exploration and development activities

N

Thank you for your comment. BiFO has complied and used the least restrictive 

stips as possible. 

DRMTDK-BL13-0121-4

Oil and Gas 

BLM needs to provide details as to how they plan to utilize scientific protocols 

and assess the effectiveness of management actions. The descriptive language 

in the RMP is very vague and comes with a lot of uncertainty of what the oil and 

gas industry can expect in the future.

N Thank you for your comment. 

DRMTDK-BL13-0121-5

Wildlife, Oil 

and Gas 

There are maps for NSO, CSU and TLS regarding oil and gas "leasing standard 

stipulations" and "major moderate constraints," however there were not separate 

maps available for many of the species with proposed restrictions. BLM should 

provide all of these habitat maps to allow interested parties to determine exactly 

what areas will be affected separately from maps demonstrating overall 

restrictions

n

Thank you for the comment. 

Individual species maps are compiled on Maps 50-57 that identify Fluid 

Minerals Standard Lease Terms and Major/Moderate Constraints, the individual 

species maps are not included.

DRMTDK-BL13-0121-6

NEPA More in-depth information regarding compensatory mitigation should be included 

in the document if BLM is proposing to implement it. Y

Thank you for your comment. 

Please see Appendix___ for information on compensatory mitigation. 

DRMTDK-BL13-0121-7

Wildlife

BLM has relied upon scientific data which is flawed for a number of reasons, not 

the least of which is the inappropriate reliance upon general scientific 

conventions based upon male lek attendance, but also because it is too general 

to be extrapolated to the planning area, and because it is based upon 

development scenarios that are unlikely to occur within Montana

n

Thank you for the comment. BLM intends to rely on the latest research and 

best available science by utilizing existing research. Other future research will 

be incorporated through the “Adaptive Management” approach described in 

Section 2.3.4, page 2-7 of the DRMP.

DRMTDK-BL13-0121-8

NEPA

Fidelity has noted a distinct lack of documentation demonstrating why current 

management strategies in the planning area are proving inadequate. A need for 

updates or added restrictions is required in order to justify additional stipulations.

n Refer to ES 1.1 “Purpose and Need” on pages ES-1 and 2.

DRMTDK-BL13-0121-9

Wildlife

Fidelity is concerned about BLM's reliance on data from the National Technical 

Team (NTT) report. A variety of peer-reviewed, scientific information should be 

included in the RMP in order to produce the best planning effort. Instead it 

seems BLM relies almost solely on information from the NTT report. Additionally, 

the Northwest Mining Association (NWMA) recently published a report which 

questions the validity of the NTT report, as the United Stated Fish and Wildlife 

Service's (USFWS) "warranted but precluded" determination was based on the 

conservation measures already in place in BLM manual 6840-” Special Status 

Species Management. Furthermore, the recommendation in the NTT report does 

n

In response to the greater sage-grouse management objectives described in 

the 2006 WAFWA Greater Sage-grouse Comprehensive Conservation 

Strategy, many reports have been prepared for the development of 

management recommendations, strategies, and regulatory guidelines. The 

National Technical Team report (NTT 2011), Conservations Objectives Team 

(COT; FWS 2013), and the Summary of Science, Activities, Programs and 

Policies that Influence the Rangewide Conservation of Greater Sage-Grouse 

(also referred to as the Baseline Environmental Report [BER]; Manier et al. 

2013) are the most widely used reports that have been incorporated in BLM 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

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not acknowledge the transient nature of activities occurring at a well. There is 

much more activity near the beginning of the drilling process, but once the well 

goes into production activity drastically declines and interim reclamation can 

usually begin. After a well is plugged and abandoned, the area is fully reclaimed 

and the site will return to productive habitat. Fidelity finds these issues very 

concerning and feels the measures contained in the EIS are unnecessarily 

restrictive or simply cannot be implemented.

and Forest Service EISs that address the effects of implementing greater sagegrouse conservation measures on lands they manage. [May use response to 

comment 10 above for specifics for NTT, COT, BER reports.]

Management actions by the BLM and the Forest Service in concert with other 

State and Federal agencies, and private land owners play a critical role in the 

future trends of greater sage-grouse populations. To ensure management 

actions are effective and based on the best available science, the BLM’s 

National Policy Team created a NTT in August 2011. The objective for 

chartering this planning strategy effort was to develop new or revised regulatory 

mechanisms, through land use plans, to conserve and restore greater sagegrouse and their habitat on BLM-administered lands on a range‐wide basis over 

the long term. The NTT report (NTT 2011) used the best current scientific 

knowledge to guide the BLM and the Forest Service planning efforts through 

management considerations to ameliorate threats, focused primarily on priority 

greater sage-grouse habitats on public lands. 

On December 27, 2011, the BLM released IM 2012-044. In accordance with 

this IM, the BLM must consider all conservation measures developed by the 

NTT in at least one alternative in the land use planning process. For the 

majority of greater sage-grouse DRMP/EISs, Alternative B fulfills this 

requirement by incorporating the recommendations set forth by the NTT. Other 

alternatives, including those developed by individuals and conservation groups, 

as well sub-regional alternatives developed by regional offices of the BLM and 

the Forest Service, have incorporated elements of the NTT report. 

The COT report (FWS 2013) qualitatively identifies threats/issues that are 

important for individual populations across the range of greater sage-grouse, 

regardless of land ownership. The Summary of Science, Activities, Programs 

and Policies that Influence the Rangewide Conservation of Greater SageGrouse (also referred to as the Baseline Environmental Report [BER]; Manier et 

al. 2013) then provides complimentary quantitative information to support and 

supplement the conclusions in the COT. Both documents helped planning 

teams identify issues within their planning area, determine the context within 

the management zone, prioritize habitats, and assist in creating a range of 

alternatives with management actions that can alleviate or mitigate threats to 

greater sage-grouse at an appropriate level. Both the NTT report and the COT 

report tier from the WAFWA Greater Sage-grouse Comprehensive 

Conservation Strategy (Stiver et al. 2006).

Alternative B is based on A Report on National Greater Sage-grouse 

Conservation Measures (NTT report) per direction in IM 2012-044. 

Conservation measures included in the NTT based alternative focus primarily 

on greater sage-grouse PPH and include a 3-percent disturbance cap in PPH. 

PPH areas have the highest conservation value to maintaining or increasing 
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greater sage-grouse populations. 

DRMTDK-BL13-0122-1WILD 

HORSES,

PMWHR

The use of reversible fertility drugs via darting has been working in the mares 

observed and even more successfully with the stallions. The costs are far far 

less than rounding up and then taking care of the horses in pens. (I live in 

Sparks, NV and board my horse just south of the BLM holding pens in Palomino 

Valley; they are never empty, often full.) The cost of darting the stallions is even 

less. The Carolina wild horses on the east coast have been managed by darting 

the females and the results are positive. The mares need to reproduce to be 

viable to the herd. The younger mares, with higher percentages of problems with 

pregnancy, births and raising the foals, due primarily to their young age, are 

darted for their first several years. Once the mares reach a more mature age 

they are left to breed until they have a foal, then can be darted again. The BLM's 

removal of horses from the range, with the known benefits of fertility drugs, is out 

dated. And based on the costs of maintaining the holding pens, lack of 

adoptions, and controversy surrounding the issues is obviously not working.

N

Thank you for your comment. This document is not tied to any gather as 

gathers are implementation level documents. 

DRMTDK-BL13-0123-1

Oil and Gas 

Although Montana has regulations that provide for minimal chemical disclosure, 

most of the chemicals used in oil and gas drilling are kept secret from the public. 

In addition to these rules, BLM recently released draft chemical disclosure and 

well stimulation rules1. We believe that, even though these rules also do not go 

far enough to protect water quality, they have some good provisions, and the 

final RMP must include these draft rules.

n Thank you for your comment.

DRMTDK-BL13-0123-

10

Coal

While the uncertainty of Asian coal demand raises serious questions about 

whether or not exports are a wise economic investment, it is clear that if Powder 

River Basin coal production is to have a future, it is in exports. This is significant 

because before leasing coal, BLM must determine that a lease sale serves the 

interests of the United States. Previous federal coal lease decisions have been 

explicitly justified on the basis that they served the nation's interests as a source 

of domestic energy. By leasing cheap coal for export to Asia (in particular, 

China, Asia's largest market), BLM subsidizes the economic engine of America's 

direct economic competitor at a cost to American jobs, in particular in the 

manufacturing sector

N

Thank you for your comment. The current Asian export market is strong and 

favors Montana PRB mines due to their coal quality and transportation 

advantages over Wyoming PRB coal producers. Due to the soft domestic coal 

market, MT coal mines may be able to maintain current production rates by 

participating in the export market thereby preserving jobs and royalty income to 

government entities.

DRMTDK-BL13-0123-2

Oil and Gas 

Although the current public debate focuses on contamination from hydraulic 

fracturing, other deficiencies such as faulty well casing, cement failure, and 

surface spills are all major threats to water quality and are the most common 

ways that water becomes contaminated in drilling operations. Earth justice has 

documented with an interactive map many of the known contamination cases 

across the US.3 However, since the water contamination that the Fort Peck 

Indian Tribe is facing from old oil wells is not on the map, it is certain that other 

incidents are also not accounted for. Through the RMP, the BLM should make 

sure that stronger casing and cementing standards are in place. These 

standards are currently included in the draft chemical disclosure and well 

n

Thank you for your comment. There is no fracking currently occurring in the 

Billings Field Office and it is unlikely to occur. Language has been added to 

Chapter 3 to address your concerns.
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stimulation rules just released by the BLM

DRMTDK-BL13-0123-3

Oil and Gas 

This water management practice is called a closed-loop system and is very 

effective for preventing some water pollution. Interestingly, despite this step 

forward, the filter socks that have been straining frack water have been 

exceeding federal radioactivity limits. This is an entirely new threat to our water 

system and, since the Montana Bakken stems from the same formation, it is a 

likely threat in Montana as well as North Dakota. The RMP must take these new 

developments into consideration. One resource could be the draft EPA "Study of 

the Potential Impacts of Hydraulic Fracturing on Drinking Water Resources." 

This study is scheduled to be completed in 2016 and the data collected so far 

should be addressed in the RMP

n

See Chapter 4, Water for text changes describing impacts from hydraulic 

fracturing. Also, see Chapter 3, Minerals, Leasable Minerals, Oil and Gas, and 

the Minerals Appendix, Oil and Gas, Fluid Minerals Operations and Procedures, 

Completion section for modifications. Draft documents are considered in 

planning but their draft decisions are not incorporated as they are subject to 

change.

DRMTDK-BL13-0123-4

water

The EPA has estimated that between 70 and 140 billion gallons of water are 

required annually for fracking6. This water is completely lost to the system since 

it is contaminated with chemicals and much of it is disposed of into deepinjection wells. This is in contrast to agricultural water use. Agriculture is the 

largest water user in Montana, but the water used is sent back into the overall 

water cycle. As the RMP states, one of the RMP's water management goals is to 

"protect water quality for municipal, industrial, agricultural, recreation, and 

residential purposes by adopting protective measures to meet federal, tribal, 

state, and local water quality requirements" (2-55). While the RMP thus affirms 

the importance of water, the impacts to water quantity from oil and gas 

development are not fully mitigated in the preferred alternative. First, we 

recommend the BLM document the amount of water available in the system on 

federal lands. According to the RMP, "no current, comprehensive, quantification, 

nor quality measurements have been made on ground waters occurring on BLM 

administered lands" (3-39).This needs to be remedied, and in particular, the 

BLM needs to track the amount of water used for federal oil and gas drilling. 

Some water resources are being documented on the industry-run website, 

FracFocus (fracfocus.org). However, from research mentioned in the Gone for 

Good report from Western Organization of Resource Councils, this data is 

incomplete. The BLM needs to take the lead on this through the RMP. 

Additionally, once documented, each well should have monitoring systems to 

ensure that the actual amount of water being used is accurate. Flow control

devices should be installed on all BLM water resources

Y

The commenter states, “Appropriate groundwater protection measures can vary 

depending on hydrologic conditions and the presence of drinking water 

resources. Depending on the level of oil and gas development, lease 

stipulations may be necessary due to the disproportionate effect on water 

resources from such development.” Relevant to this, the BLM cannot address 

every potential specific issue that may arise throughout the field office in a 

programmatic document such as this RMP. The impacts mentioned will be, if 

scoping identifies them, analyzed at the project level during NEPA analysis. A 

series of stipulations are available to managers to minimize impacts to water 

resources. 

Additionally, since this draft was produced, a new stipulation has been 

developed to conserve water quality in Source Water Protection Areas (SWPA). 

An NSO for all SWPAs is stipulated. SWPAs were identified by MT DEQ data.

Concerning municipal water supplies, MT DEQ regulates activities with 

potential to affect municipal water supplies. The BLM works under an MOU to 

follow MT DEQ guidelines in these circumstances. 

DRMTDK-BL13-0123-5

Air

One major impact from oil and gas in terms of air quality is the occurrence of 

flaring. In Montana, oil and gas wells can flare for an unlimited amount of time, if 

they produce less than 100,000 cubic feet of gas per day. This is extremely 

hazardous for the local air quality and contributes the larger threat of climate 

change. Although there is less development in the Billings Field Office than in 

the Bakken where much of the flaring occurs, the RMP should still limit flaring 

and require green completion systems for all federal wells. Fortunately, 

n

See Chapter 3, Air Resources and Climate, Climate Change, National Actions 

to Reduce GHGs section. Also, see the Air Resources and Climate Appendix, 

Air Resource Management Plan: Adaptive Management Strategy for Oil and 

Gas Resources, section 1.5.2 for additional information on GHG emission 

reductions and controls.
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according to a 2012 GAO report on natural gas emissions on federal lands, 

"data from EPA, supported by information obtained from technology vendors and 

GAO analysis, suggest that around 40 percent of natural gas estimated to be 

vented and flared on onshore federal leases could be economically captured 

with currently available control technologies.8" There is no reason why the BLM 

could not institute these technologies as conditions on each lease or as an 

overall RMP policy due to the climate and air quality impacts

DRMTDK-BL13-0123-6

Minerals

The Montana Bureau of Mines and Geology in conjunction with Montana Tech of 

the University of Montana are exploring a number of potential sites for frack sand 

mining. Two of those proposed sites are located in the Pryor Mountains (see 

Attachment 5). The BLM needs to be monitoring this proposed development and 

be ready to analyze any of the impacts associated with this mining. A section in 

the RMP about the potential for development should be included

n

Thank you for your comment. The BLM is aware of the potential for and interest 

in “frack” sand in the Bear Canyon area. Any proposed activity will be subject to 

the BLM’s 43 CFR 3809 Surface Management Regulations. Actual mining or 

disturbance greater than 5 acres would require the submittal of a Plan of 

Operations and compliance with NEPA. Chapter 3 has been edited to include 

discussion of the potential for “frack” sand, although the potential is quite limited 

and the development potential is low. 

DRMTDK-BL13-0123-7

Wildlife

Under the draft RMP there are some areas of overlap between sage priority 

protection areas and no surface occupancy oil and gas leases. While the NSO 

stipulation is a good step forward in some ways, it is concerning that more of the 

area is not closed to leasing. This needs to be considered since even with a no 

surface occupancy restriction, well pads and the associated infrastructure (such 

as roads and pipelines) are still built nearby. From reviewing sage grouse 

studies, it is clear that setbacks (which is what no surface occupancy essentially 

is) are just one way to address the issue. According to Oil and Gas Development 

and Greater Sage Grouse (centrocercus urophasianus): A Review of Threats 

and Mitigation Measures, "The focus on set-back distances provides only a finite 

set of options for land managers and permitees alike. Because this approach 

does not take into account the specific causes of sage grouse avoidance, 

mortality, or potential population-level effects, it is of limited effectiveness to 

sage grouse conservation and management. A more comprehensive approach 

should incorporate performance standards that are based on an understanding 

of specific causes and effects of oil and gas infrastructure impacts on sage 

grouse (i.e., noise, predation, disease), as well as consideration of habitats other 

than leks (i.e., nesting, brood rearing, and winter habitats).

n

Refer to page 2-77, Alternative B, states “Closed to future oil and gas leasing, 

exploration and/or development.” Alternatives C and D state that , “Surface 

occupancy and use would be prohibited in sage-grouse PHMAs (NSO).”

It is hoped that Adaptive Management can implement new guidelines such as 

Performance Standards as future research may indicate. 

Refer to cumulative effects section 4-286, paragraph one “Wildlife management 

opportunities for the BLM are very limited in scattered land ownership areas....” 

BLM can apply protections to Public lands only, make recommendations to 

private surface landowners on private surface/ Federal mineral estate and 

cannot provide any direction for surrounding non-public lands.

In addition, the Land Use Planning Handbook, H-1601-1, Appendix C, page 24, 

states: “When applying leasing restrictions, the least restrictive constraint to 

meet the resource protection objective should be used.”

Please refer to Appendix AA (section F), Mitigation Measures and Conservation 

Actions for Sage Grouse Habitat”, that emphasizes a more comprehensive 

approach to habitat management and BMPs for sage grouse from Fluid Mineral 

development.

DRMTDK-BL13-0123-8

Coal

To protect private property rights and preserve the intent behind surface owner 

consultation, BLM should undertake new surface owner consultation before it 

finds lands suitable for further consideration for leasing, as required under 43 

CFR 3420.1 4(e), and at the very least, the agency needs to ascertain surface 

owner consent before any coal exchanges

N

The coal screening process will be applied to future lease application and 

exchange areas.

DRMTDK-BL13-0123-9

Coal

While we applaud BLM's decision to take action to protect sage grouse, we 

encourage BLM to take a hard look (if it has not done so already) at the effects 

of underground mining on sage grouse populations. While undoubtedly less 

n

Thank you for your comment. Please see the Alternatives table in Chapter 2 -

solid leasables (coal) to address your concern
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significant than those caused by surface mining, underground mining techniques 

such as longwall mining lead to significant subsidence cracks that disturb land 

and threaten water resources. In the Bull Mountains, problems with carbon 

monoxide at Signal Peak Energy's mine have required new road construction, 

new pipeline, and at least one diesel generator to power noisy fans to clear out 

the mine. While those were necessary and appropriate safety steps, they would 

have a significant effect on an area, both due to direct disturbance as well as 

issues like noise (which has a well- established effect on sage grouse leks). 

Subsurface mining still has a noteworthy effect on an area that BLM needs to 

evaluate

DRMTDK-BL13-0127-1

Travel Mngt

I specifically ask that the Big Sky trail and Bear Canyon Creek Trail be 

designated only for non-motorized use. In BLM's "preferred alternative" the 

beginning of both the Bear Canyon Creek Trail (0.5 mile) and the Big Sky Trail (1 

mile) are designated for motorized use. Walkers on these increasingly popular 

trails should not need to hike to the end of 4WD/ATV routes to get to quiet trails. 

(Many people do not have 4WDs or prefer to walk.)

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon and Big Sky routes, the RMP has a range of 

possible decisions. In this case, due to the conditions you mentioned the 

Alternative D has been modified to reflect the current conditions. The routes will 

be designated as “closed” to motorized use to the public but BLM will retain 

motorized access for administrative purposes

Refer to map 146

DRMTDK-BL13-0127-2

Travel Mngt

I ask that the Demijohn Flat route not be open to motorized use. This 1 Â1⁄2 mile 

route from Crooked Creek Road threatens a culturally sensitive area which is 

designated as both a National Register District, and an Area of Critical 

Environmental Concern (ACEC). Motorized use of this route fractures the Burnt 

Timber Canyon LWC* from the Burnt Timber Canyon WSA** and thus weakens 

both. The route is also a good non-motorized route with a trailhead accessible to 

people without 4WD vehicles.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

Refer to map 146

DRMTDK-BL13-0127-3

Travel Mngt

I ask that Bear Canyon be designated for only non-motorized use beyond the 

mouth of the canyon. BLM's preferred alternative authorizes motor vehicle use of 

Graham Trail up the southwest slope of Big Pryor Mountain. That makes three 

redundant parallel motor vehicle routes within less than three miles. (The other 

two are Bear Canyon and Stockman Trail.) One of the three routes should be 

designated for non-motorized use. Of the three routes Bear Canyon, through an 

Audubon Important Bird Area, would be the best non-motorized route. (There 

would still be abundant motorized access to Big Pryor Mountain with four more 

motor routes up the west slope, and two more nearby on the south slope.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed to motorized vehicles” except for administrative purposes

Refer to map 146

DR- Travel Mngt as I understand the current document, it is at least partially incomplete. The N Thank you for your comment. The route reports were and are available upon 
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MTDK-BL13-0129-1Billings and Pompeys Pillar National Monument DEIS did not contain individual 

route reports for motorized and multiple-use recreation closures when it was 

published. BLM sent out an e-mail notice on May 13, 2013 with a web site link to 

the detailed route information. However, when my staff attempted to follow this 

web site link, the Internet browser could not display the information. Attached to 

this letter is a screen shot of the browser's attempt to retrieve this information.

request. With regards to the incorrect link, as soon as that was identified the 

correct link was sent to the MTVRA. The route reports have been available online since May 2013.

DRMTDK-BL13-0129-2

Travel Mngt

I have serious concerns about the public's ability to access information that is 

vital to their ability to review the BLM's proposed decision because this travel 

information was provided nearly halfway through the public comment period. and 

because it appears to be inaccessible even after it was posted. The National 

Environmental Policy Act and its implementing regulations require an agency to 

provide the detailed information on its proposed decision to the public. It appears 

BLM has failed to meet that standard in this instance.

N

Thank you for your comment. The route reports were and are available upon 

request with regards to the incorrect link, as soon as that was identified the 

correct link was sent to the MTVRA. The route reports have been available online since May 2013.

DRMTDK-BL13-0129-3

Social/Econ

The third reason I request an extension is because I understand that a 

significant part of the BLM's plan is intended to protect sage grouse habitat and 

populations. While I support this goal, I fear the proposed plan is an 

unnecessarily onerous restriction upon oil and gas development, coal 

development, agricultural grazing and operations, multiple-use recreation, and 

other important public lands uses in this area. I believe there is a more effective 

way to protect sage grouse without drastically impacting Montana's major 

economic drivers in over one-third of the State. The area covered by this DEIS is 

one of the most important future economic development areas in Montana. BLM 

manages 3 million surface acres and 12 million sub-surface acres. In addition to 

that, the activity or restrictions on BLM land affects neighboring private, state 

and Tribal land. In short, a poorly-crafted or overly-broad BLM land use 

restriction can have the effect of shutting down resource development on 

neighboring lands owned by others, including the State of Montana. Eastern 

Montana has vast untapped oil, gas, coal, wind and other resource potential, and 

I believe the BLM restrictions proposed in the DEIS could have untold 

consequences for current and future generations of Montana workers and 

families.

n

Opinion: not text edits necessary. The DEIS describes the employment and 

income consequences of each alternative related to energy development on pg. 

4-605

DRMTDK-BL13-0129-4

Air

BLM's land planning efforts appear to be exceeding its authority in the arena of 

air quality. Under the Clean Air Act, the Environmental Protection Agency and 

the State work hand in hand to manage for clean air standards, with the State as 

the primary and preferred air quality management sovereign. As you may know, 

Montana and the EPA have recently completed an air quality plan for the State. 

The BLM's management under the DEIS appears to have been created in 

isolation from the EPA / Montana plan, and is in fact more restrictive than that 

plan. I urge you to examine this issue, and to allow all parties more time to 

evaluate this troubling proposal.

Y

The BLM recognizes the MDEQ’s lead role in air quality management within the 

state and provided a more robust explanation of the state program and of the 

BLM’s authority in Section 1.5 of Appendix T. Several of the provisions of the 

ARMP were developed in conjunction with the EPA and other Federal Land 

Managers under the Air Quality Oil and Gas Memorandum of Understanding 

(MOU, see the USDI 2011 entry in References). The BLM seeks to create a 

Memorandum of Understanding with the MDEQ that will enhance 

communication, reduce duplication of effort, and identify additional emission 

controls, if needed.

DR- NEPA I have serious concerns about the way the DES cooperated with numerous n Thank you for your comment. Please see Chapter 4 for the environmental 
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MTDK-BL13-0129-5Montana local governments, including county commissions and grazing districts, 

under the cooperating agency status provisions in federal law and regulations. 

As you are aware, land management documents like this must be consistent 

with local government resource plans. If they are inconsistent, the DEIS must 

disclose and discuss any inconsistencies with local plans and laws, and discuss 

how these inconsistencies will be reconciled. The DEIS must evaluate the 

environmental consequences resulting from its conflict with local resource plans. 

And perhaps most importantly for this document, the DEIS must evaluate and 

discuss the economic impact of its proposed action, and the impact of its 

inconsistency with local government resource plans. In this regard, numerous 

local governments have expressed to me that the DEIS did not evaluate their 

resource plans, did not evaluate inconsistencies with such plans, and did not 

adequately analyze the economic impacts of its restrictions compared to local 

government resource plans. These same concerned local government leaders 

also feel they were surprised by many of the provisions contained within the 

DEIS, which were contrary to what they had reviewed in their role as cooperating 

local government and agency representatives. I urge you to ensure BLM officials 

fully utilize the cooperating agency process in good faith, with full disclosure, and 

with respect to the role these local citizen representatives have under federal 

and state law.

consequences and Chapters 2 and 5 for discussions of inconsistencies 

between the Proposed RMP and county or local plans. The Billings and 

Pompeys Pillar National Monument RMP/EIS has 15 cooperating agencies 

involved in the B&PPNM RMP/EIS. Invitations were sent to 43 federal, tribal, 

state, and county agencies inviting them to participate as a cooperating agency. 

DRMTDK-BL13-0131-1

lands with 

wilderness 

characteristi

cs

I emplore you to consider strongly the wilderness characteristics by minimizing 

intrusion. Choosing to protect this land, Billings-Pompey's Pillar area would help 

secure the integrity of these unique prairie lands.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

DRMTDK-BL13-0135-

17

NEPA

Recognizing the need to protect both existing cutthroat populations and also 

restoration opportunities, the neighboring Butte Field office adopted a Â1⁄2 mile 

NSO in their RMP (2009) for streams suitable for cutthroat trout reintroductions. 

It should be noted that the BLM's Instruction Memorandum 2010-117 - Oil and 

Gas Leasing Reform -“ Land Use Planning and Lease Parcel Reviews, speaks 

to the need for stipulation consistency for like resources across planning areas 

boundaries. Specifically, IM 2010-117 states, " The IDCR Teams will work with 

the field offices within their state(s) and across state administrative boundaries to 

ensure lease stipulations edge-match appropriately across BLM administrative 

boundaries and other appropriate units such as a species range or an ecoregion.

N

Thank you for your comment. 

The BLM oil and gas stipulations are currently undergoing a consistency review 

between the field offices with RMP revisions underway. 

The BLM and BiFO recognize the importance of protecting cutthroat trout and 

habitat suitable for reintroductions. The BLM is required to adopt the least 

restrictive development stipulations that will satisfy the resource objectives. In 

this case, resource specialists believe the CSU will provide adequate 

protections to conserve suitable cutthroat trout habitat.

DRMTDK-BL13-0135-

17

Fisheries

Recognizing the need to protect both existing cutthroat populations and also 

restoration opportunities, the neighboring Butte Field office adopted a Â1⁄2 mile 

NSO in their RMP (2009) for streams suitable for cutthroat trout reintroductions. 

It should be noted that the BLM's Instruction Memorandum 2010-117 - Oil and 

Gas Leasing Reform -“ Land Use Planning and Lease Parcel Reviews, speaks 

N

Thank you for your comment. 

The BLM oil and gas stipulations are currently undergoing a consistency review 

between the field offices with RMP revisions underway. Thank you for your 

comment.
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to the need for stipulation consistency for like resources across planning areas 

boundaries. Specifically, IM 2010-117 states, " The IDCR Teams will work with 

the field offices within their state(s) and across state administrative boundaries to 

ensure lease stipulations edge-match appropriately across BLM administrative 

boundaries and other appropriate units such as a species range or an ecoregion.

The BLM and BiFO recognize the importance of protecting cutthroat trout and 

habitat suitable for reintroductions. The BLM is required to adopt the least 

restrictive development stipulations that will satisfy the resource objectives. In 

this case, resource specialists believe the CSU will provide adequate 

protections to conserve suitable cutthroat trout habitat.

DRMTDK-BL13-0135-

19

Fisheries

1⁄2 mile NSO buffer for Red Ribbon Streams As discussed, above, the MRIS is a 

ranking system used to quantify fisheries values. In the planning area, Red 

Ribbon (Class II) streams include Rosebud Creek including both the East and 

West forks, Rock Creek and the Yellowstone River downstream of the Blue 

Ribbon portion. While not as high of value as Blue Ribbon Streams, these are 

still very important fisheries that require protections in order to ensure that oil 

and gas development does not impair either the habitat or recreational values 

that are evaluated to determine stream classifications. Additionally, Rosebud 

Creek is the largest tributary to the Stillwater River, a Blue Ribbon Stream; 

protecting Rosebud Creek will help to ensure the integrity of the Stillwater River. 

For these reason's MTU urges the BLM to adopt a Â1⁄2 mile NSO buffer for Red 

Ribbon streams.

n

Thank you for your comment.

BLM has developed a range of alternatives, all of which protect wildlife 

resources to an acceptable degree. Alternative B protects Red Ribbon streams 

with the 1⁄2 mile NSO stipulation.

In Alternative D, the preferred alternative, those streams labeled as red ribbon 

would be protected with a 300 foot CSU stipulation. This stipulation requires the 

developer to submit a plan that will ensure there are no unacceptable impacts 

to resources of concern (fish, water, etc). The BLM does not see this stipulation 

as sacrificing any resource integrity, regardless of the class of stream. For this 

reason, only the highest resource values were afforded the 1⁄2 mile buffer to 

ensure protections beyond the normal, because the resources are beyond the 

normal for the analysis area.

The BLM is required to adopt the least restrictive development stipulations that 

will satisfy the resource objectives. The 300 foot CSU is more protective than 

current management, which has not led to any impacts from oil and gas 

development that have degraded red ribbon fisheries.

DRMTDK-BL13-0135-

20

Fisheries 

 Montana Fish Wildlife and Parks concurrence needed for stipulation 

exceptions, modifications or waivers. MTU is concerned with the exceptions, 

modifications or waivers (EMW) language that is included in resource 

stipulations; specifically, MTU feels that not just consultation with Montana Fish 

Wildlife and Parks (FWP) needs to occur, but that there needs to be concurrence 

with Montana FWP biologists before a stipulation for fisheries or wildlife 

protection is waived, modified or excepted. For example, as written the Â1⁄2 mile 

buffer for YCT conservation populations may be waived "if the authorized officer 

determines that the entire leasehold can be occupied without adversely affecting 

Yellowstone cutthroat trout populations and Yellowstone cutthroat trout habitat." 

(Appendix C-181) At Appendix H-22, the proposed RMP specifies that 

exceptions and waivers require FWP "consultation" but not concurrence. More 

concerning is that lease modifications (e.g. shrinking and NSO buffer from Â1⁄2 

mile to Â1⁄4 mile) does not require any consultation with FWP. Given that BLM is 

the land manager, but throughout the DEIS states that FWP manages the 

n

Thank you for your comment. To clarify, MT FWP manages the wildlife, the 

actual populations and individual animals. On BLM managed public lands, the 

BLM manages the habitat. 

The BLM will review WEM applications and determine what impacts would 

affect given resources and whether those impacts are acceptable. This would 

be part of the NEPA process and MTFWP can provide input during the NEPA 

process.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-94 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

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Document 

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BLM Response to Comment

resources, it is imperative that the agency responsible for managing the 

resource concur with any determination that a lease exception, modification, or 

waiver will not adversely affect that resource.

DRMTDK-BL13-0135-

21

Fisheries

 Impacts analysis needs to consider both sedimentation and spills The impacts 

analysis only considers the effects of sedimentation, see 4-303: "These NSO 

stipulations and consistent surface disturbing management actions would protect 

fisheries resources by minimizing potential habitat degradation resulting from 

surface disturbance; erosion and sedimentation, weed infestation, direct habitat 

alteration." While this is true, it is important to note that there are two potential 

sources of impacts from oil and gas development, 1) surface disturbances and 

associated erosion and sedimentation, and 2) contamination from spills and 

other accidental releases of chemicals and wastes associated with drilling and 

production and activities. Any development within the watershed of a fish 

bearing stream introduces the risk of a spill and the resultant impacts to aquatic 

habitat and fisheries; these impacts can range from minimal to catastrophic 

depending on the severity or a given spill. These impacts need to be analyzed 

and a risk assessment provided in the EIS. Moreover, the dual nature of oil and 

gas impacts emphasize the need for 1⁄2 mile NSO buffers for sensitive coldwater 

fisheries -“ the greater the spatial separation between oil and gas development 

and surface waters, the less chance that a spill will reach and impact a given 

water body. Elsewhere, land management agencies have recognized that spills 

are a reality in oil gas development, even with environmental protection 

measures. The Dixie National Forest's Oil and Gas Leasing EIS (2010) stated: 

There is at least some indefinable probability that spills or failures in 

environmental protection measures could occur, with consequent impacts to 

water resources ranging from negligible to major. The history of oil and gas 

activities throughout the country indicates that even though improvements have 

been made in procedures, chemicals used, and environmental protection; 

unforeseen spills, ruptures, and leaks, can occur. The recent track record of oil 

and gas companies may be quite good, but it is not perfect -“ nor can it be 

expected to be perfect in the future. Moreover, spills have been shown to travel 

up to a mile1 before reaching surface waters. Given that there is no way to 

completely abate the risk of a spill, the fact that a single incident could wipe out a 

population of trout, it is important to include this in the impacts analysis.

n

Thank you for the comment. 

The sentence you reference does not “only consider the effects of 

sedimentation” it continues to consider the effects of “weed infestation and 

direct habitat alteration”. The addition of oil or chemicals to the water would 

qualify as a direct habitat alteration. It is understood that Trout Unlimited would 

push for the highest levels of protection possible on fish bearing streams, 

particularly streams with high value fisheries or rare populations, however the 

BLM manages the public lands for multiple use and tries to meet resource 

objectives with the least restrictive stipulations. In the Billings Field Office, there 

have been no instances of high value fisheries or rare fish populations, such as 

the Yellowstone Cutthroat trout, being degraded as a result of oil and gas 

development activities. In fact, only one stream is listed on the MT DEQ 

impaired waters list with Oil and Gas development as a causal factor, and this 

stream is composed of produced waters (Silvertip Creek in Carbon county).

The stipulations and mitigation measures required by the BLM to develop 

federal minerals will be more restrictive than past measures, which have been 

successful in protecting the resources you are very passionate about.

The BLM uses a range of setbacks associated with water and riparian 

resources of differing value. As sensitive species or habitats are added to or are 

proximate to a common waterbody, the setback tends to increase and more 

BMPs are recommended, however, even the lowest levels of protections have 

succeeded in protecting YCT and other sensitive species from adverse impacts 

caused by oil and gas development.

DRMTDK-BL13-0135-

23

Fisheries

 Impacts analysis should consider the cumulative effects of climate change At 4-

290, the draft EIS states that "Local climate patterns of historic record and 

related conditions for plant growth would continue during the analysis period." 

We feel that it is important to not assume impacts based upon historic climate 

patterns, but rather to base impacts on climate patterns predicted by the best 

available climate change modeling. Increasing periods of drought, winter 

flooding, increased severity and occurrence of wildfire, and increasing summer 

n

Thank you for this comment. Chapter 2 Climate Change states "Adapting 

management, to reflect emerging science, projections, and impacts of climate 

change, allows the BLM to adjust management to best meet the challenges of 

climate change and is useful for complex processes and where potential 

impacts are large and could affect multiple resources. Adaptive management 

strategies are iterative processes where monitoring and assessment refine 

management. This document is based on current scientific knowledge and 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-95

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

temperatures are all compounding factors associated with climate change that 

will exacerbate aquatic habitat impacts associated with land use activities. 

Reducing the effects of land use activities (e.g. applying a 1⁄2 mile NSO setback 

versus a 1⁄4 mile NSO set-back) will help to offset the effects of climate change 

by increasing the resiliency of watersheds that support coldwater fisheries. 

Conversely, management decisions that result in a higher degree of impacts will 

intensify the effects of climate change, especially on coldwater fisheries. TU 

completed a coarse scale analysis (Haak et al. 2010) 2 that analyzed four risk 

factors with direct implications for coldwater fisheries: summer temperature, 

persistent drought, increased wildfire, and increased winter flooding. Our 

assessment used a 3°C increase in air temperature, which is consistent with 

higher end Global Climate Model projections for the western United States by 

2050 (Climate Impacts Group, 2004), to determine the risk to trout populations. 

The results were summarized by species (including Yellowstone cutthroat trout) 

and analyzed to determine the likelihood of population persistence based on 

information drawn from the literature on relationships between persistence and 

fish abundance, habitat connectivity and patch size for each taxon. The results 

of this analysis were combined with the results of the coarse filter evaluation to 

provide a spatially explicit characterization of extirpation risk to native trout 

populations. Applying this kind of modeling to the Billings Resource Area would 

allow the BLM to scientifically analyze the effects of climate change on coldwater 

fisheries, as well as the cumulative effects that would result from additional 

stressors on the environment caused by land use activities authorized by the 

BLM. If the planning team has any questions or would like more information 

about TU's climate change assessment and modeling, please contact us.

understanding, which in the case of climate change, is still emerging. Adaptive 

management provides for new information to be evaluated and incorporated 

into project level management decisions, BMPs, mitigation and the decisionmaking process."

DRMTDK-BL13-0135-

24

Fisheries

Update references to the Cutthroat Agreement At 1.5.2, the DEIS lists the 

Conservation Agreement for Yellowstone Cutthroat Trout (1999) under State 

Plans; the more current Memorandum of Understanding and Conservation 

Agreement for West slope Cutthroat Trout and Yellowstone Cutthroat Trout in 

Montana (2007) incorporates and updates the 1999 Conservation Agreement 

and should replace the 1999 agreement in this section. Additionally at 3.5.8.3, 

the Affected Environment discussion should incorporate the Cutthroat 

Agreement by discussing the BLM's commitments as a signatory and also 

include the goal and objectives of the MOU and agreement. Doing so will 

provide context and rational for the stipulations developed to protect both 

existing YCT populations and streams suitable for YCT reintroductions.

n

Thank you, we will update the citing of the newest memorandum. 

The memorandum is referenced. 

On pages 2-80 and 2-81 the BLM incorporates key conservation actions from 

the YCT Conservation strategy directly into management actions common to all 

alternatives for fisheries management.

DRMTDK-BL13-0137-1

Travel Mngt

the identification of "wildlife viewing" as the non-motorized use of interest in 

Appendix O does not account for the great variety of non-motorized uses. The 

document should be thoroughly edited to avoid this bias and to fully recognize 

non-motorized uses as having equal footing with motorized uses.

y

Please refer to Appendix 0-157, Specific Recreation Activities. 

In response to your comment, please refer to “text changes” for Appendix O 

changes

DR- Travel Mngt With regard to Bear Canyon Road in the Pryors, please designate the "washed- n In regards to your comment, the RMP has a range of possible decisions. In this 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-96 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

MTDK-BL13-0137-2out" section of the road (north of section 3, PMI070) as non-motorized. Given 

the work it would take to re-open the route for safe passage, and given the lack 

of designated nonmotorized routes, it is a perfect route for this designation.

case, due to the conditions you mentioned the Alternative D has been modified 

to reflect the current conditions. The route will be designated as “closed”

Refer to map 146

DRMTDK-BL13-0137-3

Travel Mngt

With regards to "Big Sky Trail" (N-S through the center of section 2, T9S R26E 

from Horse Haven Rd to the Custer NF boundary fence), please designate this Imile stretch as non-motorized. It is currently signed "closed to motor vehicles" 

and there is a barricade. As the beginning of an increasingly popular hiking route 

it is a perfect candidate for the non-motorized designation.

n

In regards to your comment, the RMP has a range of possible decisions to 

make. In this case, the Alternative D decision is for it to remain as “closed”. 

Refer to map 146

The RMP will be changed to reflect that the decision is to designate it as a nonmotorized trail. 

DRMTDK-BL13-0140-1

Coal

Contained within this Basin is the Fort Union Geologic Formation extending from 

Wyoming into Montana. The Montana portion of the basin contains proven 

underground coal fields in the Red Lodge, Bear Creek & Grove Creek areas. 

Scant mention or discussion of these private resources is mentioned in the plan.

N

The text describing the coal development potential of the Red Lodge-Bearcreek 

coalfield has been enhanced in the Chapter 2, Solid Minerals-Coal section.

DRMTDK-BL13-0140-2

Oil and Gas

In review of the BLM - RMP as proposed, it is clear your agency is not 

adequately considering the economic impact of the decision in any of the 

alternatives presented in the plan. For over 80+ years many companies have 

leased oil/gas mineral rights in this area, several have drilled deep test holes. 

Area oil/gas leasing on BLM would be abolished or severely restricted by this 

plan with direct effect on adjacent taxable lands which would be closed to 

leasing. This action would result in $0 income for the BLM and ultimately the 

general population in the United States.

n thank you for your comment.

DRMTDK-BL13-0140-3

NEPA

The CEQ has directed agencies to gather data from reliable sources such as 

interviews and information from local residents which the BLM has failed to do. 

You did hold the open meetings, but refused to allow public comment at those 

meetings. How can they be considered public meetings if no public discussions 

are allowed? I suggest you reschedule the meetings and allow them to be public 

meetings as required.

N Thank you for your comment. Non substantive

DRMTDK-BL13-0140-4

Coal

Township 8 and 9 South, Range 20 and 21 East, the area of our greatest 

concern is included on the map from plan appendix M Figure M-3. As one of the 

many coal owners of coal owned in fee that covers approximately 12,000 acres 

plus; we are primarily concerned with maintaining the value of our mineral rights 

in the area known as the Bearcreek Coal area and Grove Creek area located 

near Bear Creek, MT.

N Thank you for your comment.

DRMTDK-BL13-0140-5

Social/econ

The coal mine(s) would produce significant economic impact amounting to 100's 

of millions of dollars for Carbon County, the State of Montana and the nation by 

creating well-paying jobs for hundreds of miners and related personnel.

N

Thank you for your comment. When we receive a plan of development for this 

project it will be analyzed. 

DRMTDK-BL13-0140-6

Travel Mngt

Service roads are necessary to operate these production platforms. These roads 

can be situated to by-pass cultural sites or bird nesting areas without affecting 

the whole area. Should oil/gas be produced, a pipeline may need to be built to 

the east across multiple ownerships (including BLM) to connect with existing 

pipelines. Economic coal transport from these mines could require construction 

of a railroad line of approximately 25 miles in length to the east, connecting with 

n

Thank you for your concerns and your comments. BLM staff have reviewed 

their program files and determined that your company already has an existing 

ROW for access, which would not be affected by management decisions in this 

RMP. In regards to the Rail line ROW which is requested to be addressed in 

the RMP, issuance of ROWs is a routine operation for BLM and issuance of a 

specific ROW for a Rail line, a pipeline, or any other access needs would not be 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-97

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

the existing BNSF Bridger-Lovell mainline. Obviously, this line would by 

necessity cross multiple surface ownerships including BLM. But with this EIS, 

BLM proposes to close many existing roads or trails and to eliminate new roads. 

A railroad line is not considered or mentioned in the report. I was told that in 

discussions at the public meetings last month, you indicated we "could apply for 

a permit for access." We request that a provision for such a permit be included in 

this EIS. Such a provision is not included in your proposals.

within the scope of this plan. BLM staff is available to meet and discuss this 

proposal with you; simply contact the office. 

DRMTDK-BL13-0141-1WILD 

HORSES,

PMWHR

I would like to see the first bulleted paragraph from Alternative D, which reads: 

Manage wild horses on approximately 27,094 acres of BLM-administered lands 

(39,994 acres all ownerships). Designate the closed portions of the Herd Area 

known as the administrative pastures to be included in the Herd Management 

Area. Due to private property conflicts, the "buffer" area would remain closed

N Thank you for your comment

DRMTDK-BL13-0141-2WILD 

HORSES,

PMWHR

Replaced with the first bulleted paragraph from Alternative C, which states: 

Manage wild horses on approximately 28,622 acres of BLM-administered lands 

(44,855 acres all ownerships). the entire Herd Area as the Herd Management 

Area

N

Thank you for your comment, alternative C analyzes the alternative that you are 

in support of.

DRMTDK-BL13-0141-3WILD 

HORSES,

PMWHR

I recommend this change to Alternative D for the following reasons: By adding 

this land (see map 33 Alternative C) to the WHR and HMA there can be a higher 

AML which in effect will reduce the need for gather/removals, and add to the 

genetic diversity (higher AML) of the herd. I am confident that the current pzp 

plan will now be having a significant effect on the herd. I am also in full support 

for range expansion. By opening up the "Sorenson Extension" visitors to the Big 

Horn Canyon National Recreation Area would be able to view more of the wild 

horses.

N

Thank you for your comment. Please refer to chapter two alternatives C and D 

as what is being called the buffer; it is not the administrative pasture, but rather 

the area between the county road and the external boundary fence.

DRMTDK-BL13-0141-4WILD 

HORSES,

PMWHR

I support the second bulleted paragraph from Alternative D, which states: Same 

as Alternative A - Within an HMAP, herd structure would be managed for all 

representation in the herd, not allowing specific colors or bloodlines to dominate 

from management manipulation. However, I recommend that a close eye be 

kept on the herd so as to not lose the old bloodlines from years ago that are still 

represented on the PMWHR. Allowing these horses to remain on the range and 

reproduce will ensure that these bloodlines will be carried over for years to 

come. I appreciate the Billings Field Office's efforts in the past for conserving 

these older bloodlines that exhibit evidence of their Spanish heritage

N Thank you for your comment

DRMTDK-BL13-0146-1

Travel Mngt . I request that non-motorized routes be designated at the same time as 

motorized routes are designated in the final RMP y

In regards to your comment, BLM Manual 1626 (Travel and Transportation) 

specifies that BLM establish a comprehensive program for both motorized and 

non-motorized travel. This will be done in this RMP.

In regards to your comment, please see “text changes” for changes to Appendix 

O and the Travel Management Sections in chapters 1, 2, 3, and 4.

DRMTDK-BLTravel Mngt I request that the Big Sky trail and Bear Canyon Creek Trail be designated only 

for non-motorized use. y

In regards to your comment, the RMP has a range of possible decisions to 

make. In this case, the Alternative D decision is for it to remain as “closed”. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-98 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

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Document 

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BLM Response to Comment

13-0146-2 Please see map 146

Also note that BLM Manual 1626 (Travel and Transportation) specifies that 

BLM establish a comprehensive program for both motorized and non-motorized 

travel. This will be done in this RMP. This trail will be designated as a nomotorized trail. 

DRMTDK-BL13-0146-3

Travel Mngt I request the Demijohn Flat route not be open to motorized use n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

DRMTDK-BL13-0146-4

Travel Mngt I request that Bear Canyon be designated for only non-motorized use beyond 

the mouth of the canyon. n

In regards to your comment, the RMP has a range of possible decisions. In this 

case, due to the conditions you mentioned the Alternative D has been modified 

to reflect the current conditions. The route will be designated as “closed” to 

motorized vehicles and as a non-motorized trail

Refer to map 146

DRMTDK-BL13-0151-1

Travel Mngt

I am asking that the first mile of the trail from the barricade off of Horse Haven 

up to the USFS fence remain a section used for non-motorized enjoyment. I am 

also asking that the 1/2 mile between the barricade to the USFS fence in Bear 

Canyon remain non-motorized.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

The decision on management for this specific route is manage it as a nonmotorized trail except for agency administrative purposes. Refer to map 

146Thank you for your concern and your comments. The Trail from Horse 

Haven Road and the Bear Canyon Trail in question will be closed to motorized 

vehicles and designated as non-motorized hiking trails. 

DRMTDK-BL13-0151-2

Travel Mngt

It also my understanding that Graham Trail and Stockman Trail are being 

proposed to be open to motorized use. This makes no sense as this will make 

three parallel motorized trails a short distance from one another. Having these 

designated as non-motorized will help preserve the Audubon Important Bird 

Area as well as the riparian habitat in Bear Canyon. It is my fear that if Bear 

Canyon is open to motorized use it will tear the riparian area up into a giant mud 

hole.

y

In regards to your comment, BLM Manual 1626 (Travel and Transportation) 

specifies that BLM establish a comprehensive program for both motorized and 

non-motorized travel. This will be done in this RMP.

In regards to your comment, please see changes to Appendix O and the Travel 

Management Sections in chapters 1, 2, 3, and 4.

The management decision is to leave the Graham Canyon route open for 

consistency with the adjacent FS Travel designations, while the Bear Canyon 

Route is closed and designated as a non-motorized trail. 

Thank you for your concerns and comments. The decision for the Graham 

Canyon Trail and Stockman Trail are to be designated as “open: so to be 

consistent with the adjacent FS route designation and to provide access to for 

range and mineral operators. 

DRMTDK-BL13-0158-1

Oil and Gas

Proceeding with oil, gas, and/or coal leasing and development -“ such as the 

October 2013 oil and gas lease sale -“ is impermissible due to the inherent 

prejudice that any such action would create on the pending revision of the BiFO 

n

Thank you for your comment. With regards to the 2013 Oil and Gas lease sale, 

only those parcels with no resource concerns were offered for sale. Parcels 

containing resources (i.e. sage-grouse habitat, fisheries habitat, etc.) on which 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-99

Comment 

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DRMP. See id. Without the foundational land use planning guidance that is only 

available through a current and up-to-date RMP, it would be impossible for the 

BiFO to make the type of fully informed decision that NEPA requires prior to 

completion of the BiFO RMP revision. BLM must acknowledge this reality -“ that 

the existing RMP cannot be used to guide current oil and gas leasing and 

development decision making -“ and announce a moratorium on all oil and gas 

activity pending the completion of the BiFO RMP revision.

management of those resources would be modified through the RMP process 

were deferred until after the ROD is signed.

DRMTDK-BL13-0158-

10

Climate

We reject any notion that the emissions from specific activities in the BiFO 

DRMP are so small as to warrant a dismissive analysis. The reality of climate 

change is that it is caused by myriad, specific sources of GHG pollution. For 

BLM, here, to disavow itself of responsibility for these specific emissions is to 

condemn us to unabated GHG emissions.

N

See the global warming potential discussion in Section 3.2.2.4 indicating that 

GHG emissions are being assessed and controlled by oil and gas operators 

and by multiple agencies.

DRMTDK-BL13-0158-

11

Air

To suggest that the agency does not, here, have to account for GHG pollution 

from activity authorized by the BiFO DRMP, is to suggest that the collective 700 

million acres of subsurface mineral estate is not relevant to protecting against 

climate change. This sort of flawed, reductive thinking is problematic, and 

contradicted by the agency's very management framework that provides a placebased lens to account for specific pollution sources to ensure that the broader 

public interest is protected. In fact, the climate mitigation opportunity for methane 

leaking and vented from oil and gas activity on federal lands is significant. 

Therefore, even though climate change emissions from the Alternatives may 

look minor when viewed in isolation, when considered cumulatively with all of the 

other methane emissions from BLM-managed land they become significant and 

cannot be ignored.

Y

MDEQ regulates many of these sources, as described in Section 1.5.2 of 

Appendix T. Several types of emission sources mentioned by the commenter 

do not contribute to actual GHG emissions reported by oil and gas operators 

under the EPA Greenhouse Gas Mandatory Reporting Rule (40 CFR Part 98, 

Subpart W) or contribute very small amounts, as discussed in Section 3.2.2.4.4.

DRMTDK-BL13-0158-

12

Air

The NSPS rules do not cover significant existing sources, such as pneumatic 

devices or storage tanks. They do not cover completions and recompletions for 

conventional (non-fracked) wells, or well deliquification (well clean-up, most 

commonly with plunger lifts). They also do not cover portable or smaller 

desiccant dehydrators, well-site compressors, pipeline maintenance and repair 

programs, or leak monitoring and repair programs. There is no justification for 

assuming that future federal GHG regulations will provide the necessary 

mitigation for the methane emissions estimated to result from the Alternatives 

and their contribution to the negative impacts of climate change. Rather, the 

Draft DRMP must look to actions the BiFO can take as part of this plan to 

minimize methane emissions.

Y

GHG emissions from oil and gas sources within the planning area are very low 

and are expected to remain low with maximum development of four wells per 

year. No oil and gas production companies had sufficient GHG emissions to 

require reporting under the EPA Greenhouse Gas Mandatory Reporting Rule 

(40 CFR Part 98, Subpart W) for year 2012, as summarized in Section 

3.2.2.4.4. Section B.1 of Appendix B summarizes BLM BMPs to reduce GHG 

emissions.

DRMTDK-BL13-0158-

13

Air

The practical applications of BLM's GHG pollution mandate are manifest through 

the GHG emissions and methane waste that will result from oil and gas 

development authorized by the BiFO RMP. To this end, BLM certainly does not 

provide any consideration of the relationship between GHG emissions and the 

RMP decision made, and fails to address or identify any alternatives or 

mitigation of GHG emissions from oil and gas development in the BiFO DRMP. 

N

SO 3226, NEPA, and FLPMA require the BLM to assess GHG emissions and 

impacts. GHG emissions from oil and gas sources within the planning area are 

very low and are expected to remain low with maximum development of four 

wells per year. No oil and gas production companies had sufficient GHG 

emissions to require reporting under the EPA Greenhouse Gas Mandatory 

Reporting Rule (40 CFR Part 98, Subpart W) for year 2012, as summarized in 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-100 Chapter 5: Consultation and Coordination

Comment 

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This failure is in direct conflict with SO 3226 as well as BLM's mandate under 

NEPA, FLPMA, and the MLA.

Section 3.2.2.4.4. Section B.1 of Appendix B summarizes BLM BMPs to reduce 

GHG emissions.

DRMTDK-BL13-0158-

14

Air

Indeed, a recent Report released by the Natural Resources Defense Council 

identified that "[c]apturing currently wasted methane for sale could reduce 

pollution, enhance air quality, improve human health, conserve energy 

resources, and bring in more than $2 billion of additional revenue each year."20 

Moreover, the Report further identified ten technically proven, commercially 

available, and profitable methane emission control technologies that together 

can capture more than 80 percent of the methane currently going to waste. Id. 

Such technologies must also be considered in BLM's alternatives analysis, 

discussed infra.

N

Thank you for your comment. Methane reduction is discussed in Section 

3.2.2.4.4 of the RMP, in Section 1.5.2 of Appendix T, and in Section B.1 of 

Appendix B.

DRMTDK-BL13-0158-

15

Oil and Gas 

As GAO has found, BLM's current waste prevention policies, originally created in 

1980, are outdated. That BLM intends to revise its policies does not excuse its 

failures relative to the specific actions proposed by BLM in this DRMP. This is a 

fatal deficiency.

n Thank you for your comment.

DRMTDK-BL13-0158-

16

Oil and Gas

Considering alternatives to prevent or abate these emissions, in 

particular through enforceable stipulations required in the RMP to attach to 

subsequent oil and gas leases, as detailed below, is therefore reasonable and 

prudent.

n Thank you for your comment.

DRMTDK-BL13-0158-

17

Climate

Oil and natural gas systems are the biggest contributor to methane emissions in 

the United States, accounting for over one quarter of all methane emissions.22 

In light of serious controversy and uncertainties regarding GHG pollution from oil 

and gas development, BLM's quantitative assessment should account for 

methane's long-term (100-year) global warming impact and, also, methane's 

short-term (20-year) warming impact using the latest peer-reviewed science to 

ensure that potentially significant impacts are not underestimated or ignored. 

See 40 C.F.R. § 1508.27(a) (requiring consideration of "[b]oth short- and longterm effects").

Y See the global warming potential discussion in Section 3.2.2.4. 

DRMTDK-BL13-0158-

18

Climate

EPA's GHG Inventory -“ which BLM currently relies on in its analysis -“ assumes 

that methane is 21 times as potent as carbon dioxide ("CO2") over a 100-year 

time horizon,23 a global warming potential ("GWP") based on the 

Intergovernmental Panel on Climate Change's ("IPCC") Second Assessment 

Report from 1996.24 As a Supplementary Information Report ("SIR") prepared 

for BLM's oil and gas leasing program in Montana and the Dakotas explains, 

GWP "accounts for the intensity of each GHG's heat trapping effect and its 

longevity in the atmosphere" and "provides a method to quantify the cumulative 

effect of multiple GHGs released into the atmosphere by calculating carbon 

dioxide equivalent (CO2e) for the GHGs." SIR at 1-2.25 However, substantial 

questions arise when you calibrate methane's GWP over the 20-year planning 

and environmental review horizon used in the SIR and, typically, by BLM, 

including the BiFO. See SIR at 4-1 thru 4-4 (discussing BLM-derived reasonably 

Y

See the global warming potential discussion in Section 3.2.2.4. The range of 

methane contribution to CO2e using a GWP from 21 to 105 is 3 percent to 14 

percent. 
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foreseeable development potential in each planning area). Over this 20-year 

time period, the IPCC has calculated that methane's GWP is 72 -“ over three 

times as potent as otherwise assumed by the SIR.26 23 See 78 . 19802, April 2, 

2013 (EPA proposal to increase methane's GWP to 25 times CO2). 24 

INTERGOVERNMENTAL PANEL ON CLIMATE CHANGE, Second Assessment 

Report (1996) (attached as Exhibit 48); see also U.S. Environmental Protection 

Agency, Methane, available at: http://www.epa.gov/outreach/scientific.html (last 

visited Dec. 20, 2011). 25 BLM, Climate Change, Supplementary Information 

Report, Montana, North Dakota and South Dakota (2010) available at: 

www.blm.gov/mt/st/en/prog/energy/oil_and_gas/leasing/leasingEAs.html (last 

visited Dec. 20, 2011) (attached as Exhibit 49).26 See INTERGOVERNMENTAL 

PANEL ON CLIMATE CHANGE, Fourth Assessment Report, Working Group 1, 

Contribution of Working Group I to the Fourth Assessment Report of the 

Intergovernmental Panel on Climate Change, Ch. 2, p. 212, Table 2.14, 

available at: www.ipcc.ch/publications_and_data/ar4/wg1/en/ch2s2-10-2.html 

(attached as Exhibit 50). However, recent peer-reviewed science demonstrates 

that gas-aerosol interactions amplify methane's impact such that methane is 

actually 33 times as potent as carbon dioxide over a 100-year time period, and 

105 times as potent over a twenty year time period.27 This information suggests 

that the near-term impacts of methane emissions have been significantly 

underestimated. See 40 C.F.R. § 1508.27(a) (requiring consideration of short 

and long term effects). Further, by extension, BLM is also significantly 

underestimating the near-term benefits of keeping methane emissions out of the 

atmosphere. 40 C.F.R.§§ 1502.16(e), (f); id. at 1508.27. These estimates are 

important given the noted importance of near term action to ameliorate climate 

change -“ near term action that scientists say should focus, inter alia, on 

preventing the emission of short-lived but potent GHGs like methane while, at 

the same time, stemming the ongoing increase in the concentration of carbon 

dioxide.28 These uncertainties -“ which BLM has left unaddressed in prior NEPA 

analysis -“ necessitate analysis in the BiFO DRMP. 40 C.F.R. §§ 1508.27(a), 

(b)(4)-(5).

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19

Climate

While dispersed, oil and gas development is nonetheless a massive, landscape 

scale industrial operation -“ one that just happens to not have a single roof. BLM, 

as the agency charged with oversight of onshore oil and gas development, 

therefore has an opportunity to improve our knowledge base regarding GHG 

emissions from oil and gas production, providing some measure of clarity to this 

important issue by taking the requisite "hard look" NEPA analysis before selling 

and executing oil and gas leases.36Â 36 In this context, the 2010 SIR, while 

providing a basic literature review of GHG emissions sources, is merely a 

starting point for BLM's responsibility to take a hard look at GHG emissions in 

the context of foreseeable drilling operations in the geologic formations proposed 

y

GHG emissions from oil and gas sources within the planning area are very low 

and are expected to remain low with maximum development of four wells per 

year. No oil and gas production companies had sufficient GHG emissions to 

require reporting under the EPA Greenhouse Gas Mandatory Reporting Rule 

(40 CFR Part 98, Subpart W) for year 2012, as summarized in Section 

3.2.2.4.4. Section B.1 of Appendix B summarizes BLM BMPs to reduce GHG 

emissions.
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for leasing.

DRMTDK-BL13-0158-2

Air

Research indicates a strong correlation between oil and gas development and 

increased ozone concentrations -“ particularly in the summer when warm, 

stagnant conditions yield an increase in O3 from oil and gas emissions. Marco A 

Rodriguez, et al., Regional Impacts of Oil and Gas Development on Ozone 

Formation in the Western United States, JOURNAL OF AIR & WASTE 

MANAGEMENT ASSOCIATION (Sept. 2009) (attached as Exhibit 111). 

Particularly in areas of significant existing oil and gas development -“ such as the 

area researched by Rodriguez, the San Juan Basin in the Four Corners region, 

but also relevant, here -“ "peak incremental O3 concentration of 10 ppb" have 

been simulated. Id. at 1118. This study indicates a "clear potential for oil and gas 

development to negatively affect regional O3 concentrations in the western 

United States, including several treasured national parks and wilderness areas 

in the Four Corners region. It is likely that accelerated energy development in 

this part of the country will worsen the existing problem." Id. Although these 

findings are based on a case study in the Four Corners region, the applicability 

of this research is far broader and should be considered by BiFO, here.

N

As discussed in Sections 3.2.1.3 and 3.2.1.7, ambient air quality data from 

ozone monitors near the planning area indicate ozone concentrations that are 

no more than 75 percent of the ozone NAAQS. The ARMP in Appendix T 

provides a process to manage ozone impacts from future growth in oil and gas 

activity.

DRMTDK-BL13-0158-

20

NEPA

The myriad impacts that will result from the BiFO RMP decision making must be 

considered within the context of resiliency. Although the BiFO DRMP recognizes 

the threat of climate change, the agency's decision making is not reflective of 

this harm and fails to take any steps to ameliorate the impacts to communities, 

landscapes, and species. To the contrary, the BiFO DRMP's preferred 

alternative would open up extensive lands to oil and gas leasing.

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS. Please see Tables 2-5 and 2-6.2 and Appendix C for the restrictions 

placed on oil and gas leasing. 

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21

Water

The BiFO does not even address the environmental impacts from hydraulic 

fracturing in the DRMP. The BiFO implies that hydraulic fracturing may occur, 

explaining that horizontal wells "are drilled to increase the recovery oil and gas 

reserves from vertically fractured reservoirs, or reservoirs with directional 

permeability." DRMP at D-9. Otherwise the BiFO makes no mention of hydraulic 

fracturing. As discussed in more detail below, fracking may create seismic risks, 

and negatively impact water quality and quantity, air quality, wildlife, and human 

health. Yet, the agency's decision making is not reflective of this potential harm, 

and fails to sufficiently analyze impacts, providing, only, that "[b]est management 

practices, state, and federal guidance concentrate on protecting water quality." 

Id. at 3-39; see also Center for Biological Diversity v. Bureau of Land 

Management, No. C 11-006174 PSG (N.D. Cal. 2011), Doc. No. 45 (Order 

concluding that NEPA review was inadequate and specifically referenced BLM's 

failure to adequately analyze groundwater contamination impacts). Given the 

weight of both new and old evidence documenting the risk of water 

contamination from gas drilling across the country, BLM's approach is becoming 

increasingly untenable, in particular given the absence of any scientific analysis 

n

Thank you for your comment. There is no fracking currently occurring in the 

Billings Field Office and it is unlikely to occur. Language has been added to 

Chapter 3 to address your concerns. The RFD for the B&PPNM plan revision is 

4 wells per year occurring on BLM managed federal mineral estate per year. 

There are no high potential oil and gas development areas occurring in the 

federal mineral estate. Full-scale would be four wells per year. 
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that conclusively finds that these documented problems do not exist in the area 

of the proposed lease sale. Indeed, even an industry report prepared for 

Gunnison Energy Corporation -“ a major oil and gas developer -“ has 

acknowledged the potential for significant impacts to water resources from 

fracking.72 The simple fact of the matter is that natural gas development has the 

potential for poisoning our water with toxic, hazardous, and carcinogenic 

chemicals as well as naturally occurring radioactive radium, and BLM must 

provide a thorough analysis of these potentially significant impacts in the BiFO 

DRMP. Here, BLM has failed to provide this hard look analysis.

DRMTDK-BL13-0158-

22

Oil and Gas 

In preparing its NEPA analysis for the BiFO DRMP, BLM must catalogue the 

substances that will be used or are reasonably likely to be used in fracking on 

the parcels made available in the RMP. In order to make this information 

accessible to the public, BLM should categorize these substances as hazardous, 

toxic, carcinogenic, or benign.

n Thank you for your comment.

DRMTDK-BL13-0158-

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Oil and Gas

The threat of seismic activity induced from oil and gas development practices 

must be considered in the BiFO DRMP. Here, the BiFO provides no analysis of 

seismic hazards. This dismissive approach is inadequate. As noted above, Ohio 

officials placed a five-mile buffer around waste injection wells. Given the 

recognized correlation between oil and gas development practices and the 

inducement of earthquakes, taking such a precautionary approach, here, 

through stipulations at the RMP stage is prudent and would help stem potential 

future impacts. At the very least, however, BLM must take a hard look at 

possible seismicity impacts in the planning area.

n

Thank you for your comment. However, while noting that, while rare, 

[g]ecologic hazards within eastern Montana consist primarily of threats from 

earthquakes,• Draft EIS at 3-124, and that [s]eismic surveys are a critical part of 

exploration for oil and gas resources,•

DRMTDK-BL13-0158-

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Oil and Gas

emissions from oil and gas development are not limited only to combustion, 

rather they occur throughout the chain of production -“ with some of the greatest 

emissions occurring at the point of extraction. These impacts are a consequence 

of various stages of oil and gas development -“ from the drilling and fracking of 

oil and gas wells, to air quality impacts and the release of hazardous emissions. 

The BiFO DRMP has failed to sufficiently address and analyze these impacts, 

representing a major failure of the subject EIS.

n

See Chapter 4, Air, alternative-specific sections. Emissions from noncombustion sources are included in the emission inventories provided for each 

Alternative. Detailed emission inventories are provided in the Air Resource

Technical Support Document available online on the RMP webpage. Air 

resource impacts associated with these emissions are explained in Chapter 4, 

“Air Resources and Climate”.

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Oil and Gas

The rapid development of high volume/horizontal drilling in conjunction with 

hydraulic fracturing has driven expansion of new sources resulting in increased 

emissions -“ a change that requires consideration in the BiFO DRMP. Notably, 

EPA has, thus far, decided that it will not regulate methane emissions directly, 

suggesting an important and necessary role for BLM.

n

Thank you for your comment. There is no fracking currently occurring in the 

Billings Field Office and it is unlikely to occur. Language has been added to 

Chapter 3 to address your concerns. The RFD for the B&PPNM plan revision is 

4 wells per year occurring on BLM managed federal mineral estate per year. 

There are no high potential oil and gas development areas occurring in the 

federal mineral estate. Full-scale would be four wells per year. 

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Oil and Gas

As BLM proceeds with the BiFO DRMP and evaluates public land management 

throughout the Billings area, including opening federal lands to oil and gas 

development and hydraulic fracturing, it must consider the human health impacts 

associated with these extractive practices.

n

See Chapter 4, Social Conditions for a discussion on effects anticipated from 

BLM's proposed actions.

DR- Oil and Gas The health problems and uncertainties that proliferate in communities where oil n The Clean Air Act’s regulations impose extensive actions after ambient air 
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MTDK-BL13-0158-

27

and gas development takes place warrants the further collection of data and 

research, as contemplated under NEPA, before such development can be made 

possible by the BiFO DRMP. NEPA requires a hard look at these myriad

impacts, which the Draft EIS fails to sufficiently offer.

quality monitoring indicates violations of the NAAQS and exposure of the public 

to unhealthy air quality. As explained in Appendix T, Section 1.5.3, the BLM 

operates under FLPMA and NEPA mandates to protect air resources and 

prevent violations of the Clean Air Act. As described in Appendix T, Section 

4.1, the BLM will use only quality-assured monitoring data when determining 

mitigation design values and will confer with the MDEQ and EPA concerning 

these values.

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Air

For example, the BiFO DRMP does recognize health impacts from hazardous air 

pollutants ("HAPs") -“ which "are defined by USEPA as toxic air pollutants that 

are known or suspected to cause cancer or other serious health effects, such as 

reproductive effects or birth defects, or adverse environmental effects" -“ and 

"[m]modeled impacts were compared to established health-based thresholds to 

determine the incremental increase in risk associated with the proposed 

activities." DRMP at 3-17. The BiFO only examined acute (typically 1-hour) and 

chronic (one-year) exposures for benzene, ethyl benzene, formaldehyde, nhexane, toluene, and xylene. Id. at 4-17, 18, Table 4-10. The BiFO concluded 

that "acute HAP modeling impacts were well below the REL [Reference 

Exposure Levels]" and "[m]maximum predicted cancer risks for all modeled 

scenarios and HAPs are below an incremental increase in cancer risk of 1 per 

million." Id. at 4-19.The Conservation Groups cannot assess these conclusions 

when the BiFO does not disclose any of its analysis. The BiFO states that 

"[a]additional HAP modeling results are included in the ARTSD [Air Resources 

Technical Support Document] (BLM 2013)." Id. at 4-17. However, no such 

ARTSD was provided, and the DRMP notes that a draft ARTSD will not be 

completed until 2015. Id. at T-12. BiFO has also failed to disclose how it 

calculates its Reference Exposure Levels (RELs) beyond stating that RELs are 

"established health-based thresholds." Id. at 4-17. The BiFO provides no 

information on who established these standards, whether these standards take 

sensitive human subpopulations, livestock, or wildlife into account, or whether 

near-field air pollution for gas drilling will impact nearby communities or users in 

the planning area.

n

The Clean Air Act’s regulations impose extensive actions after ambient air 

quality monitoring indicates violations of the NAAQS and exposure of the public 

to unhealthy air quality. As explained in Appendix T, Section 1.5.3, the BLM 

operates under FLPMA and NEPA mandates to protect air resources and 

prevent violations of the Clean Air Act. As described in Appendix T, Section 

4.1, the BLM will use only quality-assured monitoring data when determining 

mitigation design values and will confer with the MDEQ and EPA concerning 

these values.

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Water

The resource development proposed by the BiFO DRMP has significant 

potential to contaminate groundwater resources in the Billings area. Ground 

water is "the primary source of drinking water for Montanans who live outside 

city boundaries, as well as those who are on public water systems," and is a vital 

component of the hydrological system, impacting area streams, rivers, wetlands, 

and riparian areas. DRMP at 3-39. Yet, the agency's decision making does not 

consider fracking impacts on these resources, providing, only, that "[b]est 

management practices, state, and federal guidance concentrate on protecting 

water quality." Id. at 3-39; see also Center for Biological Diversity v. Bureau of 

Land Management, No. C 11-006174 PSG (N.D. Cal. 2011) (concluding that 

y

Drinking water sources are protected through a number of stipulations, 

including but not limited to a new stipulation developed to conserve Source 

Water Protection Areas.
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NEPA review was inadequate and specifically referenced BLM's failure to 

adequately analyze groundwater contamination impacts).

DRMTDK-BL13-0158-3

Air

There are a number of Class I air quality areas that may be directly impacted by 

any development authorized by the BiFO DRMP. These areas include, but are 

not necessarily limited to the following: North Absaroka Wilderness, Northern 

Cheyenne Indian Reservation, U.L Bend Wilderness Area, Wind Cave National 

Park, and Yellowstone National Park. BLM, Draft Resource Management Plan 

and Environmental Impact Statement for the Bureau of Land Management 

(BLM) Billings and Pompeys Pillar National Monument RMP REVISION ("BiFO 

DRMP), 3-14 (2013). However, BiFO failed to consider visibility impacts to other 

areas subject to the nonimpairment mandate. These areas include the Pryor 

Mountain, Twin Coulee, Big Horn Tack On, and Burnt Timber WSAs.

n

Visibility impacts to Class I areas and areas identified by Federal Land 

Managers as sensitive Class II areas have been assess qualitatively in the 

PRMP. Additional visibility analysis will be performed as part of the 

photochemical grid modeling described in Section 5.0 of Appendix T. The 

Wilderness Study Area (WSA) nonimpairment mandate applies to activities that 

are located within a WSA. Visibility impacts to WSAs do not need to be 

assessed since they are not Class I areas and have not been designated as 

sensitive Class II areas by the BLM.

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Water

In preparing its NEPA analysis of the BiFO DRMP, BLM must address the direct, 

indirect, and cumulative impacts to groundwater, 40 C.F.R.§ 1508.25(c), giving 

particular scrutiny to the potential for contamination of groundwater supplies.

n

When issues are identified, analysis of potential impacts is initiated. Therefore, 

if impacts to groundwater are identified as an issue, they will be analyzed. 

Impacts to ground water would more appropriately be analyzed during project 

level NEPA, when a specific proposed action is established. Without a 

proposed action and project area, it is not feasible to accurately depict impacts 

to resources. 

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Water

In its NEPA analysis, BLM must address whether the oil and gas development 

will affect any high quality waters or whether it will degrade any existing uses. 

BLM may not evade its NEPA duty to consider these impacts by asserting that 

other agencies may issue discharge permits. 40 C.F.R. §§ 1502.14(f), 

1502.16(h).

n

The BLM does not avoid requirement of NEPA. During project specific analysis, 

scoping identifies potential impacts to the environment, which are then 

analyzed and determined to be significant or not. The BLM manages land uses, 

and through agreements with the state and other federal agencies, makes 

decisions to help maintain standards that are generally set by MT DEQ, with 

regard to water quality. MT DEQ regulates discharge waters, therefore permits 

them and monitors them for compliance. 

DRMTDK-BL13-0158-

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Water

As applied to the BiFO DRMP, the BiFO must consider the current and potential 

impacts of authorizing additional oil and gas and coal development. The DRMP 

fails to sufficiently analyze these impacts. Not only is BLM mandated to follow 

antidegradation and water quality standards under the CWA and state law, but it 

must also take a NEPA "hard look" at any impacts that may be related to these 

water quality standards as well. Here, the BiFO provides only that "impacts from 

surface disturbance and NPS [non-point source pollution] associated with fluid 

mineral development can adversely impact water quality by increasing sediment 

loads or chemical pollution with overland flow from development sites." 4-85. To 

control these impacts, BiFO would apply "appropriate stipulations to oil and gas 

leases would minimize impacts to riparian and water resources." Id. These 

stipulations include "NSO [No Surface Occupancy] with various buffers to 

riparian areas, water bodies, streams, wetlands, and special status plant and 

wildlife species." Id. BLM would also use "riparian vegetation, riparian health, 

and upland health as primary indicators of water quality." Id. This analysis is 

insufficient and fails to take the hard look that NEPA demands. BiFO's statement 

n

NEPA analysis per lease sale and at the project level would take a hard look at 

impacts to water quality, specific to a site. The RMP is not used to disclose 

every impact possible from any potential development in the field office... those 

impacts are delineated at the project level.

Without a specific proposed action and a project location, it is not feasible to 

accurately determine impacts from oil and gas development. 

Impacts from hydraulic fracturing will be identified during project level NEPA 

analysis. It is not feasible to develop impact scenarios planning area wide, with 

the relatively low RFD in BiFO; time and budget is better spent on higher 

priorities with immediate need. Hydraulic fracturing has not been an issue in 

BiFO and will be analyzed in detail when proposed. 

BiFO does not rely only on riparian vegetation indicators, only partially. PFC 
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that water quality may suffer from sediment and chemical pollution is cursory 

and provides no analysis on how it may suffer. See DRMP at 4-85. Moreover, 

none of BiFO's stipulations would minimize water quality impacts from fracking 

waste and its monitoring program may not even detect these impacts. On this 

second point, BiFO's water quality monitoring relies on riparian vegetation rather 

than in-stream indicators because "[r]riparian vegetation is a valuable indicator 

of potential livestock effects" and in-stream indicators would not provide "rapid 

feedback and may result in unacceptable impacts." Id. at 4-79. BiFO's 

monitoring program should not be tailored only to livestock effects; instead, the 

BiFO should examine waterways within its planning area and consider whether 

in-stream indicators should be used to detect fracking and other oil and gas 

wastes.

assessments use a number of indicators to evaluate riparian system health and 

function. Riparian function is a valuable indicator of water quality.

BLM/DEQ MOU with discusses these functional assessments as early 

indicators and how riparian trends can serve as an indicator of water quality 

trends.

The PFC manual applies to all public land uses, not only livestock grazing 

impacts. 

The MT DEQ 303d list shows only one degraded water source with a causal of 

O&G development/produced water. (Silvertip Cr). 

Methods to identify impacts early on are being developed. 

DRMTDK-BL13-0158-

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Water

Here, in its NEPA analysis BLM must closely assess the direct, indirect, and 

cumulative impacts of lease development on water supplies from oil and gas 

operations. 40 C.F.R. §§ 1508.7, 1508.8. This analysis must consider the 

potential sources of water that would be used for oil and gas development, and 

the impacts of these water withdrawals on water availability for drinking, 

agriculture, and wildlife. The analysis must further address the impacts to water 

quantity at different annual, seasonal, monthly, and daily time scales because 

the impacts of such water withdrawals could be more acute during times, 

months, and seasons of scarcity. For example, increased withdrawal and 

irretrievable contamination of waters will be particularly harmful during times -“ 

like the present -“ when much of the state is experiencing drought conditions.118 

As noted above, the BiFO DRMP fails to provide any analysis or recognition of 

significant water quantity issues associated with oil and gas development, 

representing a fundamental shortcoming in the DRMP.

n

Water resources have not been a contentious issue in the BiFO, particularly 

during analysis of oil and gas development activities. This is evidenced through 

the MT DEQ 303d list of impaired water bodies. This list shows one stream in 

the BiFO that is impaired, with oil and gas development listed as its causal 

factor. This particular stream, Silvertip Creek, is in a historic oil and gas field 

that has seen development during times of little to no regulation.

Furthermore, it is not feasible to analyze the impact to water resources on a 

planning area scale with the low RFD scenario; the vast differences in site 

location and project activities creates too broad an analysis scale. The impacts 

to water quality, be it surface or ground, is best analyzed during project specific 

NEPA analysis when a proposed action and location are established, allowing 

resource specialists to accurately depict the affected environment and potential 

impacts. Furthermore, scoping at this level (project specific) allows internal and 

external sources to develop relevant issues to be considered in analysis, 

instead of broadly applying general issues to an entire landscape.

Additionally, MT DEQ regulates the availability of water resources for industry 

use.

DRMTDK-BL13-0158-

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Wildlife

The BiFO identify numerous threatened and endangered species within the 

planning area, including black-footed ferret (mustela nigripes), Canada lynx 

(Lynx canadenis), and grizzly bear (Ursus arctos horribilis), as well as bird 

species such as the whooping crane (Grus americana). DRMP at 3-76. Despite 

BLM's recognition that these species are present in the Billings planning area, 

the DRMP fails to provide sufficient analysis regarding possible impacts to these 

protected species. For the grizzly bear, Canada lynx, and whooping crane, the 

agency provides only that "no impacts are expected to occur." Id. at 4-241. For 

n

Thank you for the comment. Refer to Table2-6.1, page 2-68, under Wildlife 

Habitat- Management Common to All Alternatives, the statement “Assist in the 

restoration, reintroduction, augmentation, or re-establishment of T & E, special 

status, and priority species and other populations” etc. 

BLM has consulted and will continue consultation with the U.S. Fish and 

Wildlife Service, Endangered Species Office on the DRMP impacts to 

endangered species. A biological assessment and Backlog Consultation was 
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black-footed ferret, which is considered the rarest mammal in North America, the 

BiFO states only that "[o]il and gas leasing and development activities would be 

allowed after the conclusion of surveys for black-footed ferrets" and "in the 

absence of black-footed ferrets, oil and gas leasing, development and 

exploration and geothermal operations would not be allowed within 1/2 mile of 

black-tailed and white-tailed prairie dog colonies active within the past 10 years." 

Id. at 4-261. Such dismissive and lax treatment of these protected species is 

insufficient under the procedural and substantive standards established in the 

ESA.

completed in 2007 and 2008 for those species. BLM will also consult with 

USFWS through a Biological Assessment on the Final RMP. 

DRMTDK-BL13-0158-

35

Social/econ

In the instant case, authorizing 606,096 acres (under preferred Alternative D) 

acres in the BiFO DRMP to oil and gas development and its ensuing 

infrastructure -“ which includes the construction of well pads, evaporation ponds, 

roads, power lines, and pipelines -“ clearly will represent a dramatic and 

community altering change to the physical environment. The impacts that this 

development will have on the traditional rural, ranching, and native communities 

must be sufficiently identified in the DRMP.

n

The oil and gas development potential for BiFO is low to moderate (see map 

24). The RFD for BiFO (federal leases) is 4 wells per year (total). 

No text revision necessary (Thanks for the comment. Resource outputs are the 

amount of a resource (e.g., AUMs, recreation visits, tons of locatable minerals, 

etc.) that would be available for use under each alternative. Resource 

specialists projected annual resource outputs based on the best available 

information and professional judgment. Based upon public comments, 

resource specialists have reviewed assumptions used in this analysis to see if 

they need to be changed or updated. These revised assumptions have been 

incorporated into the analysis contained in the DEIS. The purpose of the 

economic analysis is to compare the relative impacts of the alternatives and 

should not be viewed as absolute economic values. Previous modeling 

experience has shown that the data contained in the IMPLAN modeling system 

for the various sectors are accurate representations of impacts. )

DRMTDK-BL13-0158-

36

Oil and gas

NEPA requires the BiFO to look at the cumulative impacts of the proposed 

action. See 40 C.F.R.§ 1508.25. Failure to include cumulative impacts of all the 

mineral development authorized by the BiFO DRMP segments the process of oil 

and gas development into many mini- NEPAs. This practice, in turn, has the 

effect of hiding the fact that the cumulative impacts of all the segments are 

significant. Historically, BLM has failed to analyze the impacts of the authorized 

oil and gas development in the BiFO DRMP with the already permitted activities 

in the vicinity of the project. Under NEPA, BLM "must analyze not only the direct 

impacts of the proposed action, but also the indirect and cumulative impacts of -

 ̃past, present, and reasonably foreseeable future actions regardless of what 

agency (Federal or non-Federal) or person undertakes such actions.'" Wyoming 

v. U.S. Dept. of Agriculture, 661 F.3d 1209, 1251 (10th Cir. 2011) (citing 

Colorado Environmental Coalition v. Dombeck, 185 F.3d 1162, 1176 (quoting 40 

C.F.R. § 1508.7)); see also 40 C.F.R. § 1508.25 (c) (stating that the "scope" of 

an EIS includes consideration of "cumulative" impacts).

n

Thank you for your comment. Please review the fluid minerals section in 

Chapter 3 and the RFD. The RFD for the B&PPNM plan revision is 4 wells per 

year occurring on BLM managed federal mineral estate per year. There are no 

high potential oil and gas development areas occurring in the federal mineral 

estate. Full-scale would be four wells per year. 

DRMTDK-BL13-0158-

Oil and gas

The cumulative impacts to the landscape of energy development in the region 

have already left scars, and the potential for further development threatens 

greater impacts to the area. Compounding the problem, BLM has historically 

n Thank you for your comment.
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37 failed to consider the cumulative impacts of extractive mineral development 

together. For example, mining activities add to the cumulative impacts of oil and 

gas development, including impacts to air and water quality, habitat destruction 

and fragmentation, and loss of wild areas and the aesthetic, recreational, and 

spiritual benefits derived therefrom.

DRMTDK-BL13-0158-

38

Air 

In addition to the cumulative land disturbance from energy development in the 

region, BLM has failed to consider the cumulative impacts of air pollution caused 

by this development.

n

Cumulative impacts of energy development activities on air resources are 

described in Chapter 4, Air Resources, and in the Air Resource Management 

Plan (Appendix T). Cumulative air pollution impacts are addressed qualitatively 

based on available data.

DRMTDK-BL13-0158-

39

Air

In addition to the cumulative effects of conventional air pollution, energy 

development in the region is causing significant GHG pollution in the form of 

methane emissions -“ the impacts of which were detailed, above. BLM has 

historically, and here, failed to consider the methane emissions of oil and gas 

development and its contribution to climate change. BLM has added to this error 

by failing to consider the cumulative methane emissions throughout the BiFO 

area. BLM must consider the cumulative impacts of oil and gas and coal 

development in the area.

n

GHG emission emissions from BLM-authorized activities are included in 

Chapter 4, Climate Change, alternative-specific emission inventories and 

Appendix Y.

DRMTDK-BL13-0158-4

Air

By authorizing the development of coal bed methane and the 606,096 acres 

(under preferred Alternative D) for oil and gas development, the BiFO must 

analyze air quality, human health, and compliance or interference with the EPA's 

Regional Haze rules in greater detail.

n

Section 4.1.1 analyzes air quality, human health, and visibility impacts at a level 

appropriate for the small emission increases associated with oil and gas activity 

under the alternatives.

DRMTDK-BL13-0158-

40

NEPA

BLM must ensure that it has adequate baseline data to determine impacts, 

rather than basing impacts only on incremental additions to the already 

significant development occurring within the Billings planning area.

N Thank your for your comment. 

DRMTDK-BL13-0158-

41

NEPA

Accordingly, the BiFO RMP revision must consider, on equal footing, the value 

of permanent protection and preservation of public lands in the Billings planning 

area, along with industry pressure to lease and develop these lands. The RMP 

revision process is the perfect opportunity for BLM to re-evaluate these 

competing resources and give suitable weight to FLPMA's mandate to, where 

appropriate, preserve and protect public lands in their natural condition. See 43 

U.S.C. § 1701(a)(8).

N Thank you for your comment. 

DRMTDK-BL13-0158-

42

Oil and Gas 

For example, oil and gas development in the Bakken Shale formation in 

northwestern North Dakota has, given current relative market prices, focused on 

oil production. However, significant quantities of associated natural gas have 

been produced in conjunction with oil, and "[c]ompanies that build pipelines and 

gas-processing plants simply cannot keep up."121 As a result, "[t]he upshot is 

flaring, and lots of it. North Dakota's flaring rose more than sixfold between 2006 

and 2011," and roughly 30% of natural gas is still currently being flared 

according to the North Dakota Industrial Commission.122 Given this tremendous 

waste of a public resource and the lack of gathering and boosting infrastructure 

n Thank you for your comment.
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in the public lands administered by the BLM, we believe that alternatives should 

be considered that either require gas reinjection, or closes public lands to oil and 

gas development until either such infrastructure is in place or development is 

planned to ensure that such infrastructure will be in place to accommodate the 

pace of oil and gas development.

DRMTDK-BL13-0158-

43

NEPA

While certain lands may indeed be appropriate for responsible oil and gas 

leasing and development, it is equally evident that there are lands where other 

resource values should prevail. FLPMA affords BLM great authority to 

appropriately balance these competing interests, which expressly includes the 

responsibility to "preserve and protect certain public lands in their natural 

condition." 43 U.S.C. § 1701(a)(8). Moreover, FLPMA further delegates BLM 

authority to permanently withdraw lands from consideration. See 43 U.S.C. § 

1714. This ability authorizes the Secretary to "make, modify, extend, or revoke 

withdrawals." Id. In either event, BLM's BiFO cannot continue its practice of 

prioritizing oil and gas leasing and development above the other resource values 

at stake. The BiFO RMP revision process should be used to provide a 

framework where BLM can more fully realize its multiple use mandate now and 

into the future.

N

Thank you for your comment.

The BLM’s multiple-use mission and the BLM’s obligation to comply with the 

Federal Land Policy and Management Act of 1976 (FLPMA) and all other 

applicable laws, regulations and policies are addressed in Chapter 1 of the 

RMP/EIS.

DRMTDK-BL13-0158-

44

WSR

The BiFO does not justify why Wild and Scenic River Act (WSRA) eligible river 

segments in the DRMP vary under the RMP Alternatives. The WSRA 

establishes, as a national policy, that rivers, which "possess outstandingly 

remarkable scenic, recreational, geologic, fish and wildlife, historic, cultural, or 

other similar values, shall be preserved in free-flowing condition," and "their 

immediate environments shall be protected for the benefit and enjoyment of 

present and future generations." 16 U.S.C.§ 1271.

n

Thank you for your review of the draft RMP and your comments. The BIFO did 

do a Suitability Study as part of this planning effort. It appears that the 

document was inadvertently left out of the document. It has been inserted into 

Appendix R, after the Eligibility Study Report. 

DRMTDK-BL13-0158-

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WSR

Although the BiFO has not completed its suitability determination, it has varied 

the number of suitable river segments under its proposed Alternatives. "Under 

Alternative B, the seven eligible river segments (14.08 miles) would be 

recommended as suitable for inclusion in the National Wild and Scenic River 

System to protect their outstandingly remarkable values and free-flowing 

nature." DRMP at 2-31. Under Alternative D (the preferred alternative), "only two 

river segments (3.15 miles) would be recommended and suitable for inclusion in 

the National Wild and Scenic River System." Id. at 2-36. Under Alternatives A 

and C, none of the eligible segments would be recommended under the system, 

but they would be managed to protect their ORVs. Id. at 2-29, 2-34. The BiFO 

provides no explanation for these different alternatives or how it reached a 

determination that two, seven, or none of the rivers are WSRA suitable. The 

BiFO must provide an explanation, particularly when it has not yet completed the 

suitability analysis. Id. at 3-223.

n

Thank you for your review of the draft RMP and your comments. The BIFO did 

do a Suitability Study as part of this planning effort. It appears that the 

document was inadvertently left out of the document. It has been inserted into 

Appendix R, after the Eligibility Study Report.

DRMTDK-BLAir it is critical that the BiFO takes a hard look in the RMP at methods to reduce 

GHG emissions and at how authorizations and management activities will Y

The BLM reviewed GHG emissions, based on new data from the USEPA's 

Greenhouse Gas Mandatory Reporting Rule (MRR). No operators of oil and 
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13-0158-

46

ensure implementation of feasible GHG emission reduction strategies. gas production facilities reported GHG emissions under the EPA’s GHG 

Mandatory Reporting Rule (MRR), as summarized in Section 3.2.2.4.4. The 

BLM also identified MDEQ regulations that would reduce methane from a 

variety of sources in Section 1.5.2 of Appendix T. Finally, Section B.1 of 

Appendix B, “Air Resource BMPs” provides a list of BMPs that would reduce 

GHG emissions.

DRMTDK-BL13-0158-

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Air

The BiFO's decision to wait to address GHG emissions at the APD stage, while 

ignoring them at the RPM and subsequent leasing stages, however, is a fatal 

flaw. It is unreasonable for the BiFO to suggest that it cannot address methane 

and other GHG emissions at the RMP stage; to suggest otherwise misleads the 

public into a false sense of confidence that the BiFO will adequately assess 

environmental impacts at the APD phase. NEPA requires BiFO to adequately 

analyze and disclose methane and GHG emissions and impacts for drilling on 

the federal mineral estate. To then segment environmental review on a case-bycase basis would misconstrue the total environmental impact of oil and gas 

drilling in the planning and development areas by only analyzing a single well's 

emissions

y

Thank you for your comment. The BLM reviewed and analyzed GHG emissions 

from oil and gas sources and determined that BMPs are sufficient to address 

GHG emissions after accounting for the quantity of GHG emissions and the 

effect of federal and state regulatory programs. 

DRMTDK-BL13-0158-

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Air

Worse, by segmenting NEPA review, the DRMP risks establishing a process for 

oil and gas development that never requires the BiFO to fully analyze methane 

or other GHG emissions. BLM is authorized to categorically exclude oil and gas 

drilling development, so long as the surface disturbance is less than five acres, 

the total surface disturbance on the lease is not greater than 150 acres, and sitespecific analysis has been previously completed pursuant to NEPA. 42 U.S.C. § 

15942. None of the forecasted drilling sites in the DRMP exceed these acreage 

limitations. DRMP at 4-423. BiFO cannot tier to the DRMP because, as 

discussed previously, it has not taken the requisite hard look at oil and gas 

development emissions. Should BiFO attempt to do so, however, the BiFO may 

never meaningfully apply the BMPs. Indeed, the BiFO has already demonstrated 

a lack of attention to methane emissions and reductions.

y

Thank you for your comment. The BLM reviewed GHG emissions, based on 

new data from the USEPA's Greenhouse Gas Mandatory Reporting Rule 

(MRR). No operators of oil and gas production facilities reported GHG 

emissions under the EPA’s GHG Mandatory Reporting Rule (MRR), as 

summarized in Section 3.2.2.4.4. The BLM also identified MDEQ regulations 

that would reduce methane from a variety of sources in Section 1.5.2 of 

Appendix T. Finally, Section B.1 of Appendix B, “Air Resource BMPs” provides 

a list of BMPs that would reduce GHG emissions. 

DRMTDK-BL13-0158-

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Air

Considerable information is available to the BiFO on ways to reduce methane 

emissions, and the agency has ample means, including binding commitments in 

the DRMP, lease stipulations, and conditions on approval to drill, that would 

ensure that such authorizations and management activities do implement 

feasible GHG emission reduction strategies. Much of this information is in fact 

contained in official documents of the BLM.

n

The BLM reviewed GHG emissions, based on new data from the USEPA's 

Greenhouse Gas Mandatory Reporting Rule (MRR). No operators of oil and 

gas production facilities reported GHG emissions under the EPA’s GHG 

Mandatory Reporting Rule (MRR), as summarized in Section 3.2.2.4.4. The 

BLM also identified MDEQ regulations that would reduce methane from a 

variety of sources in Section 1.5.2 of Appendix T. Finally, Section B.1 of 

Appendix B, “Air Resource BMPs” provides a list of BMPs that would reduce 

GHG emissions.

DRMTDK-BL13-0158-5

Air

For example, the BiFO fails to take a hard look at VOC air quality visibility 

impacts in the planning area. The BiFO recognizes that VOC emissions 

contribute to ozone formation but does not take these emissions into account 

when considering visibility. See DRMP at 4-20, 22. Instead, the BiFO only 

y The visibility discussion has been modified to include VOC emissions.
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considered SO2, NOx, and PM 2.5. DRMP at 4-22, 4-36. After assuming that the 

rise in these three pollutants would be low, see id., the BiFO concluded that the 

alternatives' "[p]otential visibility impacts are likely to be small," id. at 4-22, and 

cumulative impacts to visibility are likely to be "moderate," id. at 4-36. These 

qualitative statements, however, ignore anticipated VOC emission increases. 

RMP authorized activities are expected to increase VOCs by 3.6% and 

cumulative emissions in the area are expected to increase VOCs by 14.6%. Id. 

at 4-20, 36. Oil development and production accounts for the bulk of these VOC 

emissions. See id. at 4-28, 30, 31, 33; see also id. at 4-35 (noting, however, 

these estimates exclude coal mining emissions). Moreover, under this 

methodology, BiFO fails to examine visibility impacts for nonimpairment areas in 

the planning area. By failing to analyze these sensitive areas or VOC impacts on 

visibility, BLM has ignored its obligations under NEPA.

DRMTDK-BL13-0158-

50

Air

The first set of BMPs that the BiFO must consider including as stipulations in the 

RMP process are the BMPs included in the DRMP Best Management Practices 

Appendix. DRMP at B-1, et seq. Air quality measures include: ? Electrifying 

equipment when feasible; ? Achieving high levels of emission control by 

installing and operating low emission equipment (i.e., drill rig engines with 

emissions at least as low as Tier 4 engine standards) or operating older 

equipment that has been retrofitted with additional emission controls such as 

nonselective catalytic reduction or catalytic oxidation; ? Using natural gas or 

electric engines rather than diesel engines; ? Using alternative energy (solar 

power, wind power, or both) to power new water source developments; ? 

Converting power sources at existing water well developments to alternative 

energy sources. ? Using green completion technology to capture methane (and 

some VOC and HAP) emissions during completion and place the gas in sales 

pipelines; ? Using flaring rather than venting during completion activities, but 

only in cases where product capture is not feasible; ? Using closed tanks rather 

than open tanks or pits; ? Installing vapor recovery units on storage tanks; ? 

Using vapor balancing during condensate and oil tanker truck loading; ? Using 

closed-loop drilling; ? Replacing pneumatic (natural gas) pumps with electric or 

solar pumps; ? Optimize glycol circulation rates on glycol dehydrators; ? 

Replacing wet seals with dry seals in centrifugal compressors; ? Replacing worn 

rod packing in reciprocating compressors; and ? Installing automated plunger lift 

systems in natural gas wells; and monitoring equipment leaks and repairing 

equipment leaks. DRMP at B-16. The BMPs also call for climate related BMPs 

including: ? Reduce CO2 emissions by reducing vehicle miles traveled and using 

fuel-efficient vehicles; ? Reduce CO2 emissions by using renewable energy to 

power equipment; ? Reduce CO2 emissions by using energy-saving techniques; 

? Identify and implement methods to sequester CO2; and ? Reduce methane 

emissions from oil and gas activities by: o Capturing methane using green 

Y Thank you for your comment. Please see Appendices B and C. 
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completion, when feasible, and beneficially using the gas by placing it in sales 

pipeline; o Flaring methane during well completion activities for which green 

completion is infeasible; o Replacing natural gas driven pneumatic equipment 

with solar or electrically powered equipment; o Optimizing glycol recirculation 

rates for glycol dehydrators; o Operating flash tank separators on glycol 

dehydrators; Identifying fugitive emissions from equipment leaks and repairing 

or replacing seals, valves, compressor rod packing systems, and pneumatic 

devices; and Implementing additional GHG emission reduction strategies from 

the oil and gas BMPs located at: 

http://www.blm.gov/style/medialib/blm/wo/MINERALS__REALTY__A ND_ 

RESOURCE_PROTECTION_/bmps.Par.60203.File.dat/WO1_Air%20Re sour 

ce_BMP_Slideshow%2005-09-2011.pdf126 and the EPA Natural Gas Star 

website at http://www.epa.gov/gasstar/tools/recommended.html. 126 See 

Bureau of Land Management, Air Resource BMPs: Best Management Practices 

for Fluid Minerals (2011), available 

at:http://www.blm.gov/pgdata/etc/medialib/blm/wo/MINERALS__REALTY__AND

_RESOURCEPROTECTION_/bmps.Par.60203.File.dat/WO1_Air%20Resource_

BMP_Slideshow%2005-09- 2011.pdf (attached as Exhibit 113).DRMP at B19. The last climate-related BMP identified in the DRMP include those that BLM 

itself has recognized and publicized on its website.127 These measures 

include: 127 See Exhibit 113. Moving toward cleaner diesel engines Natural gas 

powered engines ? Flaring Reduces Methane GHG emissions, but has 

downsides as noted below. Combustion emissions include NOx, CO, VOCs, 

and PM2.5, which can pose visibility and health problems, and CO2 (a less 

potent GHG). NOx and VOCs contribute to ozone formation. Wastes valuable 

natural gas resources. Reduced Emissions Completions Using chemical pumps 

and well monitoring telemetry powered by solar panels Using electricity from the 

nation's power grid is typically cleaner than using onsite diesel or natural gas 

engines to power drill rigs, compressors, and pumping units. Using enclosed 

tanks instead of open pits to reduce fugitive VOC emissions Vapor Recovery 

Units ?Using and maintaining proper hatches, seals, and valves to minimize 

VOC emissions Optimize Glycol Circulation and Install Flash Tank Separator 

Replacement of Wet Seals with Dry Seals in Centrifugal Compressors Reduce 

Emissions from Compressor Rod Packing Systems Replace high-bleed devices 

with low-bleed and Retrofit bleed reduction kits on high-bleed devices Installing 

Plunger Lift Systems and Automated Systems in Gas Wells ? Directed 

Inspection & Maintenance and Infrared Leak Detection

DRMTDK-BL13-0158-

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Air

BLM has also noted many methane pollution mitigation measures in its Climate 

Change, Supplementary Information Report ("SIR").128 BLM notes "US EPA's 

Natural Gas STAR program has identified more than 80 potentially cost-effective 

technologies for decreasing methane emissions from the oil and natural gas 

Y

The BLM reviewed GHG emissions, based on new data from the USEPA's 

Greenhouse Gas Mandatory Reporting Rule (MRR). No operators of oil and 

gas production facilities reported GHG emissions under the EPA’s GHG 

Mandatory Reporting Rule (MRR), as summarized in Section 3.2.2.4.4. The
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industry."129 Of these, the following discussion selects technologies that focus 

primarily on natural gas production and gathering equipment and on emission 

sources for which BLM may have a major role in identifying mitigation 

measures." SIR at 6-4. The report highlights the following mitigation 

technologies: 128 URS, Climate Change, Supplementary Information Report 

(Oct. 2010) (mitigation measure costs and paybacks are summarized in Table 6-

2 at 6-6, 6-7 and described in Chapter 6), available at: 

http://www.blm.gov/mt/st/en/prog/energy/oil_and_gas/leasing/leasingEAs.html. 

129 U.S. EPA, Natural Gas STAR Program, Recommended Technologies and 

Practices, available at: http://epa.gov/gasstar/tools/recommended.html.Natural 

Gas Mitigation Measures Wells: Reduced Emission (Green) Completions 

Plunger Lift Systems Smart Automation for Plunger Lift Systems ? Well 

Foaming Agents Tanks: Installation of Vapor Recovery Units Tank 

Consolidation Glycol Dehydrators: ?Flash Tank Separators Optimization of 

Glycol Recirculation Zero-emission Dehydrators Pneumatic Devices and Control 

systems: Replacement of High-Bleed Devices with Low-Bleed Devices Convert 

Gas Pneumatic Controls to Another Motive Force Valves: Test and Repair of 

Pressure Safety Valves Inspection and Repair of Compression Station 

Blowdown Valves Compressors: ? Electrification of Compressors Replacement 

of Wet Seals with Dry Seals Replacement of Compressor Rod Packing Systems 

The report also addresses key mitigation technologies for oil production and 

Coal Bed Methane. Oil Sector Mitigation Measures Methane Flaring Methane 

Reinjection: " " in many oil production fields natural gas cannot be captured and 

sold due to a lack of gas processing facilities and the absence of a nearby 

natural gas pipeline. When the gas cannot be sold, it can be vented, used as 

onsite fuel, flared, or reinjected into the oil field. " methane reinjection is 

estimated to be " more expensive than flaring. However, methane reinjection has 

several potential benefits over flaring, including (1) increasing oil well production, 

(2) avoiding combustion emissions, and (3) preserving natural gas in the well 

field for potential recovery at a later time," at 6-14, 15. CO2 Injection ? VRU 

Installation on Oil Storage Tanks Coal Bed Methane Well Mitigation Measures ? 

CBM Wells to Remove Methane ?CBM Wells to Sequester CO2

BLM also identified MDEQ regulations that would reduce methane from a 

variety of sources in Section 1.5.2 of Appendix T. Finally, Section B.1 of 

Appendix B, “Air Resource BMPs” provides a list of BMPs that would reduce 

GHG emissions.

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Air

Gas Production and Processing Perform reduced emissions completions: Install 

plunger lifts Aerial leak detection using laser and/or infrared technology 

Eliminate unnecessary equipment and/or systems Oil Production Install VRUs

on crude oil storage tanks Route casinghead gas to VRU or compressor for 

recovery & use or sale Gas Storage Convert gas pneumatic controls to 

instrument air Replace bi-directional orifice metering with ultrasonic meters 

Reduce methane emissions from compressor rod packing systems Gas 

Transmission DI&M at compressor stations Use fixed/portable compressors for 

pipeline pumpdown Install vapor recovery units on pipeline liquid/condensate 

Y

The BLM reviewed GHG emissions, based on new data from the USEPA's 

Greenhouse Gas Mandatory Reporting Rule (MRR). No operators of oil and 

gas production facilities reported GHG emissions under the EPA’s GHG 

Mandatory Reporting Rule (MRR), as summarized in Section 3.2.2.4.4. The 

BLM also identified MDEQ regulations that would reduce methane from a 

variety of sources in Section 1.5.2 of Appendix T. Finally, Section B.1 of 

Appendix B, “Air Resource BMPs” provides a list of BMPs that would reduce 

GHG emissions.
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tanks The EPA Natural Gas STAR measures are recognized as effective, and as 

noted, were developed with industry. There is no reason why BLM should not 

work to include these measures in the BiFO RMP process.

DRMTDK-BL13-0158-

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Air

Another source of mitigation measures is the Leaking Profits report, published by 

NRDC.131 The stipulations outlined in that report would establish a mandatory 

obligation on lessees to adopt widely-recognized industry "best management 

practices," take all reasonable, cost-effective action to reduce GHG pollution and 

require the lessees to demonstrate, in applications for permit to drill, how GHG 

pollution will in fact be reduced from production-stage technologies and 

practices. It would also provide that BLM retains the authority to require best 

available technology for GHG reductions upon review of the lessee's APD. Best 

available methane emissions reduction technology would include at least the 

following, which are technically proven, commercially available and in most 

cases profitable: 131 See Exhibit 44. Green or reduced-emissions completions-

”all recovered liquids must be routed to storage vessels and all recovered gases 

must be routed to a gas gathering line and collection system. This process 

captures liquids and gases coming out of wells as they are being drilled, 

repaired, stimulated or re-stimulated during hydraulic fracturing and keeps them 

out of the atmosphere. If capturing methane is not feasible due to the absence of 

gathering infrastructure, options include (1) imposing royalty and tax payments 

on flared gas to create economic incentives for infrastructure incentives, or (2) 

requiring gas re-injection. Liquids unloading-”operators must employ a plunger 

lift system or other liquids unloading system with an equal or greater methane 

capture rate at wellhead facilities to remove accumulated liquids from the well 

bore, separate them from the gas, route gas to a sales line, and route liquids to a 

storage vessel. Improved maintenance for compressors, dry seals-”operators 

must implement a maintenance program for compressors that is in line with 

industry best practices and must also employ tandem dry seals for all centrifugal 

compressors used in the production and transmission of natural gas. Pneumatic 

devices-”for all pneumatic devices, operators must employ low bleed or nobleed 

controllers. High-bleed pneumatic devices should be prohibited for all new 

applications and replaced on existing ones. TEG dehydrator emission controls-

”methane venting from tri-ethylene (TEG) dehydrators must be minimized by 

retrofitting TEG dehydrating systems with emission control equipment including 

flash tank separators, optimizing the glycol circulation rate, rerouting the 

skimmer gas, and installing electric pumps to replace natural gas driven energy 

exchange pumps. Desiccant dehydrators-”operators must deploy desiccant 

dehydrators, which pass gas through a bed of water-absorbing salt to remove 

gas moisture without venting methane, whenever feasible. Vapor recovery units-

”operators shall employ vapor recovery units comprising scrubbers, compressors 

and valves with all storage tanks that recover, at minimum, 99 percent of all 

Y

The BLM reviewed GHG emissions, based on new data from the USEPA's 

Greenhouse Gas Mandatory Reporting Rule (MRR). No operators of oil and 

gas production facilities reported GHG emissions under the EPA’s GHG 

Mandatory Reporting Rule (MRR), as summarized in Section 3.2.2.4.4. The 

BLM also identified MDEQ regulations that would reduce methane from a 

variety of sources in Section 1.5.2 of Appendix T. Finally, Section B.1 of 

Appendix B, “Air Resource BMPs” provides a list of BMPs that would reduce 

GHG emissions.
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vapors. Recovered vapors shall not be leaked or vented into the ambient air. ? 

Pipelines-”all pipelines must be constructed using plastic pipe. If operators are 

able to demonstrate to the satisfaction of BLM that the use of plastic pipe is 

infeasible, operators shall employ plastic insert liners to reduce gas leakage. 

Excess flow valves shall be installed in all pipelines. When a pipeline is repaired 

or replaced, or cut to install a new connection point, the amount of methane 

released into the atmosphere must be reduced by either re-routed the gas and 

burning it as fuel during the repair and maintenance. Methane gas venting must 

also be mitigated by using hot tap connections, de-pressuring the pipeline to a 

nearby low pressure fuel system, or using a pipeline pump-down technique to 

route gas to sales. ? Leak Monitoring and Repair - Methane leaks can occur 

from numerous locations at an oil and gas facility -“ valves, drains, pumps, 

connections, pressure relief devices, open ended valves, and lines. Since 

methane is a colorless, odorless gas, methane leaks often go unnoticed. 

Operators must establish a well-implemented program of regularly monitoring 

and repairing leaks to significantly reduce fugitive emissions.

DRMTDK-BL13-0158-

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Air

Finally, the Clearing the Air report, by the World Resources Institute, outlines 

measures by which methane waste can be reduced.132 132 James Bradbury, 

Michael Obeiter, Laura Draucker, Wen Wang, and Amanda Stevens, Clearing 

the Air: Reducing Upstream Greenhouse Gas Emissions from U.S. Natural Gas 

Systems, Working Paper, World Resources Institute (April 2013), available at: 

http://www.wri.org/publication/clearing-the-air (attached as Exhibit 109).? 

Reducing emissions from well blowdowns with plunger lift systems ? Replacing 

existing high-bleed pneumatic controllers with low-bleed devices Leak detection 

and repair ("LDAR")

y

The BLM reviewed GHG emissions, based on new data from the USEPA's 

Greenhouse Gas Mandatory Reporting Rule (MRR). No operators of oil and 

gas production facilities reported GHG emissions under the EPA’s GHG 

Mandatory Reporting Rule (MRR), as summarized in Section 3.2.2.4.4. The 

BLM also identified MDEQ regulations that would reduce methane from a 

variety of sources in Section 1.5.2 of Appendix T. Finally, Section B.1 of 

Appendix B, “Air Resource BMPs” provides a list of BMPs that would reduce 

GHG emissions.

DRMTDK-BL13-0158-

55

Air

Otherwise, the BiFO DRMP does not sufficiently analyze air resources and 

climate actions. The DRMP does not include any stipulations that would reduce 

GHG emissions. Instead, the DRMP gives the BiFO complete discretion to 

implement BMPs on a case-by-case basis, depending on "the specific 

characteristics of project area and types of disturbance being proposed." DRMP 

at 2-8. As discussed, these actions do not go nearly far enough. Through the 

RMP, the BiFO should:

y

The BLM reviewed GHG emissions, based on new data from the USEPA's 

Greenhouse Gas Mandatory Reporting Rule (MRR). No operators of oil and 

gas production facilities reported GHG emissions under the EPA’s GHG 

Mandatory Reporting Rule (MRR), as summarized in Section 3.2.2.4.4. The 

BLM also identified MDEQ regulations that would reduce methane from a 

variety of sources in Section 1.5.2 of Appendix T. Finally, Section B.1 of 

Appendix B, “Air Resource BMPs” provides a list of BMPs that would reduce 

GHG emissions. 

DRMTDK-BL13-0158-6

Air

Despite these noted impacts, the BiFO’s preferred alternative would authorize oil 

and gas and coal development in a manner that suggests it has no power 

whatsoever to influence events. BLM not only has the authority, but an obligation 

to address GHG emissions and methane waste. Related and cumulative actions 

must be considered in the EIS. The impact from regional BLM proposed oil and 

gas drilling will be substantial. This summer BLM released three separate 

DRMPs that will result in GHG emissions increases: the BiFO, the Miles City, 

and the Hiline DRMPs. Under the preferred alternatives, the three DRMPs would 

N Thank you for your comment
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cover over 9.8 million acres of open federal lease estate in Montana-”roughly 

10% of the state-”and result in 95 new federal wells per year.12Â 12 The three 

RMPs were developed by the Miles City, Billings, and Havre Field Offices. Under 

the proposed Miles City Field Office RMP, all 5.4 million acres of federal lease 

estate would be open to oil and gas drilling and the Miles City Field Office 

anticipates 43 new wells per year. BLM, Draft . The draft Hiline Field Office RMP 

proposed development on 4,042,298 acres, and under the BLM's preferred 

alternative, estimated 98 new oil and gas wells per year. The draft Billings Field 

Office and Pompeys Pillar National Monument RMP proposed 606,096 acres of 

federal lease estate and estimated 4 new wells per year. Draft RMPs and 

Environmental Impact Statements may be found here: 

http://www.blm.gov/mt/st/en.html.

DRMTDK-BL13-0158-7

Air

In addition, when considering regional impacts, the BiFO must examine and 

disclose whether any proposed disposals under its Alternatives have been 

subject to a lease sale in the past, will result in coal, oil or gas development, and 

also disclose any anticipated GHG emissions on those lands. For example, 

under Alternatives C and D, at least two proposed lease sales (T. 4 S., R. 19E., 

sec. 35 SENE and T. 5 S., R 19 E., sec.5, SESE) were leased in 2004. DRMP at 

J-16, 17. BiFO must disclose this information -“ information that it already has in 

its possession -“ and analyze potential impacts.

N

Thank you for your comment. The RMP/EIS looks at future impacts from land 

use planning decisions and assesses direct and cumulative impacts. 

DRMTDK-BL13-0158-8

Air

Moreover, with GHG pollution and climate change, it is not only the contribution 

to climate change that must be considered, but, also, the combined impact of the 

authorized activity and climate change to specific resources; e.g., water 

resources, vegetation, farmlands, wildlife and endangered species, etc. Here, 

the BiFO fails to take this next step. While the BiFO DRMP provides data on 

GHG emissions from the preferred alternative, and lists general impacts from 

climate change, the agency fails to account for this data in its decision-making or 

provide any hard look analysis of the associated impacts, in violation of NEPA.

N

The BLM does not have sufficient data to assess specific planning area climate 

change impacts associated with authorized activities that would release GHGs.

DRMTDK-BL13-0158-9

Air

As noted above, the BiFO has recognized the impacts of authorized activities on 

GHG pollution and climate change. Accordingly, the agency must take the next 

step and address BiFO related emission contributions in the DRMP. It is not 

enough to simply identify impacts that may occur. BLM is required to take a hard 

look at those impacts as they relate to the agency action. The BiFO DRMP fails 

to provide this hard look analysis. "Energy-related activities contribute 70% of 

global GHG emissions; oil and gas together represent 60% of those energyrelated emissions through their extraction, processing and subsequent 

combustion."13 Even if science cannot isolate each additional gas well's 

contribution to these overall emissions, this does not obviate BLM's 

responsibility to consider oil and gas development in the BiFO from the 

cumulative impacts of the oil and gas sector. In other words, the BLM cannot 

ignore the larger relationship that oil and gas management decisions have to the 

Y

SO 3226, NEPA, and FLPMA require the BLM to assess GHG emissions and 

impacts. GHG emissions from oil and gas sources within the planning area are 

very low and are expected to remain low with maximum development of four 

wells per year. No oil and gas production companies had sufficient GHG 

emissions to require reporting under the EPA Greenhouse Gas Mandatory 

Reporting Rule (40 CFR Part 98, Subpart W) for year 2012, as summarized in 

Section 3.2.2.4.4. Section B.1 of Appendix B summarizes BLM BMPs to reduce 

GHG emissions.
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broader climate crisis that we face. If we are to stem climate disaster -“ the 

impacts of which we are already experiencing, as discussed above -“ the 

agency's resource management decisions, as will be provided in the BiFO 

DRMP, must be reflective of this reality and plan accordingly. 13 International 

Investors Group on Climate Change, Global Climate Disclosure Framework for 

Oil and Gas Companies (attached as Exhibit 36).The current DRMP fails to do 

so.

DRMTDK-BL13-0171-1

Livestock 

Grazing

 The BLM assumed that removing livestock from the landscape would be 

necessary on allotments "wholly located within Sage grouse Habitat." 

DRMP/DEIS at 2-116. However, based on research removing livestock is not 

necessary for sage grouse. Exhibit A -” M. M. Rowland, Effects of Management

Practices on Grassland Birds: Greater Sage Grouse, Northern Prairie Wildlife 

Research Center Online (2004)

n

BLM did not assume that removing livestock from the landscape would be 

necessary. It may however be desirable for sage grouse on an allotment basis 

to retire specific allotments from grazing. Additionally, and further proof that 

BLM did not assume removal of livestock on a landscape basis is necessary for 

sage grouse, on page 2-116 under impacts common to all alternatives it is 

stated BLM would “ use livestock grazing to enhance ecosystem health, wildlife 

habitat, .... Where supported by site-specific environmental analysis.” If current 

livestock use is compatible with sage grouse habitat requirements, BLM would 

have little basis to retire the allotment from grazing. In addition, base property 

owners rarely relinquish their preference.

DRMTDK-BL13-0171-

10

Livestock 

Grazing

In this case, the BLM failed to "insure the professional integrity, including the 

scientific integrity, of the discussions and analysis in the [DEIS]," in violation of 

NEPA and the DQA. Some examples of the BLM's failure to meet data quality 

standards include: At 3-40 of the DRMP/DEIS the BLM states that there are 

427,619 surface acres in the planning area, but at 3-134 of the DRMP/DEIS, the 

BLM states that it has 433,688 acres available in its VRM qualifications. There 

seems to be an error. The information on 4-37 of the DRMP/DEIS, related to 

temperature, was cherry picked to leave out years in the 1930s that were very 

hot and would throw the desired curve off. Throughout the DRMP/DEIS (at 2-14; 

4-37, 42, etc.), the whole plan seems to be to get rid of livestock grazing, which 

will only increase the dead vegetation that will lead to hot fires. Hot fires kill big 

sagebrush. The BLM states that big sagebrush is sage grouse habitat. 

Therefore, it seems that the data and science do not add up. On 4-473 of 

DRMP/DEIS, the BLM is requiring a two-year rest after a fire. However, this 

requirement is totally false according to USDA research. Exhibit B -” Lance 

Vermeire, Challenging Taboos in Fire and Grazing Management, Soil and Water 

Conservation Society (2006).

Y

Thank your for your comment. 

Please see Chapter 3 Vegetation-Rangeland. The acre discrepancies will be 

corrected.

DRMTDK-BL13-0171-

11

Livestock 

Grazing

The reality is that the initial reduction in grazing is much larger than the reduction 

in livestock numbers that the BLM used to underpin its analysis. The DRMP 

provides for: Lass of 47,097 acres and up to 7,746 AUMs; The closing of 

allotments for sage-grouse; The closing of allotments for not meeting water 

quality standards; The reduction livestock grazing acres for Areas of Critical 

Environmental Concern; The reduction of livestock grazing acres for Wild and 

Scenic River Designation areas; The reduction of livestock grazing acres for 

n

The reduction of grazing varies little throughout the alternatives. Table 2-6.2 in 

the DRMP shows that: 1) 434,154 acres would available to livestock grazing 

under all alternatives. Total acres permitted for livestock grazing ranges 

between 386,092 acres and 387,057, similar to the current level of 387,057 

acres. The 47,097 acres of assumed loss described in the comment, likely 

includes the 9,522 acres of isolated parcels not included in allotments, the 

28,387 acres of Pryor Mountain Herd Area, and the 9,021 acres available for 
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Wilderness Study areas. These reductions were not properly analyzed under 

NEPA, as to required indirect and direct effects of this action. Furthermore, when 

the BLM analyzed the economic and social impacts of the DRMP/DEIS it did not 

use the actual, correct number in the plan for livestock grazing reductions. The 

BLM has violated NEPA, the TGA, FLMPA and the DQA due to its unlawful, 

arbitrary and capricious actions related to grazing.

prescriptive use. Currently these acres are closed to permitted livestock 

grazing; therefore there would be no loss of these acres. Additionally, under 

alternative C and D, 9,021 acres that are currently not permitted to livestock 

grazing could be opened to prescriptive grazing. 2) The 7,746 AUMs of 

assumed loss are the currently suspended AUMs. Under alternative B these 

AUMs would be maintained as suspended, Under alternative C these AUMs 

would be available for livestock grazing, and under alternative D BLM could 

adjust these AUMs, which includes the ability to make these AUMs available for 

livestock grazing based upon resource condition. 3) Under Alternative B, C, and 

D the BLM would consider the retirement of allotments wholly located within 

sage grouse PHMAs only if the base property owner relinquishes their 

preference. Based on historical grazing administration in the Billings Field 

Office, grazing preference is rarely relinquished. If current livestock use is 

compatible with sage grouse habitat requirements, BLM would have little basis 

to retire the allotment from grazing. 4) BLM is required under the federal 

grazing regulations 43 CFR 4180.2 to manage public lands to attain standards 

for rangeland health. Water quality is a standard of rangeland health (Standard 

#3 , Appendix I), however if livestock grazing is not determined to be a causal 

factor for this (or any) standard to be achieved, changes to livestock grazing 

management are not required. If livestock grazing is a causal factor, changes 

to management would be required; however closing an allotment would only be 

considered as a last resort option. 5) On table 2-6.2 9,021 acres of ACEC 

currently closed to permitted livestock grazing would be available to prescriptive 

grazing treatment. None of the other ACECs throughout the field office would 

be closed to livestock grazing in any alternative. 6) Table 2-6.2 does not show 

any reduction to livestock grazing from wilderness study areas or wild and 

scenic river designations, under any alternative. Additionally, on Table 2-6.3 

(Pg. 2-169 through 2-170) reduced or no grazing is not discussed in either the 

WSA or WSR sections. Therefore there is little reduction to grazing acres, or 

amounts. In fact the BLM has allowed discretion to authorize grazing over 

more acreage, than current management, with potentially more AUMs grazed. 

DRMTDK-BL13-0171-

12

Livestock 

Grazing

In 1934, Congress enacted the Taylor Grazing Act ("TGA"), "to provide for the 

orderly use, improvement, and development of the range." 43 U.S.C.§ 315(a). 

"One of the key issues the TGA was intended to address was the need to 

stabilize the livestock industry by preserving ranchers' access to the federal 

lands in a manner that would guard the land against destruction." Public Lands 

Council v. Babbitt, 167 F.3d 1287 (loth Cir. 1999). Additionally, the TGA requires 

that the BLM adequately protect grazing privileges. 43 U.S.C. §§ 315a, 

315b.Even though at first glance, the BLM indicates that grazing will continue at 

near current levels, a more detailed analysis indicates many instances where the 

BLM may negatively impact grazing under this DRMP. These instances include 

N

Thank you for your comment. 

Please see chapter 3 table 3-16. 

The BLM’s multiple-use mission and the BLM’s obligation to comply with the 

Federal Land Policy and Management Act of 1976 (FLPMA) and all other 

applicable laws, regulations and policies are addressed in Chapter 1 of the 

RMP/EIS.
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statements such as: "Allotments wholly located within sage grouse Habitat -” 

Priority Area habitat would be considered for retirement where the base property 

owner relinquished their preference." DRMP/DEIS at 2-116. "Areas with active 

surface disturbance (such as energy and mineral development, range 

improvements, wildfire, and prescribed fire) would be unavailable to livestock 

grazing." DRMP/DEIS at 4-157. "If standards are not being met, and grazing is 

a causal factor, management actions would be taken to make progress toward 

meeting the standard before the next grazing season." DRMP/DEIS at 2-119. 

Exhibit C -” Standards for Rangeland Health and Guidelines. Throughout the 

DRMP/DEIS the BLM has committed itself to meeting PFC water quality 

standards and to manage for aquatic habitat. "Areas with active surface 

disturbance would be unavailable to livestock grazing. The AUMs for these 

areas would be suspended during surface disturbance activities until at such 

time grazing would continue in a manner which supports the standards for 

rangeland health. DRMP/DEIS at 2-120. Based on the DRMP/DEIS, livestock 

grazing is not the reason for most issues related to water quality and watershed 

health. Therefore, closing allotments is not a solution and this language indicates 

that the BLM is just attempting to get rid of livestock grazing. The mandatory 

compliance with the Standards for Rangeland Health violates the very principal 

of the Standards, which provides that livestock grazing would not be changed 

unless grazing caused the non-compliance. Further, the Standards are meant to 

establish a process of analysis to progress towards meeting the Standards. The 

Standards are not meant to be a punitive way to get rid of livestock grazing. At 

L-1, the BLM sets up permit standards that in the future will cause every BLM 

grazing permit change to go through a NEPA analysis. This contradicts national 

laws and policy. These statements that could negatively impact grazing are in 

direct violation of the BLM's duty to adequately safeguard grazing under the 

TGA and FLMPA.

DRMTDK-BL13-0171-

13

Livestock 

Grazing

The Standards for Rangeland Health and Guidelines "provide the technical and 

scientific basis for measuring progress towards healthy and productive 

rangelands." Standards for Rangeland Health and Guidelines, Preamble. 

However, the DRMP requires the closing of allotments instead of making 

progress towards meeting the functions and conditions included within the 

Standards. Therefore, the DRMP is more restrictive than the Standards the 

DRMP is supposed to meet. This is arbitrary, capricious and unlawful.

N

Thank you for your comment. 

Please see Chapter 2 Livestock Grazing. The B&PPNM RMP/EIS does not 

have an alternative that includes closing of grazing allotments not 

meeting/making progress towards land health standards.

DRMTDK-BL13-0171-

15

NEPA, 

Livestock 

grazing

Furthermore, the DRMP's Guidelines overreach their proposed authority and 

impose a more stringent grazing management policy than required by the 

Federal environmental laws set forth in the Endangered Species Act. In fact, the 

only instance in which the Federal Government has used restrictive language as 

restrictive as the DRMP's ("should maintain or improve habitat for federally listed 

threatened, endangered, and special status plants and animals") is in a 

N Thank you for your comment. Comment outside the scope of the document. 
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handbook put out by the U.S. Fish and Wildlife Service, outlining consultation 

procedures under the Endangered Species Act. Even here, the standard 

suggested by the DRMP is referenced by the Government only in its Safe 

Harbor Agreements, and these are agreements in which Montana does not 

participate.

DRMTDK-BL13-0171-

16

NEPA

As mentioned earlier, NEPA requires that the BLM use best available science 

and quality data to make its decisions. City of Sausalito v. O'Neill, 386 F.3d 

1186, 1213 (9th Cir. 2004). Also, in addition to NEPA requiring the BLM to use 

best available science and quality data and to determine the impacts on the local 

culture and economy, the BLM is required to balance these impacts after it has 

done the initial analysis. Nowhere in the DRMP does the BLM attempt to explain 

how it is going to balance or coordinate these environmental impacts caused by 

the BLM's plan.

N

Thank your for your comment. Please see Chapter 4 for environmental 

consequences and impact analysis of the Proposed RMP.

DRMTDK-BL13-0171-

17

Travel mngt

The BLM is not supposed to increase or decrease the ability of Montana to 

manage fish and wildlife. However, in contrast to that stated goal, under the 

DRMP the BLM is planning to limit hunter and game warden ability for vehicular 

travel that allow hunters to reach big game hunting and fishing areas. If hunters 

cannot reach the game, they will not be able to harvest it, which means that 

Montana will be less able to manage the numbers of big game. The BLM has not 

considered how its transportation plan will negatively impact hunting. Access to 

game hunting areas is key to game harvest and retrieval in the rugged terrain of 

the areas included within the DRMP. In fact, promotion of public access to 

hunting is a top priority for the State's game management officials and continues 

to be a huge public interest issue in Montana.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

In specific response to the statement that BLM has not considered access for 

hunting purposes, please refer to Appendix O and numerous sections 

throughout the RMP which analyze the effects of vehicle routes being open or 

closed and also the inventory sheets for individual routes. 

DRMTDK-BL13-0171-

18

Wildlife 

Sage grouse within the area should be managed following the plan written by the 

State of Montana. Currently, since the sage grouse is not listed under the 

Endangered Species Act, the State of Montana has developed a sage grouse 

plan. The BLM's actions as listed in the DRMP do not follow the State's plan. 

While the Montana plan does suggest avoiding the placement of salt near leks 

during breeding season and avoiding supplemental winter feeding on crucial 

winter habitat, it does not go so far as to suggest conservative stocking levels to 

avoid concentrations of livestock. The DRMP should follow the 2005 

Management Plan and Conservation Strategies for Sage Grouse in Montana 

which recognizes that "properly managed grazing can stimulate growth of 

grasses and forbs, and thus livestock can be used to manipulate the plant 

community toward a desired condition." See 2005 Management Plan and 

Conservation Strategies for Sage Grouse in Montana at 55 (available at 

Doc.ht1?kl= n8 m ) (last accessed June 4, 2013).

n Thank you for your comment. 

DRMTDK-BL13-0171-

wildlife

The BLM based the DRMP on its 2011 National Technical Team Report ("NTT 

Report"), which is not based on best available science in violation of the ESA. 

Exhibit D -” Megan Maxwell, BLM's NTT Report: Best Available Science or a 

n

The NTT report is not the sole source of management decisions for the range of 

alternatives. A National Technical Team (NTT) was formed as an independent, 

science-based team to ensure that the best information about how to manage 
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19 Tool to Support a Pre-Determined Outcome? Northwest Mining Association 

(2013). The BLM's dependence on the NTT also violated the DQA and is 

arbitrary, capricious and unlawful. Further, it seems that the BLM is using the 

DRMP to justify the BLM's determination related to sage grouse that were made 

prior to the DRMP/DEIS analysis, which is a violation of NEPA

the greater sage-grouse is reviewed, evaluated, and provided to the BLM and 

the Forest Service in the planning process. The group produced a report in 

December 2011 that identified science-based management considerations to 

promote sustainable greater sage-grouse populations. The NTT is staying 

involved as the BLM and the Forest Service work through the Strategy to make 

sure that relevant science is considered, reasonably interpreted, and accurately 

presented; and that uncertainties and risks are acknowledged and documented. 

A baseline environmental report, titled Summary of Science, Activities, 

Programs, and Policies That Influence the Rangewide Conservation of Greater 

Sage-grouse (Centrocercus urophasianus) (referred to as the BER), was 

released on June 3, 2013, by the U.S. Geological Survey. The peer-reviewed 

report summarizes the current scientific understanding about the various 

impacts to greater sage-grouse populations and habitats and addresses the

location, magnitude, and extent of each threat. The BER does not provide 

management options. The report is being used by the BLM and the Forest 

Service in our efforts to develop regulatory mechanisms and improve our 

conservation efforts of the greater sage-grouse and its habitat to reduce the 

potential for listing it under the Endangered Species Act. The data for this report 

were gathered from BLM, Forest Service, and other sources and were the "best 

available" at the range-wide scale at the time collected. The report provides a 

framework for considering potential implications and management options, and 

demonstrates a regional context and perspective needed for local planning and 

decision-making.

In March 2012, the FWS initiated a collaborative approach to develop rangewide conservation objectives for the greater sage-grouse to inform the 2015 

decision about the need to list the species and to inform the collective 

conservation efforts of the many partners working to conserve the species. In 

March 2013, this team of State and FWS representatives, released the 

Conservation Objectives Team (COT) report based upon the best scientific and 

commercial data available at the time that identifies key areas for greater sagegrouse conservation, key threats in those areas, and the extent to which they 

need to be reduced for the species to be conserved. The report serves as 

guidance to Federal land management agencies, State greater sage-grouse 

teams, and others in focusing efforts to achieve effective conservation for this 

species.

The range of alternatives is based upon analysis of public scoping comments 

as well as information provided in the NTT report, the BER, the COT report, and 

State management plans. The alternatives represent different degrees of and 

approaches to balancing resources and resource use among competing human 

interests, land uses, and the conservation of natural and cultural resource 

values, while sustaining and enhancing ecological integrity across the 
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landscape, including plant, wildlife, and fish habitat. 

Greater sage-grouse conservation measures in A Report on National Greater 

Sage-grouse Conservation Measures (NTT 2011) were used to form BLM and 

the Forest Service management direction under at least one alternative 

(Alternative B and portions of Alternative D), which is consistent with the 

direction provided in BLM Washington Office Instruction Memorandum 2012-

044 (the BLM must consider all applicable conservation measures developed 

by the NTT in at least one alternative in the land use planning process). 

Additionally, all alternatives considered within this planning process are 

consistent with conservation measures and objectives outlined in the COT 

Report and follow the basic principles of: (1) avoiding the impact of an activity; 

(2) minimizing impacts by limiting the degree of activity; and (3) mitigating for an 

impact by improving or enhancing greater sage-grouse habitat. Each of the 

alternatives considers different means for accomplishing this strategy. For 

example, some alternatives place greater emphasis on avoidance of impacts, 

whereas other alternatives place more emphasis on minimization and 

mitigation.

While there was consistent direction provided in alternative develop, such as 

BLM WO IM 2012-044, variation across sub-regionals was needed to 

accommodate the local issues and specific state and Forest Service 

requirements.

DRMTDK-BL13-0171-2

Vegetation 

Invasive 

Species 

and 

Noxious 

Weeds 

 The BLM assumed that creating 3 mile buffers would benefit the resources. 

DRMP/DEIS at 2-79. However, the problem with a buffer zone is that those 

areas increase invasive species and weeds. This action could actually create a 

negative ecological impact.

n

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS.

DRMTDK-BL13-0171-

20

Wildlife 

Furthermore, as stated earlier in these comments, the BLM failed to conduct the 

necessary economic analysis to determine the impacts of sage grouse 

management on the local customs and culture, which is required by NEPA. Also, 

the BLM has not provided an adequate basis for its plans surrounding sage 

grouse leks so that the public could provide adequate comments. Again, there is 

a total lack of scientific basis and data as required by NEPA and the DQA. Also, 

much of the scientific data cited is very old and possibly irrelevant.

n

The requisite level of information necessary to make a reasoned choice among 

the alternatives in an EIS is based on the scope and nature of the proposed 

decisions. As the EIS analyzes land use planning-level decisions, which by their 

nature are broad in scope, the requisite level of data and information is more 

generalized in order to apply to a wide-ranging landscape perspective. Although 

the BLM realizes that more data, and more site specific data, could always be 

gathered, the baseline data utilized in the EIS provide the necessary basis to 

make informed land use plan-level decisions.

The BLM considered the availability of data from all sources, adequacy of 

existing data, data gaps, and the type of data necessary to support informed 

management decisions at the land-use plan level. The data needed to support 

broad-scale analysis of the BLM Billings planning area are substantially 

different than the data needed to support site-specific analysis of projects. The 
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RMP/EIS data and information is presented in map and table form and is 

sufficient to support the broad scale analyses required for land use planning.

Additionally, the BLM used the most recent and best information available that 

was relevant to a land-use planning-level analysis including the Baseline 

Environmental Report ([BER]; Manier et al. 2013). The BER assisted the BLM 

in summarizing the effect of their planning efforts at a range-wide scale, 

particularly in the affected environment and cumulative impacts sections. The 

BER looked at each of the threats to greater sage-grouse identified in the Fish 

and Wildlife Service’s “warranted but precluded” finding for the species. For 

these threats, the report summarized the current scientific understanding, as of 

the BER’s publication date (June 2013), of various impacts to greater sagegrouse populations and habitats. The report also quantitatively measured the 

location, magnitude, and extent of each threat. These data were used in the 

planning process to describe threats at other levels, such as the sub-regional 

boundary and WAFWA Management Zone scale, to facilitate comparison 

between sub-regions. The BER provided data and information to show how 

management under different alternatives may meet specific plans, goals, and 

objectives.

The BLM consulted with, collected, and incorporated data from other agencies 

and sources, including but not limited to the U.S. Fish and Wildlife Service, and 

the Montana Fish, Wildlife and Parks. Additional information provided by state 

and local governments regarding socioeconomics also support the analysis in 

Chapter 4. 

As a result of these actions, the BLM gathered the necessary data essential to 

make a reasoned choice among the alternatives analyzed in detail in the Draft 

RMP/EIS, and provided an adequate analysis that led to disclosure of the 

potential environmental consequences of the alternatives (see Chapter 4, 

Environmental Consequences and Cumulative Effects). As a result, the BLM 

has taken a “hard look,” as required by the NEPA (see 40 CFR 1502.16), at the 

environmental consequences of the alternatives in the Draft RMP/EIS to enable 

the decision maker to make an informed decision.

As noted in more detail in responses to issue statements identified elsewhere in 

the report, the BLM has complied with the myriad applicable laws, policies, and 

guidance in developing the RMP/EIS. Section 2.2, Developing the Range of 

Alternatives, of the RMP/EIS, states that all alternatives would comply with 

state and federal laws, regulations, policies, and standards, and implement 

actions originating from laws, regulations, and policies. Additionally, in Section 
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1.4.2, Planning Criteria, of the Draft RMP/EIS, the BLM has a criterion stating 

that all alternatives would comply with existing laws, regulations, and policies. 

The BLM has reviewed all actions in the Proposed RMP/Final EIS and found 

them to be consistent and within the bounds of all required laws, regulations, 

and policies. Further details regarding BLM compliance with state, county, and 

local plans and policies can be found in Section 1.5, Consistency with Other 

State, County, or Local Plans, of this report.A land use planning-level decision 

is broad in scope and, therefore, does not require an exhaustive gathering and 

monitoring of baseline data. Although the BLM and the Forest Service realize 

that more data could always be gathered, the baseline data provides the 

necessary basis to make informed land use plan-level decisions. Land use 

plan-level analyses are typically broad and qualitative rather than quantitative or 

focused on site-specific actions (BLM Land Use Planning Handbook H-1601-1, 

Chapter II, A-B at 11-13 and Chapter IV, B at 29; Forest Service Handbook 

1909.12 – Land Management Planning). The BLM and the Forest Service will 

conduct subsequent project-specific NEPA analyses for projects proposed for 

implementation under the land use plan, which may include but are not limited 

to fuels treatment, habitat restoration, [etc.; list others as applicable]. The 

subsequent NEPA analyses for project-specific actions will tier to the land-use 

planning analysis and evaluate project impacts at the appropriate site-specific 

level (40 CFR 1502.20, 40 CFR 1508.28). As required by NEPA, the public will 

have the opportunity to participate in the NEPA process for site-specific actions. 

A summary of Economic impacts is included in Ch.2, pgs. 196-199 and Ch.4, 

pgs.4-588-594(Social) and pgs. 4-594 to 4-628(Economic). The impacts were 

summarized for all wildlife. Specific sage-grouse management economic 

impacts are beyond the scope of this RMP.

DRMTDK-BL13-0171-

21

NEPA

The requirements imposed on state and county governments and private 

property owners by the DRMP violate the Unfunded Mandates Reform Act 

("UMRA"). 2 U.S.C.§ 1501 et seq. A federal mandate is defined as "any 

provision in legislation, statute, or regulation that would impose an enforceable 

duty upon State, local, or tribal governments" or which "would impose an 

enforceable duty upon the private sector." 2 U.S.C.§ 658(5)(A), (6), (7)(A). The 

DRMP is such a mandate. The DRMP would require ranchers to take additional 

actions to manage livestock grazing on lands covered by the DRMP, would 

impose a number of enforceable restrictions on natural gas operators, and would 

require additional services, such as county emergency services, to be provided 

by local governments. The UMRA requires that, "before promulgating any 

general notice of proposed rule-making that is likely to result in promulgation of 

any rule that includes any Federal mandate that may result in the expenditure by 

State, local, and tribal governments, in the aggregate, or by the private sector, of 

N Thank you for your comment.
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$100,000,000 or more (adjusted annually for inflation in any 1 year)," the agency 

must prepare a written statement assessing the qualitative and quantitative costs 

and benefits on State and local governments and the private sector. 2 U.S.C. § 

1532(a)(2). This assessment must include the extent to which Federal financial 

assistance is available to carry out the mandate. Id.

DRMTDK-BL13-0171-

22

Social/econ

For the reasons recited previously, the agency has failed to adequately outline 

the quantitative and qualitative economic impacts on the private sector. Similarly,

the economic analysis is completely void of any quantitative or qualitative costs 

and benefits to the State and local governments from imposition of the DRMP. 

The economic analysis section does note that the costs of managing the area 

may change under the RMP; however, there is no assessment of any impact to 

State or local governments. Clearly, this fails to meet the requirements of the 

UMRA.

n

The URMA addresses unfunded mandates imposed on state, local, and tribal 

governments by the federal government. The decisions to be made under the 

RMP may affect revenue from federal activities, but it would not impose costs 

on state and local governments. The decisions to be made under the plan 

would apply only to federal lands. A change in revenue from federal activities is 

not equivalent to an unfunded mandate. Furthermore, the economic analysis 

addresses the economic consequences of federal payments to states and 

counties on pg. 4-605 of the DEIS. 

DRMTDK-BL13-0171-

23

Social/econ

The UMRA additionally requires that the agency estimate the future costs of 

complying with the federal mandate, as well as any disproportionate budgetary 

effects upon State or local governments or particular segments of the private 

sector. 2 U.S.C. § 1532(a)(3). Nowhere in the DRMP does the BLM provide such 

an estimate. As stated in the section on economic analysis, the costs of 

complying with the DRMP would significantly impact the local tax base (due to 

decreases in ranch values, decreased revenue from natural gas operations, and 

a decrease in the tax base due to BLM land acquisitions). This would, in turn, 

significantly impact local communities, and particularly school districts, whose 

budgets are already struggling to meet the requirements of the No Child Left 

Behind Act. Furthermore, the BLM failed to provide an analysis of the budgetary 

impact to local communities from having to provide increased emergency 

services on the DRMP lands. The Act further requires the agency to provide a 

description of the extent to which the agency has consulted with elected 

representatives of State, local, and tribal governments, a summary of the 

representatives' comments and concerns (submitted either orally or in writing), 

and the agency's evaluation of those comments and concerns. 2 U.S.C. § 

1532(a)(5).Finally, the UMRA requires that the BLM "enable officials of affected 

small governments to provide meaningful and timely input in the development of 

regulatory proposals containing significant Federal intergovernmental mandates" 

and "inform, educate, and advise small governments on compliance with the 

requirements." 2 U.S.C. § 1533(a). While the county governments were included 

as cooperating agencies in the development of the DRMP, the BLM has 

completely ignored the concerns of these local governments, thereby preventing 

them from providing meaningful input into the process. For example, the BLM 

ignored a request for more time for the public to provide comments on the 

DRMP.

N

Thank you for your comment.

See Chapter 3, Socioeconomics for the description of social, economic and 

environmental justice conditions and trends and the description of social, 

economic and environmental justice impacts in Chapter 4, under those 

sections, which describes changes in employment, income, in various private 

sectors and changes to social conditions. The Annual Average BLM Revenues 

and Payments to State and Counties table shows impacts to public revenues to 

state and counties. No public comment period extensions were granted.

DR- Social A. The BLM Failed to Comply With Intergovernmental Cooperation Act The N Thank you for your comment.
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MTDK-BL13-0171-

24

/econ Intergovernmental Cooperation Act ("ICA"), 31 U.S.C.§§ 6501-6506, and 

companion Executive Order 12372, require all federal agencies to consider local 

viewpoints during the planning stages of any federal project. 31 U.S.C. § 

6506(c). The obligation of the BLM to consider local government concerns is a 

legally enforceable right. City of Waltham v. United States Postal Service,, 11 

F.3d 235, 245 (1st Cir. 1993). Injunctive relief is available in those cases where 

the federal agencies have failed to comply with the ICA. City of Rochester v. 

United States Postal Serv., 541 F.2d 967, 976 (2nd Cir. 1976). The 

consideration of local government plans and policies must occur on the record. 

Federal agencies have an affirmative duty to develop a list of factors which 

support or explain an agency's decision to act in disharmony with local land use 

plans. Village of Palatine v. United States Postal Serv.., 742 F. Supp. 1377, 

1397 (N.D. Ill. 1990).B. The BLM Failed to Comply With the Regulatory Flexibility 

Analysis Requirement The Regulatory Flexibility Analysis Act, 5 U.S.C. § 601 et 

seq., requires the BLM to perform an analysis on whether the approach outlined 

in the DRMP is the most flexible necessary to meet the goals. This analysis has 

not been done, which means the public, including my clients, have not had the 

opportunity to comment based on legally mandated analysis by the BLM.C. The 

BLM Failed to Provide a Small Business Regulatory Enforcement Fairness Act 

Analysis Pursuant to 5 U.S.C. § 804(2), the BLM was supposed to determine 

whether the DRMP would negatively impact small businesses in the area. This 

analysis was not done. D. The BLM Failed to Comply with the Executive Order 

Requiring Regulatory Planning and Review Executive Order 12866 requires the 

BLM to have the Office of Management review all significant rules and 

regulations. This analysis has not been done. E. The BLM Failed to Provide an 

Energy Effect Analysis Executive Order 13211 requires that the BLM analyze 

how this DRMP would impact energy needs in the United States. This analysis 

has not been done. F. The BLM Failed to Provide a Federalism Analysis 

Executive Order 13132 requires that the BLM provide a federalism analysis. This 

analysis has not been done. G. The BLM Failed to Provide a Civil Justice 

Reform Analysis Executive Order 12988 requires that the BLM analyze the 

impact of the DRMP on civil justice. This analysis has not been done. H. The 

BLM Failed to Provide an Environmental Justice Analysis The 8 rural counties in 

Montana impacted by the DRMP have some of the oldest and poorest people 

per capita in Montana. The economy of this area is dependent upon harvesting 

natural resources and the meager PILT payments that these counties receive. 

These communities are low-income and would suffer from disproportionate 

negative impacts due to the DRMP. Executive Order 12898 requires the BLM to 

analyze the impact of the DRMP on low-income citizens. As found in the DRMP, 

many of those in the area impacted by the DRMP are lower income citizens. The 

BLM has not done the necessary analysis on how the DRMP negatively impacts 

See chapter 1 for list of compliance with various plans, laws, etc. See Appedix 

A for list of laws, acts, BLM manuals and handbooks this document is in 

compliance with.

See Chapter 3, Socioeconomics for the description of social, economic and 

environmental justice conditions and trends and the description of social, 

economic and environmental justice impacts in Chapter 4, under those 

sections, which describes changes in employment, income, in various private 

sectors and changes to social conditions. The Annual Average BLM Revenues 

and Payments to State and Counties table shows impacts to public revenues to 

state and counties. No public comment period extensions were granted.
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those people, as required. I. The BLM Failed to Provide a Takings Analysis 

Executive Order 12630 requires that federal government actions which may 

result in a taking of private property must undergo a takings analysis prior to 

implementation. Executive Order 1263o, 62 Fed. Reg. 48, 445 (Governmental 

Actions and Interference with Constitutionally Protected Property Rights (1988)) 

(stating that "governmental actions that may have significant impact on the use 

of value or private property should be scrutinized to avoid undue or unplanned 

burdens on the public.") The BLM has failed to complete a takings analysis. J. 

The BLM Has Violated the National Historic Preservation Act Pursuant to this 

Act, 16 §§ 470-470x-6, the BLM was supposed to consult with the local 

governments impacted to determine whether the DRMP would adversely affect 

historic property. This consultation has not occurred. K. The BLM Has Violated 

the Soil and Water Resources Conservation Act Pursuant to this Act, the BLM 

was supposed to coordinate with local governments. See 16 §§ 2003(b), 2008. 

As already explained, the BLM has failed to adequately coordinate with local 

governments. L. The BLM Has Violated the Resource Conservation Act of 

1981Pursuant to this Act, 16 U.S.C. § 3451 et seq., the BLM was supposed to 

coordinate with local governments. As already explained, the BLM has failed to 

adequately coordinate with local governments .M. The BLM Has Violated the 

Regulatory Planning and Review Requirement Executive Order 12866 states 

that, "[the American people deserve a regulatory system that works for them, not 

against them: a regulatory system that protects and improves the health, safety, 

environment, and well being and improves the performance of the economy 

without imposing unacceptable or unreasonable costs on society; regulatory 

policies that recognize that the private sector and private markets are the best 

engine for economic growth; regulatory approaches that respect the role of state, 

local and tribal governments; and regulations that are effective, consistent, 

sensible, and understandable." Pursuant to this Executive Order, the agencies 

were supposed to seek input from local governments, minimize the regulatory 

burdens, and harmonize federal regulatory actions with related state, local and 

tribal regulatory functions. Again, the BLM has not met the requirements in this 

Executive Order.

DRMTDK-BL13-0171-3

Livestock 

grazing

 Throughout the DRMP (DRMP/DEIS at 2-14; 4- 37, 42, etc.), the whole plan 

seems to be to get rid of livestock grazing, which will only increase the dead 

vegetation that will lead to hot fires. Hot fires kill big sagebrush. The BLM states 

that big sagebrush is sage grouse habitat. Therefore, it is the BLM who has 

failed to analyze the direct and indirect ecological effects of the DRMP.

n

Thank you for your comment. "Removal of livestock grazing from public lands 

has not be considered in detail in the DRMP/DEIS. In fact on pages 2-12 

through 2-14 of the DRMP, it is stated that this alternative was not considered 

because it does not meet the purpose and need of the RMP/EIS. In addition in 

table 2-6.2 (pg 2-117 through 2-120 of the DMRP) the acres permitted to 

livestock grazing across all alternatives (A through D) vary by 965 acres across 

the entire field office. This represents less than 1% of the public surface acres 

managed by the BLM Billings Field Office. Due to the minimal difference in 

acres permitted to livestock grazing between alternatives, an analysis of the 
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effects of removal of grazing, vegetative buildup, fire frequency, fire intensity, 

and sage brush mortality was not analyzed"

DRMTDK-BL13-0171-4Livestock 

grazing, 

social/econ

Examples of the BLM's failure to analyze the direct and indirect historic, cultural, 

economic, and social effects: The BLM plans on cutting 47,097 acres and 7,746 

AUMs from livestock grazing use. However, there is inadequate or no review, 

analysis, or research on how this drastic cut in livestock grazing will impact the 

cultural, economic and social effects. Further, this area has been used for 

livestock grazing for more than 120 years, which would mean that the cut in 

livestock grazing would also have a negative effect on the historic use of the 

area. DRMP/DEIS at 2-117, 2-13.

n

Thank you for your comment. 

The reduction of grazing varies little throughout the alternatives. Table 2-6.2 

(pg 2-116 through 2-120) shows that: 1) 434,154 acres would available to 

livestock grazing under all alternatives. Total acres permitted for livestock 

grazing ranges between 386,092 acres and 387,057, similar to the current level 

of 387,057 acres. The 47,097 acres of assumed loss described in the 

comment, likely includes the 9,522 acres of isolated parcels not included in 

allotments, the 28,387 acres of Pryor Mountain Herd Area, and the 9,021 acres 

available for prescriptive use. Currently these acres are closed to permitted 

livestock grazing; therefore there would be no loss of these acres. Additionally, 

under alternative C and D, 9,021 acres that are currently not permitted to 

livestock grazing could be opened to prescriptive grazing. 2) The 7,746 AUMs 

of assumed loss are the currently suspended AUMs. Under alternative B these 

AUMs would be maintained as suspended, Under alternative C these AUMs 

would be available for livestock grazing, and under alternative D BLM could 

adjust these AUMs, which includes the ability to make these AUMs available for 

livestock grazing based upon resource condition.

Because the “assumed cuts” would be of little change compared to current 

management, and the fact that currently closed areas could be open to 

prescriptive grazing, a detailed review or analysis of impacts to cultural 

resources, economics, or environmental justice.

No net change in AUMs is expected in the decision area as a result of any of 

the alternatives, as stated on pg. 4-472 of the DEIS. More AUMs are permitted 

than are in use, therefore, the suspension of 7,746 AUMs would not reduce 

actual livestock grazing in the field office area. The DEIS analyzes the 

employment and income consequences of grazing, by alternative, on pg. 4-605 

of the DEIS. The livestock grazing analysis uses the best available information 

from BLM grazing permits and a peer-reviewed method of estimating 

employment and income associated with livestock grazing, as described on pg. 

4-595 of the DEIS. The social analysis addresses the heritage values of 

ranching on pg. 4-589 of the DEIS.

DRMTDK-BL13-0171-5

Social/econ

Some of the farmers and ranchers with private land included in the DRMP are 

third and fourth generation farmers and ranchers, and many others have lived in 

the area the majority of their lives. The proposed management plan will impact 

these people's ability to make a living, thereby destroying the ranching culture of 

the area. The limited access will also preclude them from enjoying their 

traditional family activities. The area included with DRMP includes counties with 

a declining population and tax base, and an older, more poverty stricken 

n

No net change in AUMs is expected in the decision area as a result of any of 

the alternatives, as stated on pg. 4-472 of the DEIS. More AUMs are permitted 

than are in use, therefore, the suspension of 7,746 AUMs would not reduce 

actual livestock grazing in the field office area. The DEIS analyzes the 

employment and income consequences of grazing, by alternative, on pg. 4-605 

of the DEIS. The livestock grazing analysis uses the best available information 

from BLM grazing permits and a peer-reviewed method of estimating 
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population. Additionally, as the tax base and tax revenues dwindle, funding to 

the local schools will dwindle, which will also hinder these families' ability to raise 

their children in the area. The BLM should have taken the required steps to 

preserve the cultural heritage of ranching in the area covered by the DRMP.

employment and income associated with livestock grazing, as described on pg. 

4-595 of the DEIS. The social analysis addresses the heritage values of 

ranching on pg. 4-589 of the DEIS.

DRMTDK-BL13-0171-5

Social/econ

Some of the farmers and ranchers with private land included in the DRMP are 

third and fourth generation farmers and ranchers, and many others have lived in 

the area the majority of their lives. The proposed management plan will impact 

these people's ability to make a living, thereby destroying the ranching culture of 

the area. The limited access will also preclude them from enjoying their 

traditional family activities. The area included with DRMP includes counties with 

a declining population and tax base, and an older, more poverty stricken 

population. Additionally, as the tax base and tax revenues dwindle, funding to 

the local schools will dwindle, which will also hinder these families' ability to raise 

their children in the area. The BLM should have taken the required steps to 

preserve the cultural heritage of ranching in the area covered by the DRMP.

n

No net change in AUMs is expected in the decision area as a result of any of 

the alternatives, as stated on pg. 4-472 of the DEIS. More AUMs are permitted 

than are in use, therefore, the suspension of 7,746 AUMs would not reduce 

actual livestock grazing in the field office area. The DEIS analyzes the 

employment and income consequences of grazing, by alternative, on pg. 4-605 

of the DEIS. The livestock grazing analysis uses the best available information 

from BLM grazing permits and a peer-reviewed method of estimating 

employment and income associated with livestock grazing, as described on pg. 

4-595 of the DEIS. The social analysis addresses the heritage values of 

ranching on pg. 4-589 of the DEIS.

DRMTDK-BL13-0171-6

WSR, WSA

The relevant information or impacts that the BLM failed to consider include but 

are not limited to: the historical and current information detailing the cultural 

heritage of ranching in the impacted area; the impacts of layers and layers of 

regulation (Wild and Scenic River designation, Wilderness Study Area 

designation, the National Historic Trails designation, and so on) that already 

exist and which all negatively affect the historic, cultural, economic, and social 

environment attached to the area; the DRMP limits all pipelines, phone lines, 

cell towers, electrical lines, and the like; but, there is no analysis of these 

limitations and their impact on local communities and economies. Furthermore, 

this exclusion forces all such linear projects on to private land without an 

adequate cumulative impacts analysis.

n

Thank you for your comments. In response specifically to your concern of 

layers and layers of regulation, the Federal land management agencies are 

guided in their management by a number of factors, including Acts of Congress, 

such as FLPMA, the Wilderness Act, the Wild and Scenic Rivers Act, etc. 

These Acts were passed by Congress, signed by a President of the United 

States of America, and are intended to benefit the entire peoples of this 

country, as well as protecting and enhancing those features which the people 

cherish and appreciate. The BLM only implement public law decisions. In many 

cases, the decision to designate a portion of federal lands will also benefit the 

surrounding communities. These intentions are found in the enabling 

legislations of the various Acts. 

The DEIS addresses the economic consequences of land and realty decisions 

on pg. 4-598 and pg. 4-602 of the DEIS. The analysis of existing regulations are 

outside the scope of this analysis. An analysis of community-level effects of 

linear projects is not possible in the RMP due to the programmatic level of the 

decision. Site-specific analysis will occur when particular projects are proposed. 

Such analyses will address effects to local communities and economies.

DRMTDK-BL13-0171-7

Social/econ

There are instances where the alternatives could affect grazing. DRMP/DEIS at 

However, the DRMP/DEIS makes no attempt to quantify any potential impacts to 

grazing. Equally important, the DRMP/DEIS does not provide any sort of 

comparison of the economic costs among the alternatives with regard to the 

impacts on grazing. The economic analysis shows economic impacts from 

natural gas exploration and development. However, the BLM still has not 

provided any analysis quantifying the potential impacts to ranching.

n

No net change in AUMs is expected in the decision area as a result of any of 

the alternatives, as stated on pg. 4-472 of the DEIS. More AUMs are permitted 

than are in use, therefore, the suspension of 7,746 AUMs would not reduce 

actual livestock grazing in the field office area. The DEIS analyzes the 

employment and income consequences of grazing, by alternative, on pg. 4-605 

of the DEIS.

DRMTDK-BLSocial/econ Furthermore, it is widely recognized that grazing permits have value which is 

capitalized into the value of a ranch. L. Allen Torell & John P. Doll, Public Land n

Opinion: Response: No text revision necessary (Thanks for the comment. 

Resource outputs are the amount of a resource (e.g., AUMs, recreation visits, 
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13-0171-8 Policy and the Value of Grazing Permits, 16 W. J. AG. ECON. 174, 175 (1991). 

Increasing restrictions on livestock grazing on the Federal Allotments decreases 

the value of the permit, and thereby the value of the ranch to which the permit is 

attached which, in turn, could impact property tax values. Moreover, the 

preference right itself is often subject to taxation. Frank J. Falen & Karen BuddFalen, The Right to Graze Livestock on the Federal Lands: The Historical 

Development of Western Grazing Rights, 30 Idaho L. Rev. 505, 511 (1993-

1994). A decrease in the value of the preference right will therefore decrease the 

amount of taxes that are generated.

tons of locatable minerals, etc.) that would be available for use under each 

alternative. Resource specialists projected annual resource outputs based on 

the best available information and professional judgment. Based upon public 

comments, resource specialists have reviewed assumptions used in this 

analysis to see if they need to be changed or updated. These revised 

assumptions have been incorporated into the analysis contained in the DEIS. 

The purpose of the economic analysis is to compare the relative impacts of the 

alternatives and should not be viewed as absolute economic values. Previous 

modeling experience has shown that the data contained in the IMPLAN 

modeling system for the various sectors are accurate representations of 

impacts. )

DRMTDK-BL13-0171-9

Social/econ

In summary, the BLM's economic analysis is deficient because it provides no 

data to indicate that the BLM actually did any analysis showing the impact that 

the alternatives would have on ranching, local communities, towns or the other 

individuals impacted by the DRMP. While acknowledging that the various 

alternatives could increase costs or reduce income to ranchers, the BLM makes 

no attempt to quantify these costs, or even to provide a comparison of the 

relative costs associated with implementing different alternatives. Also, much of 

the data added in the DRMP is not on point, is speculative, is not timely and 

provides no detailed economic analysis of the specific impacted area. Clearly, 

the BLM has failed to follow NEPA's requirement to "assess and discuss the 

secondary [socio-economic] effects of the project in question."

n

The IMPLAN data are comprehensive - it includes data from both metropolitan 

and non-metropolitan areas. It is neither feasible nor desirable to conduct 

economic impact analyses on very small scales (e.g., zip code level) due to the 

economic linkages between communities. A small-scale IMPLAN analysis 

would fail to capture the labor and trade flows between communities and the 

economic consequences would be underestimated. As a result, consequences 

particular to small communities are addressed in the social analysis. The social 

analysis addresses environmental justice considerations on pg. 4-590, which 

describe the potential for disproportionately adverse effects on low income 

individuals and communities.

DRMTDK-BL13-0172-1

Realty, 

Cadastral 

Survey, and 

Lands

These comments are submitted in behalf of three landowners in the Custer 

Montana area: Junction City Ranch Co ("JCR"), Allen Creek Ranch (owned by 

its founder George Larsen together with Russ Waddington, and referred to as 

"Larsen"), and the Gordon Plotts and Richard Swanson Ranch ("Plotts and 

Swanson") and concern the following described public lands, administered by 

the Bureau of Land Management, and located in Yellowstone County, State of 

Montana ("BLM lands");: Township 5 North Range 33 East Section 12: NE 1/4 

and S 1/2 These BLM lands are dry-land grazing lands situated within a larger 

private pasture enclosed by a barbed wire perimeter fence. The BLM lands are 

surrounded on all sides by privately held lands, without access by public roads 

or rights of way. The three land owners join in requesting that the described BLM 

lands be reclassified as "Category III: Disposal lands" pursuant to Section 3.19.1 

Land Tenure Adjustments and Access of the Draft Resource Management Plan. 

Sale of these lands is justified because they have low resource value, and are 

isolated and fragmented from other public land ownerships, making them difficult 

and uneconomic for the BLM to manage. Attached is a topographic map of the 

area in question including the private pasture identified as "East Pasture". The 

East Pasture includes about 8 sections owned by JCR and 1 1/4 sections owned 

by Larsen. Plotts & Swanson Ranch owns the allotment rights to the Section 12 

n

Thank you for your comment. Text has been edited in response to your 

comment.
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BLM land, and has subassigned their rights in the NE 1/4 to Larsen and the S 

1/2 to JCR. Plotts & Swanson, Larsen and JCR own additional abutting land 

interests outside of the East Pasture, and have an agreement that if and when 

these BLM lands are offered for sale and are purchased by any of them, 

subsequent transfers would be made between themselves so as to refigure 

ownerships and increase the efficiencies of each of their respective operations.

DRMTDK-BL13-0174-1

ACEC, Fire 

Mngt

The BLM ownership in the Grove Creek area is greatly interspersed with private 

lands. Some of these private lands are mine. This is the exact wrong place to let 

natural fires burn and the exact wrong place to not fight fires with equipment. In 

fact it would absolutely be negligent to allow a fire to burn or not stop it with the 

best tools available should it then burn on to private lands. We all know a small 

wildfire in eastern Montana is only one wind event away from being extremely 

large. A fire you let burn can be gone in an instant. I am going on record to say 

that should you chose to let a fire burn or not use equipment to stop it and it then 

burns on to my land, I will hold you responsible for damages in every way. You 

will have knowingly made a decision to not do everything (or anything) to have 

stopped it and once it burns my land your actions and decisions will have caused 

damage to my land. It's called negligence at that point. What about all the 

houses that are in the area? You can't just let fires burn in an area like this with 

so much interspersed private land and houses. You can't just let it burn. Even 

the National Park Service now realizes Let It Burn is a bad idea and isn't socially 

acceptable after 1988. Wouldn't a natural fire that is again one wind event away 

from a large wildfire also have negative effects to sage grouse and their habitat? 

An inevitable large wildfire that began as a natural fire that was left to burn or 

wasn't suppressed with equipment would destroy a lot of sagebrush and habitat 

in the core sage grouse areas. A large wildfire in this area would be bad for sage 

grouse and would have large negative effects to the species. You have not 

adequately analyzed for these inevitable negative effects. You will need to 

analyze for these very likely negative impacts to both private lands and sage 

grouse. At the current time the EIS is extremely inadequate for both.

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS. 

Please see table 2-6.3 Grove Creek

Please see Appendix E for the resource evaluation on this ACEC. Also please 

refer to FLPMA Sections 103, 201, and 202 for the direction which it provides 

regarding the high priority BLM is to give in the designation and management of 

ACECs. In response 

to your comment, the text in Alternative D for the Grove Creek ACEC of the 

Proposed RMP and Final EIS has been revised to state: Wildfire management 

(natural ignitions) for resource benefit. Full range of fire management activities 

would be used in ACEC in response to human-ignited fires. Use of heavy 

equipment and retardant would be avoided unless approved by authorized 

officer. 

DRMTDK-BL13-0176-1

Travel Mngt

RE: "Horsethief" management area I would like to recommend that a portion of 

this area be dedicated to "full sized" OHV use. There is a portion that would lend 

itself well to "rock-crawling". As the majority of BLM recreation users have 

specific areas to recreate in and also dedicated areas for hiking, biking, 

motorcycle riding, atv use, bird watching, and even "quiet areas", I ask the BLM 

to consider some areas for these individuals.

n

Thank you for your comments. The BLM has in the past requested additional 

information regarding the possibility of this area as a designated “rock crawling 

Area” but has not received additional information from the public to consider. A 

BLM staff review has not found a suitable area on public lands. 

DRMTDK-BL13-0176-2

Travel mngt

RE: Pryor Mtn. area I ask that you re-evaluate this area, specifically routes that 

you want to close. Many of these so called routes are listed as duplicate (going 

to the same destination), whereas the individuals who choose a specific route 

more than likely want to "experience the trip", more than "the destination". The 

"recreational touring", specifically utilizing a jeep or other full sized 4x4, consider 

n

Thank you for your comments. Based on yours and other comments the BLM 

has altered several of its decisions regarding Travel routes within the Pryor 

Mountains area, including route PM 1023, which is a route referenced. This 

route will be classified as open for all vehicle sizes. 
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what the BLM calls "bad roads" or "impassible" as Great routes. Please consider 

re-evaluating your routes and possible classifying them @ different levels or 

even just posting them as "extreme travel", travel at your own risk, may cause 

vehicle damage etc.. The switchback areas on the east slopes are a good 

example, these you have classified as ATV only, when they are passable with 

"jeep" type vehicles and also UTE's.

DRMTDK-BL13-0176-3

Travel Mngt

PM1023 is noted to have RS2477 designation, this route should defiantly remain 

open to "all" for recreation as well as travel purposes. I would also like to make a 

comment that there is a route between PM1017 and PM1024 that is still not 

marked (but appears on the map).

n

No regulations currently exist to either assert of recognize R.S. 2477 ROWs. It 

is beyond the scope of the RMP to recognize or reject RS 2477 assertions, and 

this issue is not addressed in the RMP. At such time as a decision is made on 

RS 2477 assertions, BLM will adjust its travel routes accordingly, if necessary. 

DRMTDK-BL13-0176-4

Travel Mngt PM1084; keep this open to access Forest Service routes and PM1079 to allow 

for that "different experiences" going up the mountain. n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

On a specific note, the routes in Stockman Canyon and Graham Canyon are 

designated as “open” in the RMP preferred Alternative

Purposes. Refer to map 146

DRMTDK-BL13-0176-5

Travel Mngt

In the Cottonwood/Weatherman area; CW2024 & CW 2025 Routes should 

remain open to gain hunting access to State lands, and also for vehicle exploring 

of the area.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

In regards to your specific comment regarding access to the Montana State 

Land Parcel, the RMP has a range of possible decisions. In this case, the 

decision to ensure adequate public access resulted in CW 1030, the proposed 

access route, being closed and CW 2024 being designated as “open” while CW 

2025 remains unchanged. 

DRMTDK-BL13-0179-1

Coal

BLM's revisions of the RMP are largely focused on sage-grouse conservation 

and the master leasing plan for oil and gas. However, since this is the first 

update of the RMP in almost 30 years, and it is intended to guide land use 

decisions for the next 20 years, BLM should update the coal information and 

management objectives within the resource planning area. In Chapter 1, the EIS 

states a management objective to "recognize the nation's need for domestic 

sources of minerals, food, timber and fiber, and incorporate requirements of the 

Energy Policy and Conservation Act (EPCA) Reauthorization of 2000." Draft 

RMP/EIS at 1-5. This plan falls short of meeting that objective. BLM has not 

considered new technologies, economics and information on coal development 

potential in the area and simply evaluates the coal exploration and development 

in terms of existing condition. Further, BLM has defined an alternative that 

contradicts the requirements of EPCA by proposing (in Alternative B) to close all 

N

Thank you for your comment. The B&PPNM RMP/EIS did not consider a 

Master Leasing Plan (see section 1.4.1.3). 

The possibility that future coal leasing may be associated with in-situ coal 

gasification and coal to liquids type projects was added to the text.

Alternative B is just one of the alternatives in the range of alternatives analyzed. 

Alternative D is the Preferred Alternative. 

The discussion of the coal resources in the planning area has been enhanced 

and moved from Appendix M to Chapter 3. 
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of the resource area to coal leasing, except for that area which has been leased. 

As discussed further below, this RMP/EIS should realistically evaluate the 

potential for exploration and development of coal over the life of the RMP.

DRMTDK-BL13-0179-

10

Coal, 

Social/econ

B. Economic Impact The Draft RMP/EIS significantly underestimates the positive 

economic impact that coal exploration and development has on local 

employment and economies. Id. at 4-601. As previously discussed, it is 

reasonable to assume that there will be considerable exploration within the life of 

the RMP, and that some economic coal deposits will be developed. At a 

minimum, the economic benefits of potential mine development, beyond the 

estimated 2,680 acres of federal mineral estate identified in the Draft RMP/EIS, 

should be evaluated.

N

Per requirements of NEPA as noted above, the DRMP/EIS provided analysis of 

the effects of each alternative’s actions on Coal. “Socioeconomic impacts and 

the method of analysis are described in Section 4.3.1 of the DRMP/EIS. For 

each alternative, the DRMP/EIS describes the impacts on the region’s natural 

gas production, regional housing, regional income, tax revenues, local 

government expenditures, population, housing, community stability and 

connectiveness, quality of life, and other social and community services. Under 

Alternative D, the pace of coal production and, therefore, the socioeconomic 

impacts, are expected to be very similar to Alternative A, the current 

management situation.

DRMTDK-BL13-0179-

11

Coal. 

Social/econ

VI. Impacts to Coal Aside from the inconsistent information regarding acres 

closed to coal leasing discussed above, the Draft RMP/EIS fails to provide any 

information regarding the impact of the RMP's other management direction on 

coal development. For instance, Alternatives B, C, and D would each impose 

significant sage-grouse conservation restrictions on solid mineral leasing. Table 

2-6.2 indicates that within sage-grouse protection priority areas and restoration 

areas coal mining would only be allowed via sub-surface methods and all mine 

related appurtenant facilities would be placed outside of the priority protection 

habitat. Id. at 2-100. Likewise, Appendix AB describes mitigation measures and 

conservation actions for greater sage-grouse habitat, including measures and 

actions required for solid minerals. See id. at AB-13-15. Those measures and 

actions have the potential to have significant impacts on solid mineral 

development. For instance, surface use would be subject to seasonal restrictions 

near active leks and crucial sagegrouse wintering areas. Id. at AB-14. The 

Appendix also includes a vague, open-ended requirement for off-site mitigation, 

such as habitat creation or acquisition of conservation easements. Id. at AB13.However, the Draft RMP/EIS provides no analysis of how those or other 

environmental restrictions would impact solid mineral leasing. The entire effects 

analysis is limited to (inconsistent) identification of areas closed to leasing and a 

discussion of the process for analyzing future coal leasing proposals. Id. at 4-

421. BLM should revise the RMP/EIS to explain the effects of the various 

management decisions in the alternatives on solid mineral leasing.

n

Per requirements of NEPA as noted above, the DRMP/EIS provided analysis of 

the effects of each alternative’s actions on Coal. “Socioeconomic impacts and 

the method of analysis are described in Section 4.3.1 of the DRMP/EIS. For 

each alternative, the DRMP/EIS describes the impacts on the region’s natural 

gas production, regional housing, regional income, tax revenues, local 

government expenditures, population, housing, community stability and 

connectiveness, quality of life, and other social and community services. Under 

Alternative D, the pace of coal production and, therefore, the socioeconomic 

impacts, are expected to be very similar to Alternative A, the current 

management situation.

DRMTDK-BL13-0179-

12

Coal

VIII. Appendix M -” Coal Resources In addition to the broader issues discussed 

above, GNP has specific comments on statements made in Appendix M 

regarding coal resources. In its background discussion, Appendix M does not 

mention the Carpenter coal bed. The Carpenter coal bed occurs 35 to 65 feet 

below the McCleary coal bed and is significant in the northeastern portion of the 

Bull Mountains coalfield." GNP conducted a substantial exploration drilling 

N

The development potential of the Carpenter seam in the Bull Mountain coalfield 

has been included. GNP’s exploration efforts in the Bull Mountain coalfield 

have been acknowledged.

The surface mining limit of the Mammoth seam has been readdressed.
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program in 2012, and the Carpenter bed was observed to be of consistent 

thickness and of greater areal extent than the McCleary coal bed. The Carpenter 

bed should be noted here as a coal bed of interest. Appendix M states that the 

Keene underground mine produced coal from the McCleary coal bed. Id. at M-2. 

However, according to the USGS, the Keene mine produced coal from the 

Roundup coal bed, not the McCleary coal bed.12 GNP agrees that there are 

approximately 604 million tons of Mammoth-Rehder coal amenable to surface 

mining and that these coal resources are about 90% recoverable. Draft RMP/EIS 

at M-3. The statement that surface mining be limited to a 1/4 to 3 /4 mile wide 

"strip" along the outcrop of the Mammoth-Rehder coal bed requires clarification. 

Draft RMP/EIS at M-3. The referenced figure M-4 clearly shows that the area 

containing the approximate 604 million tons of coal resources that are 

amendable to surface mining is significantly greater than 1/4 to 3/4 mile.11 See 

Woolsey, Richards, Ralph , Lupton, et all, "The Bull mountain coal field, 

Musselshell and Yellowstone counties, Montana", USGS Bulletin: 647, 1917, 

available at http://pubs.usgs.gov/bul/0647/report.pdf.12 Id. GNP agrees that 

there are more recoverable Mammoth-Rehder coal tons available through 

surface mining methods (544 million tons) than there are through underground 

mining methods (354 million tons). Id. However, the statement that nearly the 

entire Mammoth-Rehder coal bed may be developed through underground 

methods is in contradiction to the fact that Appendix M recognizes that more coal 

tons are recoverable through surface mining than through underground 

methods. According to the USGS, the Mammoth-Rehder coal bed is the thickest 

and most important in the Bull Mountains coal field.I3 Thus, utilization of both 

underground and surface methods will be necessary and appropriate to develop 

the entire Mammoth-Rehder coal bed. The reference to the "Carpenter Creek" 

bed, id. at M-4, requires clarification. Two coal beds of importance to both 

surface and underground development occur in the Carpenter Creek resource 

area: the Carpenter coal bed and the McCleary coal bed. GNP disagrees with 

the statement that only in the Bull Mountains coal field may federal coal be 

developed through surface mining methods. Id. at M-5. There are areas of 

shallow coal both north and south of the Bull Mountains coal field that may be 

amenable to surface mining methods. Suitability criteria should be separately 

analyzed on a site specific basis. Also, the Carpenter bed should be noted here 

as a coal bed of interest along with the McCleary bed. Appendix M states: 

"Surface owners of land overlying federal coal from both the Mammoth-Rehder 

and McCleary beds were consulted to determine their preference for or against 

leasing of their land for surface mining. The results of the consultation are shown 

in Table 2.3. Federal coal was found unacceptable for further consideration 

where the surface owners responded negatively to surface mining." Id. BLM 

should clarify that this consultation occurred in 1984 or earlier; there has been 

This statement has been removed from the text.

The surface and underground development potential of the McCleary and 

Carpenter seams have been added to the text.

Coal seams present in other coalfields within the planning area may have 

surface mine development potential. However, BLM does not have sufficient 

data to define those areas. It was also added that a surface minable resource in 

the Bridger seam may exist in the Joliet-Fromberg coalfield.

The date when the surface owner consultation was conducted was added to the 

text.

The development potential of the McCleary and Carpenter seams in the 

Carpenter and Lost Horse Creek drainages, and in the South Divide area was 

added to the text. BLM does not have the data to characterize the coal 

resources in the area west of Musselshell. 

The appropriate figures have been revised.

The coal screening process would be applied to lease applications that propose 

surface mine development.

The unsuitability criteria and citation have been revised.

The references to Appendices 2.4, 2.5, and 2.6 have been removed.

Surface mining limitations pertaining to overburden depths and stripping ratio 

limits have been removed from the text.
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no updated surface-owner consultation for this RMP planning effort. Also, Table 

2.3 does not exist in Appendix M. In Figure M-2, id. at M-7, the area that 

defines the "McCleary Coal Bed" should be expanded to the west to the town of 

Musselshell and to the northwest along the outcrop of the Carpenter coal bed. 

The Carpenter bed should also be mentioned here as a significant coal bed of 

interest for surface and underground mining. Appendix M states that "[t]here are 

9,360 acres of federal coal in the Bull Mountains found acceptable for further 

consideration for leasing, pending further study (see figures 2.1 and 2.2)." Id. As 

there are no figures 2.1 and 2.2 in the appendix, this is presumably a reference 

to figures 2.1 and 2.2 in the 1984 Record of Decision for the Billings RMP. BLM 

should (1) provide those figures in this document, (2) expand the areas identified 

as "areas found acceptable for further consideration, pending further study" in 

recognition that no recent surface-owner consultation has occurred, and (3) 

acknowledge that other areas may also be acceptable on a case-by-case basis 

after application of the coal screens future leases by application are consisting 

with the RMP direction.13 See Woolsey, Richards, Ralph , Lupton, et all, "The 

Bull mountain coal field, Musselshell and Yellowstone counties, Montana", 

USGS Bulletin: 647, 1917, available at http://pubs.usgs.gov/bul/0647/report.pdf. 

BLM cites to the 1981 version of unsuitability regulations found at 43 C.F.R. § 

3461.1. Id. at M-18. These regulations were revised in 1987, so BLM should 

update the citation and related text. Similarly, the references to Appendices 2.4, 

2.5, and 2.6, id. at M-19, are improperly carried over from the 1984 RMP Record 

of Decision. BLM should provide the information contained in those appendices 

in this RMP/EIS. Appendix M also states that "[d]ue to the lower economic 

feasibility of surface mining coal at depths greater than 100 feet (the moderate 

potential coal), resulting in larger surface acreage disturbances, it will be 

recommended to allow surface mining only with a maximum10:1 stripping ratio 

(high potential coal) limit." Id. at M-20. Since, as noted above, the economic 

viability of a potential surface mine depends on a variety of factors, in addition to 

overburden, it is inappropriate to use a blanket standard of 100 feet of 

overburden when determining the economic feasibility of surface mining. 

Likewise, GNP disagrees with the recommendation that a maximum 10:1 strip 

ratio be applied to potential surface mines in the Bull Mountains. A 10:1 strip 

ratio alone cannot determine the areas suitable for surface mining.

DRMTDK-BL13-0179-

13

Wildlife

The use of the broad habitat identifications in the RMP (see Maps 23, 24, and 

168) can provide a management framework for BLM, but site-specific studies, 

habitat delineations, and biologic surveys are needed to provide for a fair 

evaluation of a coal development proposal, the suitability of the area for mining, 

and development of potential mitigation measures. Prescriptive mitigation 

measures for any sage-grouse habitat do not provide allowances for creative, 

economic means of protecting the species. GNP supports the use of adaptive 

n

Thank you for your comment. The B&PPNM RMP/EIS is following the 

consistent management prescriptions and guidance for GRSG. In following the 

management prescriptions, please see Appendix AA (section F) for mitigation 

measures. The BLM and the Forest Service complied with the NEPA by 

including a discussion of measures that may mitigate adverse environmental 

impacts of the alternatives in the DRMP/EIS. See 40 CFR 1502.14(f), 

1502.16(h). Potential forms of mitigation include: (1) avoiding the impact 
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management techniques for sage-grouse mitigation. Alternatives B, C, and D 

propose to limit coal leasing in sage-grouse priority protection areas (PPAs) to 

sub-surface methods, with all mine related appurtenances outside the PPA. See 

id. at 2-100. GNP does not support this proposed management decision for two 

reasons. First, it ignores the coal resource potential in areas within and adjacent 

to the proposed PPAs without adequately analyzing the value or development 

potential of the resource. This is not consistent with federal energy policies. 

Second, the proposed stipulation does not take into account current and future 

technology advances for mining and mitigation potential within these areas, as 

well as potential site-specific analyses of proposed activities. Relying on sitespecific NEPA analyses, coal screening, and development of mitigation 

measures to ensure sage-grouse protection is more appropriate and consistent 

with BLM's multiple-use mandate than blanket prohibitions. A more reasonable 

approach would be to require a sage-grouse management plan for any coal 

exploration or development proposals within the PPAs. Additionally, sage-grouse 

PPAs and restoration areas are adjacent to or interspersed with the lands not 

currently managed by BLM, and are part of the GNP checkerboard mineral rights 

holdings in certain areas. It should be noted that unilaterally specifying these 

areas for special treatment for sage-grouse conservation effectively expands the 

management practices to these interspersed private sections, making them 

unavailable for development. GNP is willing to work with BLM to address sagegrouse management in these areas where the minerals and surface 

management is mixed, on a site-specific basis to ensure that there is a 

reasonable balance of resource management.

altogether by not taking a certain action or parts of an action; (2) minimizing 

impacts by limiting the degree or magnitude of the action and its 

implementation; (3) rectifying the impact by repairing, rehabilitating, or restoring 

the affected environment; (4) reducing or eliminating the impact over time by 

preservation and maintenance operations during the life of the action; or (5) 

compensating for the impact by replacing or providing substitute resources or 

environments. 40 CFR 1508.20. Taking certain is only one of many potential 

forms of mitigation. The BLM and the Forest Service must include mitigation 

measures in an EIS pursuant to the NEPA; yet the BLM and the Forest Service 

have full discretion in selecting which mitigation measures are most 

appropriate, including which forms of mitigation are inappropriate

DRMTDK-BL13-0179-

14

Coal 

GNP objects to recommended mitigation measures proposed for solid minerals 

that restrict surface use or disturbance. Id. at AB-14. BLM has proposed 

appropriate general criteria that are sufficient to protect the greater sage-grouse 

on an activity specific proposal: analysis of the habitat and population in a 

project-specific analysis, minimization of disturbance, incremental development, 

offsite mitigation as necessary, and appropriate reclamation and removal of 

redundant facilities. Because these general criteria provide a sufficient 

framework to ensure the conservation of the sage-grouse, there is no basis for 

the proposed restrictions that would require surface-use restrictions for solid 

mineral development. These proposed restrictions, as well as requirements for 

location of roads, pipelines, wells, and storage facilities, appear to be lifted out of 

the restrictions for fluid minerals and are not applicable to solid minerals. These 

restrictions ignore the basic difference in development of fluid and solid minerals 

and are not supportable

n

Thank you for your comment. Text in Chapter 2 – alternatives table - has been 

modified in chapter 2 – alternatives table to reflect coal leasing/mitigation 

measures.

DRMTDK-BL13-0179-

Coal 

While the Draft RMP/EIS pays little attention to coal development, it includes 

numerous provisions regarding oil and gas development. These provisions 

include areas closed to oil and gas leasing and various no-surface-occupancy 

n

The oil and gas lease terms (NSO, CSU, etc) apply specifically to Oil and Gas 

leasing and not to coal. Coal development, is subject to its own coal screening 

process
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15 (NSO) and controlled-surface-use (CSU) stipulations to protect sensitive 

resources. For instance, under Alternative D, "an estimated 357,536 acres of the 

decision area's federal mineral estate is administratively unavailable (No Lease) 

for oil and gas leasing or has major constraints (NSO, CSU)." Draft RMP/EIS at 

4-75. In the past, some BLM offices have interpreted oil and gas NSO and CSU 

stipulations as applicable to all mineral development, which is not consistent with 

the management direction of the land use plan. While taking no position as to 

whether these stipulations are or are not appropriate and/or necessary, because 

these stipulations are specific to oil and gas leasing, the RMP should expressly 

confirm that they are not applicable to coal leasing and development, which is 

subject to its own coal screening process.

DRMTDK-BL13-0179-2

Coal 

Future coal leasing beyond the current Signal Peak underground operation is 

likely within the time frame of this planning document due to an increasing 

international demand, particularly in Asia, for the type of high-quality steam coal 

found in the Bull Mountains. The availability of improved coal mining 

technologies currently allow extraction of coal to be conducted more efficiently 

than was possible at the time of the 1984 RMP. Indeed, in anticipation of 

continued strong off-shore demand for high quality steam coal, additional 

exploration has recently been undertaken in the Bull Mountains to further define 

coal development potential in the resource planning area. Thus, the RMP/EIS 

should be revised to anticipate an increase in coal leasing beyond the status 

quo. Significant coal exploration has been conducted by the private sector under 

the authorization of State of Montana prospecting permits, with potential for 

additional exploration under the Federal Coal Exploration License program. 

There is a substantial amount of public information available with which to 

update information about coal resources. Since this RMP planning process is 

intended to cover the foreseeable future of the resource area, the coal 

development potential within the planning area should be updated

N

The recent exploration activities conducted in the Bull Mountain coalfield have 

been acknowledged.

Information pertaining to the coal resources and their development potential in 

the planning area has been updated

DRMTDK-BL13-0179-3

Coal 

The Draft RMP/EIS only addresses the potential of conventional surface and 

underground (continuous miner and longwall) methods. Draft RMP/EIS at App. 

M. In expanding coal development potential, BLM should specifically consider 

(1) the impacts and improved economics of more efficient and improved mining 

techniques in connection with surface mining, which were not in use in 1984, (2) 

the potential for deployment of unconventional mining techniques-”such as the 

use of highwall mining techniques in connection with surface mining, the 

potential for underground coal gasification, coal beneficiation, and coal 

liquefaction-”which will enable development of some coal deposits previously 

considered to be uneconomic, and (3) the development and construction of 

mine-mouth coal gasification projects. Additionally, BLM should also 

acknowledge that these unconventional mining techniques have substantially 

less surface-disturbance impacts as compared to conventional surface mining

N

The possibility that future coal leasing may be associated with coal conversion 

projects has been added to the text.

The possibility that highwall mining may be incorporated in a surface mining 

scenario was added to the text.
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DRMTDK-BL13-0179-4

Coal 

In addition to underestimating coal development potential, BLM has vastly 

underestimated the demand for coal. There is a significant export demand for 

the high-quality (high-BTU) coal that exists in the Billings RMP planning area. 

The Energy information Administration (EIA) recently issued a report stating that 

"[c]oal exports from the United States in March 2013 totaled 13.6 million short 

tons, nearly 0.9 million short tons above the previous monthly export peak in 

June 2012. EIA is projecting a third straight year of more than 100 million short 

tons of coal exports in 2013, following annual exports in 2011 of 107.3 million 

short tons and record annual exports in 2012 of 125.7 million short tons. 

Increased Asian demand for coal contributed to the record level of coal exports 

from the United States in March."4 The coal reserves in Bull Mountains are well 

situated to respond to this demand because considerable infrastructure is in 

place, including a rail loop to facilitate surface mining. BLM must consider this 

increased export demand and how the existing Signal Peak Energy 

infrastructure provides an advantage to Bull Mountain reserves in that market 

when evaluating the likelihood of additional coal development. In addition, and in 

direct support of the significant coal export demand, several new coal export 

terminals in Washington and Oregon are in the process of being permitted and 

developed to facilitate the coal export market: SSA Marine's Gateway Pacific 

Terminal in Whatcom County, Washington; Ambre Energy and Arch Coal's 

Millennium Terminal in Longview, Washington; and Ambre Energy's Morrow 

Pacific Terminal at the Port of Morrow in Oregon.4 See U.S. coal exports set 

monthly record, http://www.eia.gov/todayinenergy/detail.cfm?id=11751 (June 19, 

2013).

N

Additional text has been added to reflect that coal being produced in the 

planning area is currently being exported.

Additional text has been added to reflect that future coal development in the 

planning area may increase as a result of the completion of coal export facilities 

on the west coast.

DRMTDK-BL13-0179-5

Coal

C. Map 47 -” Coal Development Areas BLM underreports the extent of the coal 

locations within the resource management area, as shown on Map 47. Fields 

within the Bighorn Basin of Montana contain some of the highest quality 

mineable coals in Montana. In particular, Red Lodge-Bearcreek, Bridger, and 

Silvertip coal fields in Carbon County should be added to Map 47 and identified 

as an area acceptable for further leasing consideration, pending further study. 

The area that defines the McCleary coal bed should be expanded to the west to 

the town of Musselshell and to the northwest along the outcrop of the Carpenter 

Seam. Also note that Map 47 (Coal Locations) and Map 2 (Federal Minerals) 

appear to be inconsistent. BLM should ensure that all federal coal identified on 

Map 47 should also be shown as federally owned minerals on Map 2.

N

Map No. 47 has been revised to reflect all areas where coal resources are 

managed by the BLM.

The development potential of the McCleary/Carpenter seams in the Carpenter 

and Lost Horse Creek drainages, and in the South Divide area was added to 

the text. BLM does not have the data to characterize the coal resource of these 

two seams in the area west of Musselshell. 

DRMTDK-BL13-0179-6

Coal

E. Northern Musselshell County GNP and BLM both have significant mineral 

ownership within northern Musselshell County, located north of the Bull 

Mountains coalfield. Though these areas have not experienced historic mining 

and are not well explored, the bedrock geologic maps' illustrate the presence of 

the coal-bearing Cretaceous Eagle and Judith River formations. As such, GNP 

requests that these areas be identified as "Coal Areas Acceptable for Further 

N

The BLM does not have the geologic data to evaluate the coal resources in the

Eagle and Judith River formations in northern Musselshell Co.

The coal screening process will be applied to future lease application areas.
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Consideration" or "Coal Areas Acceptable for Further Consideration and 

Pending Further Study" in the RMP, and that further exploration and potential 

development of these coal resources be included and analyzed in the Final 

RMP/EIS.

DRMTDK-BL13-0179-7

Coal

F. Big Horn Basin Coalfield, Carbon County, Montana Significant quantities of 

coal have been mined historically in Carbon and Stillwater counties, though no 

mining is currently taking place.6 The coals within this region are located in the 

Big Horn Basin of Montana and are principally contained within the Fort Union 

Formation.7 These are some of the highest-quality mineable coals in Montana 

with an apparent rank ranging from subbituminous to bituminous.8 Four distinct 

coalfields have been identified in the Montana portion of the Bighorn Basin, 

including (1) the Bridger (including Joliet/Fromberg), (2) Stillwater, (3) Silvertip 

(part), and (4) the combined Red Lodge-Bearcreek coalfield (formerly the Red 

Lodge coalfield). Draft RMP/EIS at 3-152, M-1-”M-2.5 Geologic Map, 

Musselshell 30'x60' Quadrangle, Open File MBMG 386, Plate 1 of 1, available at 

http://www.mbmg.mtech.edu/pdf 100k/musselshell.pdf.6 Draft RMP/EIS at 3-

152; 1999 Resource assessment of selected Tertiary coal beds and zones in the 

Northern Rocky Mountains and Great Plains region, U.S. Geological Survey 

Professional Paper 1625-A, available at http://pubs.usgs.gov/pp/p1625a/ 

(hereinafter USGS Professional Paper 1625-A).7 See USGS Professional Paper 

1625-A.8 Id. Though no current mining is taking place in this region, there is 

significant recent and ongoing interest in developing underground projects in this 

region, including within the Red Lodge-Bearcreek coalfield. Beartooth Mountain 

Coal Company has published reports which clearly demonstrate the recent and 

current interest in underground mining.9 Further, a USGS assessment states 

"an evaluation of six coal beds, each greater than 4ft thick in the Bearcreek 

district, Rawlins (1986) estimates that total Fort Union coal reserves in the area 

may exceed 700 million tons."10 It further describes the high-quality 

characteristics of the coals of the area. GNP has significant coal holdings and 

interest in this area and believes that exploration and development of these 

coalfields is reasonably foreseeable within the RMP planning time frame.9 See 

http://beartoothmtncoal.com/mine/?page_id=100.10 See USGS Professional 

Paper 1625-A.

N

The text describing the coal development potential of the Red LodgeBearcreek/Joliet-Fromberg coalfields has been enhanced in the Chapter 2, 

Solid Minerals-Coal section.

Additional information has been incorporated into the text including material 

from the references that are mentioned here.

The following information was added to the text: “In late 2013, it was reported 

that a private company completed an exploration drilling program on nonfederal coal in the Bearcreek area.”

DRMTDK-BL13-0179-8

Coal

The Draft RMP/EIS provides inconsistent information regarding the areas that 

BLM is recommending as being closed to solid leasable mineral development. 

Table 2-6.2 (Detailed Table of Alternatives) and Table 4-25 (Total Acreage 

Recommended for Closure for Solid Leasable Mineral Development) indicate 

that the following acreages will be closed to coal leasing: Alternative A 29,466 

acres Alternative B 211,485 acres Alternative C 170,276 acres Alternative D 

200,539 acres ID. at 2-99, 4-421. However, several other places within the Draft 

RMP/EIS contradict these tables and state that the following acreages would be 

n Thank you for your comment. Text will be clarified in Chapter 2.
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closed to coal development: Alternative A 26,131 acres Alternative B 290,048 

acres Alternative C 264,450 acres Alternative D 280,971 acres See, e.g., id. at 

2-20 (Table 2-1), 4-89, 4-99, 4-165, 4-178, 4-255.BLM should clarify how many 

acres would actually be closed to coal leasing under each alternative. It should 

also provide a map that identifies, by alternative, where those closures would be 

located within the planning area. In light of these discrepancies and the inability 

to determine the actual impacts of each alternative on coal development, once 

this corrected information is available, BLM should provide additional opportunity 

for public comment.

DRMTDK-BL13-0179-9

Air 

The Draft RMP/EIS correctly reports that there have been no exceedences of air 

quality standards from the Signal Peak Energy mine. Id. at 4-25. However, the 

air quality analysis is based on an unrealistic assumption of no additional 

development beyond that mine. The analysis must be revised to include a 

complete analysis of reasonably foreseeable activities surrounding coal 

development. As previously noted, further exploration of coal reserves identified 

in the Draft RMP/EIS is probable within the life of this RMP. Much of the coal 

that will be further delineated in these exploration programs has potential for 

surface mining. Emissions from exploration and development of additional 

surface coal mines should be analyzed for all alternatives in the Final EIS. With 

respect to the BLM's proposal to require Tier 4 engines on diesel-powered drill 

rigs, id. at 4-11, GNP believes that such a requirement is inappropriate in the 

context of this RMP. Whether such extraordinary emission controls on 

equipment are necessary to protect air quality should be based upon modelpredicted impacts as they compare to applicable EPA established air quality 

standards and prevention of significant deterioration increments; BLM should not 

presume that such controls are necessary before their actual need is 

demonstrated. Additionally, in Montana, the Montana DEQ is charged with the 

monitoring and protection of air quality, including on federal surface, under the 

authority of its EPA-approved Clean Air Act program. GNP believes it is wholly 

inappropriate for BLM to arbitrarily impose stringent emission control 

requirements that may not be necessary for the protection of air quality. Where 

air quality will be protected without such extraordinary controls, they would only 

serve to unnecessarily increase the cost of production and perhaps create a 

barrier to entry for smaller operators. GNP encourages the BLM to defer to 

Montana DEQ as the appropriate agency for implementation of air quality 

protection programs in Montana and eliminate the blanket Tier 4 engine 

requirement.

Y

The coal RFD was the basis of the air resource analysis. See the Section 

4.1.1.3.1 for an explanation of Tier 2 versus Tier 4 modeled impacts. Also see 

the Section 1.5.3 of Appendix T for an explanation of the BLM’s authority to 

protect air resources. 

DRMTDK-BL13-0180-1

Travel mngt

2. Close Demijohn Flat route in the Pryors to motorized use. There is a culturally 

sensitive area here and motor vehicles would destroy it. Please make this a 

quiet non-motorized route for those who value the quiet and the history of this 

area. 3. In Bear Canyon in the Pryors please close the two track road that leads 

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 
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into the canyon. There are two other parallel routs in this area that provide motor 

routes for those that are too lazy to walk.

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Demi John Flat route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed to motorized vehicles” except for administrative purposes. This will 

not prohibit non-motorized use. 

Refer to map 146

DRMTDK-BL13-0182-1

Travel mngt 

Wild Horse Protection: Seasonal road closures -“ Motorized routes within the 

PMWHR would be designated according to the Pryor TMA. Burnt Timber Road 

from the East Pryor Mine (the abandoned uranium mine) to the USFS boundary 

and Sykes Ridge Road from the horse trap to USFS boundary would be closed 

to wheeled vehicles and motorized vehicles to protect wild horse foaling and 

their habitat (April 15 to June 15) providing consistency with the USFS seasonal 

closures.

n

Thank you for your comments. 

The BLM decision in the RMP is to protect the resources from degradation. 

BLM has been and intends to continue signing and rehabbing unauthorized 

vehicle routes throughout the FO and welcomes any assistance from any entity. 

BLM will be addressing many of the issues mentioned in the letter through a 

site specific Implementation Level Plan following the RMP. 

DRMTDK-BL13-0183-1

Coal 

BLM acknowledges that there are "Known coal resource areas with underground 

development potential are located in the Bull Mountains and in Carbon County" 

(p. 3-152). In addition to the resources with underground development potential, 

there is significant resource in the area with surface mining potential. Given 

BLM's directive to recognize and develop energy resources, this RMP should 

include and analyze the leasing of all surface minable resources in Bull 

Mountains, Carbon County and throughout the Resource Management Planning 

area. BLM should note that technologies such as highwall mining techniques 

enable access to more coal resources with higher stripping ratios than those 

previously considered by BLM, and mine economics can change significantly 

with market conditions.

N

BLM recognizes the existence of surface minable coal resources in the 

planning area. The coal screening process will be applied to future lease 

application areas that have surface mine development potential. The possibility 

that highwall mining may be incorporated in a surface mining scenario has been 

discussed. Stripping ratio limitations have been removed from the text.

DRMTDK-BL13-0183-2

Coal 

In its analysis of RMP alternatives, the BLM underestimates the potential for 

future development of coal by narrowly defining the reasonably foreseeable 

future as the continuing mining at the Signal Peak operations under current 

conditions. The analysis should be expanded to include considerations for 

expanded operation at the existing mine, additional exploration and potential 

leasing within a reasonable distance to the existing mine infrastructure and 

additional underground and surface mining new leases in all of the known areas 

of coal deposits.

N

Text has been added to reflect SPE’s recent coal exploration activities adjacent 

to its existing operation. Factors that may influence future coal development in 

the Bull Mountain coalfield were also discussed.

DRMTDK-BL13-0183-3

Coal 

Signal Peak Energy currently operates at a permitted rate of 15 million tons of 

coal produced per year - a rate that is used for the environmental analyses in 

this EIS. However, the infrastructure in place at the operation could 

accommodate a throughput of 60 million tons of coal per year without major 

construction at the coal load out. It is reasonable to expect that market 

conditions may sustain such a production increase within the life of the RMP. 

State permits e.g. air permits, would require demonstrations of compliance with 

n

Thank you for your comment.

Text has been added to reflect the role that SPE’s existing coal processing and 

rail infrastructure may have regarding future coal development in the Bull 

Mountain coalfield. 
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appropriate environmental standards if production rates increase. Site specific 

environmental evaluation of expansion at the site would be done by the state 

and, in the case of development of federal coal leases, by the BLM as well. 

These reasonably foreseeable conditions should be included in the Chapter 4 

analysis.

DRMTDK-BL13-0183-4

Social/econ

, Coal

Economic evaluations should also take into account future development of 

federal coal and expansion of Signal Peak operations. Currently, Signal Peak 

has 325 employees with an annual payroll of $39 million. Federal, state and local 

extractive taxes contribute an additional $40 million to the economy each year. 

With the addition of coal from Federal leases, additional employees may be 

added, and Federal lease payments will further contribute to the economy.

N

Chapter 4 currently states the following: The average annual federal coal 

leasing, production, tax, and royalty revenues related to BLM federal minerals 

are unknown at this time and would be determined based on whether the 

proposed Montana Federal Mineral Conveyance Act (HR 1158) passes in 

Congress. For analysis purposes, under all Alternatives, it is assumed that all 

federal coal is retained in federal ownership, and a coal lease sale covering 

2,680 acres of federal coal are leased, an annual average of 2.8 million tons of 

federal coal are produced over the life of the lease, and price per ton of coal in 

Montana is $18.11 (Energy Information Administration, 2012). Future coal 

leasing is uncertain due to lack of infrastructure (e.g., rail lines) near potential 

coal reserves and low international coal prices.

DRMTDK-BL13-0183-5

edits

BMPs for mineral exploration and development should be clarified to reflect that 

these relate to oil and gas exploration and development. Not all of the 

recommendations are appropriate for coal exploration or development.

n text has been modified in Appendix B to reflect your comment.

DRMTDK-BL13-0183-6

NEPA, 

wildlife 

The BLM proposes Mitigation Measures and Conservation Actions for Greater 

Sage Grouse Habitat. The recommended measures for solid minerals clearly do 

not reflect mining practices and appear to be more consistent with BLM's 

approach to development of fluid minerals. In describing its recommended 

practices for solid minerals, BLM appropriately recognizes the need to develop 

mitigation measures during activity level planning. Many of the recommendations 

for solid minerals are not appropriate, for a variety of reasons. First, coal is 

located where naturally deposited and recovery of coal must be done in an 

economically viable fashion where the coal is located. Location of surface 

disturbance and surface facilities may not be optional, particularly in the case of 

surface mining, and should only be evaluated on a site specific basis, not 

specified in a general BMP. While seasonal restrictions may be possible when 

using certain types of technologies e.g. coal gasification, it is inappropriate to 

unilaterally apply seasonal restrictions to solid mineral development without a 

clear recognition that the BLM is effectively withdrawing coal resources without 

the proper findings. Secondly, the BLM has erroneously attempted to apply strict 

BMP requirements proposed for fluid minerals development to solid minerals 

development without consideration of the nature of solid minerals extraction. 

Appendix AB includes BMPs for location of pipelines, roads and holding tanks -

facilities that are connected with fluid minerals management but are generally 

only incidental to mining. Surface mining is often the most economic means of 

recovery of solid minerals, including coal, and by nature does not lend itself to 

n

The BLM and the Forest Service complied with the NEPA by including a 

discussion of measures that may mitigate adverse environmental impacts of the 

alternatives in the DRMP/EIS. See 40 CFR 1502.14(f), 1502.16(h). Potential 

forms of mitigation include: (1) avoiding the impact altogether by not taking a 

certain action or parts of an action; (2) minimizing impacts by limiting the 

degree or magnitude of the action and its implementation; (3) rectifying the 

impact by repairing, rehabilitating, or restoring the affected environment; (4) 

reducing or eliminating the impact over time by preservation and maintenance 

operations during the life of the action; or (5) compensating for the impact by 

replacing or providing substitute resources or environments. 40 CFR 1508.20. 

Taking certain is only one of many potential forms of mitigation. The BLM and 

the Forest Service must include mitigation measures in an EIS pursuant to the 

NEPA; yet the BLM and the Forest Service have full discretion in selecting 

which mitigation measures are most appropriate, including which forms of 

mitigation are inappropriate.
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seasonal restrictions as proposed in Appendix AB. If implemented as proposed, 

restrictions of activities to certain times and dates would have significant 

socioeconomic impact within the resource management area, potentially 

necessitating long furloughs for workers, reduction of production capacity and 

rendering certain mineral resources uneconomic. Thirdly, the BLM has not 

provided sufficient rationale or basis for some of the restrictions. For example, 

BLM suggests that roads should not be designed to standards any higher than 

necessary to accommodate their intended purpose. While we are sure that the 

BLM does not intend for any road to be unsafe for travel, this restriction implies 

that only minimum safety standards can be used as a basis of design. SPE 

specifically objects to this requirement as safety (personnel and public) is the 

highest priority in our operations and we are unwilling to accept minimum 

standards. The restriction on ROW designations for counties on mining 

development roads is not justified or supported by any rationale that show 

greater protection for sage grouse habitat. County maintenance of mine access 

roads is often the most safe, efficient and economic means to support transport 

of personnel, equipment and supplies to mine related activities such as 

exploration and operations and should not be precluded by some unsupported 

BMP. Fourthly, the operations restrictions, in addition to the misapplication of 

fluid mineral restricted actions to solid minerals, do not necessarily provide the 

best environmental balance when evaluated on a project or site specific basis. 

For example, there are many requirements in this appendix referring to pit and 

impoundment construction that is not applicable to mining operations and 

include extraneous requirements not directly applicable to the greater sage 

grouse (e.g.: equip tanks and other above ground facilities with structures or 

devices that discourage nesting of raptors and corvids; eliminate threats from 

West Nile virus). Man camps are rarely used in solid minerals operations and 

sage grouse mitigation measures should be specifically designed for mining or 

exploration activities that use them. The ROW siting requirement to reduce 

disturbance to sagebrush habitats may not be the best overall environmental 

option for a solid mineral project, when considering other resources and habitat 

types. Reclamation requirements for access roads and well pads is not 

appropriate for this section. Appendix T has been included for oil and gas 

activities. SPE requests confilluation in the FEIS and final RMP that these 

requirements are not applicable to activities related to coal resource 

development. Exploration and water well drilling should not be required to be 

done using drill rig engines that meet Tier 4 emission standards.

DRMTDK-BL13-0183-7

Coal

The BLM states that "Surface owners of land overlying federal coal from both the 

Mammoth- Rehder and McCleary beds were consulted to determine their 

preference for or against leasing of their land for surface mining. The results of 

the consultation are shown in Table 2.3. Federal coal was found unacceptable 

N

The date when the surface owner consultation was conducted was added to the 

text. The coal screening process would be applied to future lease application 

areas.
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for further consideration where the surface owners responded negatively to 

surface mining." BLM did not mention that this consultation occurred in 1984 or 

earlier. Furthermore there has been no updated surface-owner consultation to 

support this draft RMP. Table 2.3 does not exist in Appendix M. SPE requests 

that coal screening be conducted in response to specific proposals using current 

data for future coal leasing actions.

DRMTDK-BL13-0197-1

Edits

Noticed one thing that looks like a small typo on page 3-165, 3rd paragraph: 

"The BLM does not anticipate that CBNG drilling and development would result 

in any different environmental impacts than conventional drilling and 

development. In contract to the Powder River Basin (PRB), coals in the Big Horn 

and Bull Mountains Basins are at greater depths."

n

Thank you for your comment. Text has been edited in response to your 

comment.

DRMTDK-BL13-0204-1

Livestock 

Grazing

Chapter 2, Page 52 Climate Change The alternatives are different in how they 

relate to climate change. Climate change is predicted to bring a warmer and 

drier climate to interior western North America. This means that water will 

become more precious and distribution of water among livestock operations, 

farming, fisheries and wildlife and wetland and riparian vegetation will become 

contentious. Thus, maintaining in-stream flows that benefit wildlife will become 

even more important as the climate warms etc. In this way the various 

alternatives are different in how they deal with climate change. Drought and 

grazing have similar effects on rangelands by favoring lower-growing, less 

productive species. As the climate warms, stocking rates will probably have to 

be adjusted down. Again, different alternatives deal with livestock grazing 

differently and this relates to climate change.

n Thank you for your comment.

DRMTDK-BL13-0204-

10

Edits Chapter 3, Page 41 Table 3-13 Utah juniper (Juniperus osteosperma) occupies 

many thousands of acres on the south side of the Pryors. N Thank you for your comment

DRMTDK-BL13-0204-

11

vegetation

Chapter 3, Page 44, Rangelands A Montana Natural Heritage report describes 

several plant communities from the Pryor Mtns. that are considered rare in 

Montana. Recognizing and doing protective management is a "coarse-filter" 

approach to conserving biological diversity. The existence of these communities 

is mentioned in the ACECs and should also be mentioned here.

n

Due to the size of the document, the major ecological systems and 

communities were discussed. While rare communities are important, the size 

and scale of these communities precluded in-depth discussion in this section in 

the range and shrubland section. 

In addition, the special status species section (3.6.6) does reference that the 

East Pryor ACEC has documented special status species.

DRMTDK-BL13-0204-

12

WILD 

HORSES,

PMWHR

Chapter 3, Page 112, Wild Horses Figure 14 of Ricketts et al. (2004) indicates 

that much of the Sykes Ridge area (mid-elevation) has an SI index of 0.1 which 

is very poor condition as we understand it. Many of the steep slopes provide little 

forage but are still subject to trampling degradation.

N

Thank you for your comment. The Natural Resource Conservation Service 

Survey and Assessment you are referencing does not have any Site Index of 

0.1. However the presence of wild horses does not ultimately mean that the 

ecological condition is due to their presence as opposed to a cumulative effect 

of past uses and practices. Horse trampling on steep slopes would be difficult 

as horses tend to follow trails in order to pass between grazing areas.

DR- water Chapter 4, Page 159, Impacts from vegetation Impacts from timber harvest in a n While we agree that the impacts identified in your comment can occur, 
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MTDK-BL13-0204-

13

watershed may not always be "negligible." Loss of trees can cause more water 

going into shallow groundwater and eventually into streams because trees take 

up water and lose it through transpiration. Removing trees can result in greater 

snowpack and higher groundwater. Removing trees can also cause higher 

earlier runoff due to lack of shade protecting the snowpack.

especially from large scale projects or on a cumulative basis, at the scale of 

treatment identified under any of the alternatives, these impacts would be 

undetectable and therefore negligible 

DRMTDK-BL13-0204-

14

water

One rangeland improvement action can be the construction or maintenance of 

stock ponds. These ponds can capture significant amounts of spring runoff that 

would otherwise be transported downstream and possibly causing the flood 

conditions necessary for cottonwood and willow rejuvination.

n

Thank you for your insightful comment. This will be considered during NEPA 

analysis of any site specific project involving stock pond construction. 

DRMTDK-BL13-0204-

15

SS Plants Chapter 4, Page 222, Special Status Plants Herbicide treatment by airplane or 

boom sprayers is much more likely to be detrimental than by hand spot spraying. n

Please also refer to comment in the ACEC section.

Please refer to Appendix B. BPMs in the Draft RMP/EIS for a reference to the 

17 Western States Veg EIS Best Management Practices for special status 

plants and can be found in the Standard Operating Procedure appendix B. of 

that document, which can be found here:

http://www.blm.gov/style/medialib/blm/wo/Planning_and_Renewable_Resource

s/veis/dear_reader_letter.Par.5918.File.dat/AppendixB-HerbicideUseSOPs.pdf 

see page B-11 under the Threatened, Endangered, and Sensitive Species 

(especially the second bullet)

DRMTDK-BL13-0204-

16

SS plants

Chapter 4, Page 224 Impacts from livestock grazing Many special status plants 

are broadleaved forbs. Forbs are often benefitted by cattle grazing that helps to 

reduce the dominance of grasses. In some cases removing grazing pressure 

could cause a decline of special status broadleaved forbs; this possibility should 

always be considered.

n

In response to your comment, the text in Ch. 4, Special Status Plants, Impacts 

from Livestock Grazing of the Proposed RMP and Final EIS has been revised 

to clarify the discussion of benefits to forbs from managed grazing. The basic 

impact conclusions presented in the Draft RMP/EIS have not changed.

DRMTDK-BL13-0204-

17

ACEC

Chapter 4, Page 549 East Pryor ACEC The draft RMP states that Alternative D 

would designate 11,122 acres and that this is more than Alternative A, but under 

the Alternative A section, it states that the ACEC would be 29,550 acres. Clearly 

Alternative D designates less that Alternative A; i.e., Alternative D reduces the 

acreage of East Pryor ACEC by two-thirds.

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS. The text has been corrected in 

Chapter 4 Alternative D.

ACECs are proposed where special management attention is required 

to protect the important and relevant values in relationship to the BLM preferred 

alternative in the RMP. Should existing management be present (like a WSA) 

that protects the relevant and important values then ACEC designation is not 

necessary. 

As WSAs contain the most restrictive management, there is no need for an 

ACEC to overlap the WSA. The relevant and important values of the East 

Pryor ACEC are addressed through the management of the WSAs. 
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DRMTDK-BL13-0204-

18

ACEC

Three species of globally rare vascular plant species occur in the East Pryor 

Mountains area. Erigeron allocotus occurs only in the Pryor and Bighorn 

mountains; Shoshonea pulvinata is found only in the Pryor Mountains and the 

foothills of the Absaroka-Beartooth; and Physaria (=Lesquerella) lesicii is known 

only from the Pryor Mountains. Populations of all three species should be 

protected by ACEC designation. Although Wilderness Study Area (WSA) 

designation will preclude motorized vehicle use, it is not adequate to protect 

these plants from habitat degradation caused by livestock or wild horses and 

does not mandate periodic monitoring that should be conducted. In order to 

protect significant populations of these species we recommend that the East 

Pryor ACEC encompass at least the BLM land in the following sections: T8S 

R28E sections 20, 21, 28, 29, 30, 31, 32, 33 and T9S R28E sections 

4,5,6,8,9,10,15,16,17,20,21, 22.

n

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS

ACECs are proposed where special management attention is required 

to protect the important and relevant values in relationship to management in 

the BLM preferred alternative in the RMP. Should existing management be 

present (like a WSA) that protects the relevant and important values then ACEC 

designation is not necessary. Language is included in the RMP that should 

congress (ever) make a decision on wilderness in the Pryors, and this area not 

be designated wilderness, then it would be managed as an ACEC.

As WSAs contain the most restrictive management, there is no need for an 

ACEC to overlap the WSA. The relevant and important values of the East 

Pryor ACEC are addressed through the management of the WSAs. 

Please also refer to comment in the ACEC section.

Please refer to Appendix E. Areas Of Critical Environmental Concern in the 

Draft RMP/EIS for a discussion of ACEC Nominations for East Pryor ACEC 

(BLM nomination), Pryor Foothills Research Natural Area/ACEC (public 

nomination), and Sykes Ridge Rare Plant ACEC (nomination by Peter Lesica). 

DRMTDK-BL13-0204-

19

ACEC

Chapter 4, Page 562, Pryor Foothills ACEC A Montana Natural Heritage report 

describes several plant communities from the Pryor Mtns. that are considered 

globally rare as well as rare in Montana. Many of these occur in the Gyp Springs 

area. These communities are just as important for conservation as the special 

status species. Recognizing and doing protective management for these 

communities is a "coarse-filter" approach to conserving biological diversity. We 

believe that the ACEC boundaries should be extended west to include Section 

30 which has large outcrops of Chugwater sandstone which is associated with 

the Atriplex nuttalliil Artemisia spinescens community as well as populations of 

Leptodactylon caespitosum and Mentzelia pumila. It would also be good to 

include at least a portion of Section 31 which has extensive stands of Artemisia 

pedatifzda-dominated communities which are rare in Montana. Soils in this area 

are very highly erodible, and soils on many of the slopes are protected from 

erosion by fragile communities of lichens and mosses.

n

Thank you for your comment. 

Please refer to Appendix E. Areas Of Critical Environmental Concern in the 

Draft RMP/EIS for a discussion of ACEC Nominations for East Pryor ACEC 

(BLM nomination), Pryor Foothills Research Natural Area/ACEC (public 

nomination), and Sykes Ridge Rare Plant ACEC (nomination by Peter Lesica). 

 

DRMTDK-BL13-0204-2VegRangelands

, Fire

Chapter 2, Page 59, Rangelands Two studies by the Montana Natural Heritage 

Program indicate that Wyoming big sagebrush recovers very slowly after fire. 

Prescribed fire may not be a good way to restore habitat diversity in sagebrush 

stands.

n

Please refer to Chapter 2, Page 59, Management Common to All Alternatives in 

the Draft RMP/EIS that states: Within sage grouse PHMAs only treatments that 

conserve, enhance, or restore Greater Sage-grouse habitat would be allowed. 

Site specific NEPA will address implementation practices (prescribed 
Billings and Pompeys Pillar National Monument

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(Y/N)

BLM Response to Comment

fire/mechanical treatment/chemical treatment) adjacent to and within sagebrush 

communities. 

 It is well known and documented that Wyoming big sagebrush is slow to 

recover, however prescribed fire is a valuable, and economic land management 

tool that needs to be available to land managers. While it may not be 

applicable in every situation, all of the time, it still needs to be available. Please 

note that it is stated in the desired outcomes section on page 2-59, “Manage 

vegetation resources ... based on sound biological principles and the best 

available science.” Therefore during site specific NEPA analysis if current 

literature indicates that prescribed fire will not achieve the desired goals and 

objectives for the project area, it will not be implemented.

DRMTDK-BL13-0204-

20

NEPA Oil and gas exploration could be disastrous to the fragile soils and vegetation in 

this area. N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS. 

DRMTDK-BL13-0204-3

Vegetation 

Invasive 

Species 

and 

Noxious 

Weeds

Chapter 2, Page 60 Rangelands BLM manages a great deal of rangeland that 

has been converted to crested wheatgrass. Some of these stands have been 

significantly invaded by native species while others have maintained their 

monoculture character. It would be good if restoration was prioritized to 

concentrate on those areas that are near mono cultures of crested

n

thank you for your comment. Page 2-60 BLM identifies various amounts of 

crested wheatgrass that would be treated over the life of the plan, as well as 

priorities for treating. In alternatives B, C, and D priorities would be: 1) located 

in PHMA, RA, or general sage grouse habitat. 2) Areas not currently being used 

in a grazing system to defer native rangelands. The intent of these treatments 

in Alternatives B, C, and D is to convert crested wheatgrass to native 

sagebrush/grassland. Therefore in these areas near monocultures would be 

priority treatment areas compared to crested/native areas. 

DRMTDK-BL13-0204-4

Vegetation 

Invasive 

Species 

and 

Noxious 

Weeds

Chapter 2, Page 62 Invasive species Early detection and control is key to 

managing invasive species (see Invasive Plant Science and Management (2013) 

6: 48-59 and references therein).

n

Thank you for your comment. 

Please refer to Chapter 2, Table 2-6.1 Page 2-62, pre-amble Section 

“Vegetation: Invasive Species and Noxious Weeds” discussion in the Draft 

RMP/EIS: “...by implementing a comprehensive weed program including: 

coordination with key partners, prevention and early detection, education, 

inventory and monitoring, and using the principles of Integrated Pest 

Management (IPM) and creating weed management areas (WMAs)”. 

DRMTDK-BL13-0204-5WILD 

HORSES,

PMWHR

Chapter 2, Page 83 Wild Horses There is no mention of wild horse impacts on 

special status plants and yet some special status plants occur on the wild horse 

range. Areas of potential conflict between horses and special status plants 

should be given priority for monitoring. There is a 1995 report done by Lesica 

and the Montana Natural Heritage Program that outlines the possible threats to 

LesquereUa lesicii.

N

Thank you for your comment. This table is for alternatives of wild horse 

management not impact analysis. Please see chapter four for impact analysis.

DRMTDK-BL13-0204-6

SS Plants

Chapter 2, Page 153 Grove Creek ACEC Herbicide application should only be 

by hand, not by boom or aerial in order to protect special status plants. Chapter 

2, Page 155 Meeteetse Spires (also Appendix E-22) There may be some historic 

value to this ACEC. Wasn't this an important trail for early settlers and maybe 

N

Thank you for your comments. 

Text in chapter 2 – vegetation – noxious and invasive species will be clarified to 

reflect your concerns. Please also refer to comment in the 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-148 Chapter 5: Consultation and Coordination

Comment 

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even Native Americans? Herbicide application should only be by hand, not by 

boom or aerial in order to protect special status plants. Chapter 2, Page 160, 

Pryor Foothills ACEC This area has very low precipitation. Consequently the 

vegetation can easily be degraded by livestock grazing. Herbicide application 

should only be by hand, not by boom or aerial in order to protect special status 

plants.

ACEC section.

Please refer to Appendix B. BPMs in the Draft RMP/EIS for a reference to the 

17 Western States Veg EIS Best Management Practices for special status 

plants and can be found in the Standard Operating Procedure appendix B. of 

that document, which can be found here:

http://www.blm.gov/style/medialib/blm/wo/Planning_and_Renewable_Resource

s/veis/dear_reader_letter.Par.5918.File.dat/AppendixB-HerbicideUseSOPs.pdf 

see page B-11 under the Threatened, Endangered, and Sensitive Species 

(especially the second bullet)

DRMTDK-BL13-0204-8

VegRangelands Chapter 3, Page 40 Crested wheatgrass should be mentioned in Table 3-12. n

Thank you for your comment. Please see that in table 3-12 in the rangelands 

cover type under characteristic species, wheatgrass is listed this included 

crested wheatgrass.

DRMTDK-BL13-0208-1

Vegetation 

Invasive 

Species 

and 

Noxious 

Weeds, 

Travel mngt

the increased motorized use of the Pryors, along with cattle grazing, has 

introduced numerous species of noxious weeds and troublesome weeds to this 

isolated and special mountain range.

n

Noxious and invasive weed species can be introduced and spread by many 

vectors. With regard to prevention, early detection, education, inventory and 

monitoring, please refer to Chapter 2, Table 2-6.1, Page 2-62, pre-amble 

section “Vegetation: Invasive Species and Noxious Weeds” and “Desired 

Outcomes (Goals and Objectives)” discussions in the Draft RMP/EIS: “ The 

BLM would control invasive, and non-native weed species and prevent the 

introduction of new invasive species, including aquatic nuisance species, by 

implementing a comprehensive weed program including: coordination with key 

partners, prevention and early detection, education, inventory and monitoring, 

and using the principles of Integrated Pest Management (IPM) and creating 

weed management areas (WMAs)”. Thank you for your 

comment. The BLM Travel and Transportation Manual, Manual 1626, which 

recently came out, instructs the BIFO to establish and long-term, sustainable, 

multi-modal transportation system of roads, primitive roads, and trails. It is an 

interdisciplinary approach to travel and transportation planning and 

management that addresses resource uses and associated access to public 

lands and which encompasses motorized, non-motorized, mechanical and 

animal powered modes of travel. The final RMP has been modified to 

incorporate this new Manual. In regards to your concern on the spread of 

invasive vegetation, and your concern regarding grazing is addressed (Please 

note that the goal for the Pryor Mtn TMA is to protect wilderness values, cultural 

assets, visual characteristics, sensitive plants, fragile and erosive soils, wild 

horses and wild horse habitat.) 

DRMTDK-BL13-0208-2

Livestock 

Grazing

Please include in your livestock grazing plans that it is the responsibility of the 

rancher who has an allotment to spray for weeds at the round-up and feedlot 

locations such as those along the Gyp Springs and Helt Roads. It is clear that it 

n

Thank you for your comment. The subject of this comment is beyond the scope 

of the Billings and Pompeys Pillar National Monument RMP/EIS and does not 

require further agency response. Specific Grazing permit terms and conditions 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-149

Comment 

Number Topic Comment Text

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BLM Response to Comment

is livestock that are dispersing weeds including annuals like cheat grass that are 

dismissed as unimportant.

require a site specific analysis, rather than a RMP level analysis.

DRMTDK-BL13-0209-1

Recreation 

There is no reason why target shooting should be allowed in the PMWHR, and 

many good reasons why it should not be allowed. Not only does target shooting 

endanger the horses and other wildlife on the range, but it also presents a clear 

and present danger to members of the public.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

Please note that on page 2-172 safety is noted as a specific concern and that 

the closure is only during the period of peak visitation and only in the area 

where people and horses congregate in close proximity with a potential for both 

vegetation and topography screening.

DRMTDK-BL13-0209-2

Recreation 

the Pryor Mountain Herd is especially famous and as such, people come from 

around the country and indeed the world to observe these horses. Other tourists 

are drawn to the area because of its natural beauty. All these people provide 

significant benefits to the local economy through the purchase of meals, lodging 

and other amenities, but target shooting endangers them and makes them less 

likely to visit the area. This in turn would hurt the local economy. There are 

plenty of other places where individuals can engage in target shooting without 

allowing the practice within the PMWHR.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

Please note that on page 2-172 safety is noted as a specific concern and that 

the closure is only during the period of peak visitation and only in the area 

where people and horses congregate in close proximity with a potential for both 

vegetation and topography screening.

DRMTDK-BL13-0209-3WILD 

HORSES,

PMWHR

any enclosures not in use should be removed as a matter of priority. Many 

enclosures (in particular the large ones on Sykes Ridge) are not being used for 

data collection, are a safety hazard to foals and other vulnerable animals, and 

generally undermine the goal of achieving and maintaining a Thriving Natural 

Ecological Balance within the PMWHR.

N Thank you for your comment

DRMTDK-BL13-0209-4

PMWHR, 

Travel Mngt

I do not support the preferred alternative of closing part of Burnt Timber and 

Sykes Ridge Roads from April 15 - June 15. This area is very popular with 

tourists, who provide important economic stimulus to the area, and the dual 

goals of protecting both the ecological integrity of the area and the safety of the 

horses can be achieved through cost-effective public education measures. For 

example, the BLM should utilize aesthetically appropriate signage and use other 

public education tools to discourage the public from going off-road and to make 

clear penalties for going off-road, and volunteers can help in this effort by 

creating natural blocks to keep the public from going off-road in these areas.

N

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

In regards to your comment on closing Burnt Timber and Sykes Ridge Road 

from April 15 to June 15, the decision was made to protect a number of 

resource values, not just wild horses. The final decision has been made to 

leave the Burnt Timber road closed during this time period while allowing 

access up Sykes Ridge Road.

DRMTDK-BL13-0216-1WILD 

HORSES,

PMWHR

According to NAS, wild horse roundups aren't necessary! No more roundups! 

There is plenty of room for the existing wild horses and then some in the Pryor 

Mountains! Remove the fences! Thank you!

N

Thank you for your comment. This document is not tied to any gather as 

gathers are implementation level documents. 

DR- ACEC Of lower priority would be any documents used to justify proposing only 2,606 n Thank you for your comment. Please see the 1998 ACEC Assessment and 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-150 Chapter 5: Consultation and Coordination

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BLM Response to Comment

MTDK-BL13-0222-1acres of the Pryor Foothills as a Research Natural Area/ACEC on 30 September 

2009. The Nomination Evaluation is found in the Draft RMP in Appendix E on 

page E-28. Specifically why were the recommendations of Peter Lesica and 

Peter Achuff in Distribution of Vascular Plant Species of Special Concern and 

Limited Distribution in the Pryor Mountain Desert, Carbon County, Montana, 

January 1992 rejected

Proposed amendment to the Billings, Powder River and South Dakota RMPs 

here:

http://www.blm.gov/style/medialib/blm/mt/blm_programs/

planning/billings_rmp/amendments.Par.94086.File.dat/acecEA.pdf pages 74-

76 are the nominations evaluations for the Billings RMP and page 103 shows 

the map of the nominated vs. recommended ACEC.

DRMTDK-BL13-0223-3

ACEC

Based on a survey of plants on the south side of the Pryors done in May and 

June of 1991, Peter Lesica and Peter L. Achuff recommended the Township 

T9S, R27E and the western half of Township T9S, R28E as a reserve for 

protection of eight of the 15 high-priority species of plants they found in the Pryor 

Mountain Desert. Their report was presented to Don Heinze in January 1992. 

hey recommended 34,560 acres be designated in some manner to protect the 

rare plants in the Pryor Mountain Desert. The number of acres proposed for 

Pryor Foothills ACEC or RNA falls far short of the Lesica -

Achuf recommendation. It appears that the Gypsum Creek drainage is not 

being considered. Why?

n

Thank you for your comment. In response to your comment

Please refer to Appendix E. Areas Of Critical Environmental Concern in the 

Draft RMP/EIS for a discussion of ACEC Nominations for East Pryor ACEC 

(BLM nomination), Pryor Foothills Research Natural Area/ACEC (public 

nomination), and Sykes Ridge Rare Plant ACEC (nomination by Peter Lesica). 

Please see the 1998 ACEC Assessment and Proposed amendment to the 

Billings, Powder River and South Dakota RMPs here: 

http://www.blm.gov/style/medialib/blm/mt/blm_programs/

planning/billings_rmp/amendments.Par.94086.File.dat/acecEA.pdf 

pages 74-76 are the nominations evaluations for the Billings RMP and page 

103 shows the map of the nominated vs. recommended ACEC.

DRMTDK-BL13-0226-1

ACEC

Combine all lands proposed for special designation that are west of Crooked 

Creek into one ACEC.I do not understand why BiFO would fragment the lands 

west of Crooked Creek by applying different administrative designations. 

Common sense would dictate one administrative designation with one set of 

managerial policies. As BLM makes decisions about conservation designations 

consider keeping lands on the west side of Crooked Creek in one designation 

and separate from the designations on the east side. As an example, it is 

illogical for the Demijohn Flat to be in the Burnt Timber Canyon ACEC. Those 

sections of land with various designations lie within T9S R27E. I propose that 

BiFO combine the Burnt Timber Canyon WSA west of Crooked Creek; all or part 

of sections 4, 3, 9, 10, 14, 15 that lie to the west of Crooked Creek Road; the 

Penney Peak Strip which is section 22 and parts of sections 21 and 23; and 

Alternative D proposed Pryor Foothills RNA/ACEC, which is basically sections 

29, 28, 32 and 33.I do not understand why the southwest corner of section 15 

was excluded from the Alternative D East Pryor ACEC. It should be included.

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS

Demi-John Flat national register district is partly included within the Burnt 

Timber Canyon WSA. When expanding the boundaries of the East Pryor 

ACEC, the ACEC boundary was expanded to include the entire national 

register district. 

DRMTDK-BL13-0226-2

ACEC

The Penney Peak strip Incorporate the Penney Peak Strip into an ACEC to 

provide the protection this strip of land requires. The Penney Peak Strip is in 

T9S R27E, and includes all of section 22 in which Penney Peak is located 

together with the portions of sections 21 and 23 from the Crooked Creek Road 

on the west, to Tillet's land on the east. This strip consists of very fragile land. 

Various geological strata are exposed. Some of the South Pryor Desert plants 

are in this strip. It has a its own special beauty.

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-151

Comment 

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(Y/N)

BLM Response to Comment

DRMTDK-BL13-0226-3

ACEC

I present four alternatives beginning with Alternative W, which is my preferred 

alternative, ranked down to Alternative Z, which is a poor compromise. Please, 

consider each of these alternatives as a comment for response. Alternative 

Designate all BLM lands on the southern slopes of the Pryor Mountains between 

the Forest Service lands to the north and the Wyoming border to the south and 

from the road that comes out of Bear Canyon and joins Highway 310 north of 

Frannie on the west to Crooked Creek on the east. This would be West Side, 

South Pryors Desert It is difficult to set the northern boundary for my Alternative 

W. My focus is upon the conservation of the desert areas. How can one easily 

establish where the desert lands end and the uplands begin? It would be simpler 

to set the northern boundary at the Forest Service boundary. This would be 

West Side, South Pryors BLM. This area, if managed as an ACEC, would give 

the most protection to the wide range of plants, plant communities and 

geological formations. The Montana Native Plant Society incorporates this area 

within its South Pryor Mountains Important Plant Area. This is the place where 

Montana botanists believe efforts should be made to conserve plants. Alternative 

X Designate the area recommended by Peter Lesica and Peter Achuff in 1992 

as an ACEC. They recommended 34,560 acres be designated in some manner 

to protect the rare plants in the Pryor Mountain Desert. I cannot say it better than 

Lesica and Achuff's statement on page 35 of their report. "The Gypsum Creek -“ 

Crooked Creek area (T9S R27E and the western half T9S R28E) stands out as 

having the highest concentration of high-priority species populations. Eight of the 

15 high-priority species: Astragalus geyeri, Astragalus oreganus. Camissonia 

andia, Cleome lutea, Grayia spinosa, Leptodactylon caespitosum, Malacothrix 

torreyi and Mentzlia pumila, have known populations in this area. The Gypsum

Creek -“ Crooked Creek area is 4100 -“ 5200 ft in elevation and contains soils 

derived from calcareous sandstone, Chugwater sandstone and limestone. 

Terrain varies from highly dissected foothills with deep canyons to broad alluvial 

valleys. The appreciable habitat diversity and the large number of populations of 

both high -“ and low -“ priority species make the Gypsum Creek -“ Crooked 

Creek area the best choice for a single reserve in the Pryor Mountain Desert. 

The seven high -“ priority species not represented in this area occur in widely 

separated sites throughout the study area and cannot be protected practically in 

large reserves. In addition to the many species of rare plants found in the Pryor 

Mountain Desert, we believe that many of the plant communities are rare in 

Montana, and some may be globally unique." Lesica, Achuff 1992Note that this 

statement predates DeVelice and Lesica's 1993 study which delineated those 

plant communities in the Pryor Mountain Desert, a report to which you should 

refer. It is important that in designating an ACEC that BLM focus not only on 

BLM's plant species of concern - but also consider the plant communities. 

Designating the one and one-half townships as recommended would also 

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-152 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

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Document 

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conserve those unique plant communities and other natural features. Alternative 

Expand the Alternative D for the proposed Pryor Foothills RNA/ACEC to include 

these uncommon plant communities. Consider each of these four areas 

separate recommendations or combined as one recommendation. A.) McKown 

wellT9S R26E, sections E half 27, 26, 34I have not yet walked this area. It does 

include the exposure of the Kootenai stratum that is poorly represented 

elsewhere in the South Pryors. b.) Artemisia pedatifida/Agropyron spicata and 

Artemisia pedatifida/Atriplex gardneri plant communities Section 23, T9S 

R26EThese are important plant associations in the South Pryor Desert that have 

not been given any conservation status. c.) Atriplex gardneri/Monolepis 

nuttalliana Section 30, T9S R26E (This plant community is also in the adjacent 

sections 32, T9S R26E and 24 in T9S R25E.)I have not yet walked this area. 

Petroglyph Canyon is in section 35, T9S R26E. BiFO has set aside 240 acres to 

preserve this archeological site, but has not divulged the boundaries. Section 35, 

T9S R26E is also interesting for its plant associations. An all inclusive option for 

Alternative Y would be to expand the proposed Alternative D for the Pryor 

Foothills RNA/ACEC to include the following sections: In T9S R26E include 

sections 23,24, 27, 26, 25, 34, and 35 (36 is State land) and in T9S R27E 

include sections 30 and 31. BLM has proposed Sections 29, 28, 32, and 33 for 

the Pryor Foothills RNA/ACEC. Alternative Z If BiFO rejects the above 

Alternatives W, X and Y, at least adjust the west boundary of the RNA/ACEC to 

the west line of sections 29. It would then be reasonable that the west line of 

section 32 would also be the border. The western boundary that BiFO proposes 

for the RNA/ACEC in the draft RMP appears to be an old roadbed parallel to and 

west of the Gypsum Creek Drainage. It runs up the middle of a broad valley. The 

former road is now a faint pathway that is no longer drivable. Extending the 

boundary to the west side of Sections 29 would then include the more of the 

valley and some of the ridge of Chugwater to the west. In Section 32 the 

proposed west boundary for the Alternative D Pryor Foothills RNA/ACEC 

appears to be arbitrary and makes no sense. As proposed it is simply a line 

drawn south from the junction of the former road with the junction of the Gypsum 

Spring Road. Under the travel plan I will propose that BLM designate the old, 

now undrivable, road parallel to the Gypsum Creek Drainage be designated as a 

hiking trail from the Gypsum Spring Road to the watering tank

DRMTDK-BL13-0229-1

NEPA

The CEQ has directed agencies to gather data from reliable sources such as 

interviews and information from local residents which the BLM has failed to do. 

You did hold the open meetings, but refused to allow public comment at those 

meetings. How can they be considered public meetings if no public discussions 

are allowed? I suggest you re-schedule the meetings and allow them to be 

public meetings as required. I request your agency follow the CEQ requirement 

and gather more reliable information in completing the BLM RMP/EIS. Failure to 

N

Thank you for your comment.

The BLM Billings Field Office held 5 Open House style meetings to answer 

questions about the draft RMP/EIS and the public comment period on the draft 

RMP/EIS was open for 90 days. Also, at the request of members of the public, 

the BLM attended a meeting on June 22, 2013 in Belfry, Montana to answer 

questions regarding proposed management in the Grove Creek area.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-153

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gather true data on the economic impacts of this decision and to incorporate this 

information into the document would result in the decision being arbitrary and 

capricious.

DRMTDK-BL13-0232-1WILD 

HORSES,

PMWHR

Round ups and holding pens for Mustangs is not a sustainable solution for the 

range/public lands. What is sustainable is to remove the cattle/sheep from the 

range and return the natural predators that will thin the herds and end the need 

for land management.

N

Thank you for your comment. The PMWHR has not had active livestock 

grazing since 1968 on the Secretarial Order and 1975 on the higher elevations 

when this area was added to the range.

DRMTDK-BL13-0233-1WILD 

HORSES,

PMWHR

I am also writing to encourage you to consider:1) Prioritizing the removal of any 

enclosures not in use. The large ones on Sykes Ridge area a potential to be a 

safety hazard to small foals, which we have seen in years past with other 

enclosures.2) Encourage BLM, to work with the National Park Service to 

reintroduce the Sorenson Extension into the horse range.

N Thank you for your comment 

DRMTDK-BL13-0234-1

Travel mngt

The Demijohn Flat route should be designated non-motorized. Please specify in 

your RMP the non-motorized routes. They deserve as much recognition as the 

motorized routes. But thank you for clarifying that motor vehicle use is limited to 

designated routes.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Demi John Flat route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed to motorized vehicles” except for administrative purposes. This will 

not prohibit non-motorized use. 

Refer to map 146

DRMTDK-BL13-0237-1

Edits

ES-2 Special Designations Please add National Trails System Act (P.L. 90-543, 

as amended through P.L. 111-11, March 30, 2009) (also found in the United 

States Code Volume 16, Sections 121-1251) especially the following section to 

set the tone: The following portion of the law directions our management for 

these two trails: SEC. 7. (16USC1246) (c) National scenic or historic trails may 

contain campsites, shelters, and related public-use facilities. Other uses along 

the trail, which will not substantially interfere with the nature and purposes of the 

trail, may be permitted by the Secretary changed with the administration of the 

trails. Reasonable efforts shall be made to avoid activities incompatible with the 

purposes for which such trails were established" "Where a national historic trail 

follows existing public roads, developed rights-of-way or waterways, and similar 

features of man's non-historically related development, approximating the 

original location of a historic route, such segments may be marked to facilitate 

retracement of the historic route, and where a national historic trail parallels an 

existing public road, such road may be marked to commemorate the historic 

route. Other uses along the historic trails and the Continental Divide National 

Scenic Trail, which will not substantially interfere with the nature and purposes of 

n

Thank you for your comment. Text has been edited in response to your 

comment.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-154 Chapter 5: Consultation and Coordination

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the trail, and which, at the time of designation, are allowed by administrative 

regulations, including the use of motorized vehicles, shall be permitted by the 

Secretary charged with administration

DRMTDK-BL13-0237-

10

National 

Historic 

Trails

2-175 National Historic Trails and then throughout the document Add a 

standard: Manage the Auto Tours associated with the National Trails to include 

interpretive sites and turn outs along with designated markers as set out in the 

NHT's comprehensive management plans. Add a to Management Common to 

All Alternatives, 1st standard: Implement the Interagency National Historic Trail 

Plans and all revisions including sub plans such has interpretive plans Add to 

Management Common to All Alternatives, 2nd standard: and solar ROW actions 

Add to Management Common to All Alternatives, 3rd standard: And participate 

and follow Trail's Land Acquisition Management Plans or create a standard for 

this Add a Standard: In areas that may affect the NPNHT, consultation will be 

undertaken with the 3 affected tribes: Nez Perce, Confederated Tribes of the 

Umatilla Reservation, and Confederated Tribes of the Colville Reservation

n

Thank you very much for comment. The RMP text has been altered to reflect 

your comment and concerns

DRMTDK-BL13-0237-

11

National 

Historic 

Trails

3-116 3.10.1.5 Historic Period Please add: In 1877, 5 bands of Nez Perce 

fleeing the U.S. Army passed through this area during September followed by 

several elements of the U.S. Calvary

n

Thank you for your comment. In response to your comment, the text in chapter 

3 section 3.10.1.5 will be revised.

DRMTDK-BL13-0237-

12

National 

Historic 

Trails

3-122 3.19.6.2 Tribal Consultation Need to add a sentence indicating that in 

areas near the Nez Perce (Nee-Me-Poo) National Historic Trail (NPNHT), the 

NPNHT Auto Tours and potential NPNHT associated sites tribal consultation 

must occur with the three tribes associated with the Nez Perce; Nez Perce, 

Confederated Tribes of the Umatilla Indian Reservation and the Confederated 

Tribes of the Colville Indian Reservation

n

Thank you for your comment. The text in section 3.19.6.2 will be revised to 

reflect your concern. 

DRMTDK-BL13-0237-

13

National 

Historic 

Trails

3-190 3.21.2 Sundance Lodge Recreation Area SRMA This area is also close to 

or is where the some or all of the Nez Perce crossed during the 1877 Flights and 

they were followed by elements of the U.S. Army crossing behind them

n

The RMP text will be modified to reflect this information. Please see “text 

changes. 

DRMTDK-BL13-0237-

14

National 

Historic 

Trails

3-196 3.22 Trails and Travel Management Please add the following 

standard: The NPNHT (and Lewis& Clark NHT) is a non-motorized trail by 

Congressional designation except for auto tours, crossing, etc

n

Thank you for your comments and your concern. We appreciate the interest in 

management of public lands. The sections of the RMP have been altered to 

include the statement.

DRMTDK-BL13-0237-

15

National 

Historic 

Trails

3-196 or 3-205 3.22 Trails and Travel Management or 3.24 Transportation and 

Facilities There is no acknowledgement or discussion of the Nez Perce National 

Historic Trail Auto Tours that pass through the District. Please add a discussion 

of the Auto Tours including the Highway route and Adventurous routes. More 

information can be found at 

http://www.fs.usda.gov/detail/npnht/home/?cid=FSBDEV3_055663

n

Thank you for your comment. The text in the RMP has been altered to reflect 

your concerns. 

DRMTDK-BLNational 

Historic 

3-224 3.31 National Historic Trails Please add: The National Historic Trails are 

managed according to guidelines set up in their Comprehensive Management n

Thank you very much for comment. The RMP text has been altered to reflect 

your comment and concerns
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-155

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

13-0237-

16

Trails Plans. The plan for Nez Perce National Historic Trail is found in the The Nez 

Perce (Nee-Me-Poo) National Historic Trail Comprehensive Plan, Forest 

Service, Northern Region, 1990 which is undergoing a plan revision at this time

DRMTDK-BL13-0237-

17

National 

Historic 

Trails

Chapter 4 General Observation Not all resource areas list impacts to Special 

Designations topics in the same format. Some sections include some special 

designations like National Historic Trails or Wilderness and some resource 

sections do not. It would be helpful to have a statement in the front of the 

resource sections indicating what special designations topics are impacted by 

the resource and which special designations topics have no impacts and why. 

This would help the reader when they are looking for specific topics

n

Thank you for your comment. Text has been edited in response to your 

comment.

DRMTDK-BL13-0237-

18

National 

Historic 

Trails

4-581 4.4.6 National Historic Trails 1st paragraph, there is a reference to Map 

175 that shows the National Historic Trails, I cannot find Map 175 in my 4 

volumes for the RMP/EIS

n

Thank you for your comment. Text has been edited in response to your 

comment.

DRMTDK-BL13-0237-

19

National 

Historic 

Trails

4-582 4.4.6.1 Method and Assumptions 1st sentence add the word 

Comprehensive between Trail and Plans There is no discussion of the Auto 

Tours in this section, please add a section on the Auto Tours

n

Thank you very much for comment. The RMP text has been altered to reflect 

your comment and concerns

DRMTDK-BL13-0237-2National 

Historic 

Trails

I-151.4.1.4 Issues Addressed Through Policy or Administrative Actions First 

bullet, please add National Trails System Act to the list of laws and add it into the 

glossary of terms too

n

Thank you for your comment. Text has been edited in response to your 

comment.

DRMTDK-BL13-0237-3National 

Historic 

Trails

1-261.6.1 Consultation with American Indian Tribes Please add the following 

sentence: In areas that may affect the Nez Perce National Historic Trails, high 

potential sites, high potential segments, and the Auto Tours consultation will be 

undertaken with the 3 affected tribes: Nez Perce, Confederated Tribes of the 

Umatilla Reservation, and Confederated Tribes of the Colville Reservation

n

Thank you for your comment. The text in section 1.6.1 indicates those tribes 

invited to become cooperating agencies in 2008. 

DRMTDK-BL13-0237-4

National 

Historic 

Trails, Oil 

and Gas

2-39 2.6.2.1 Leasable Fluid Minerals, Management Common to All Alternatives, 

Oil and Gas1st paragraph, add National Trails System Act to discussion of 

applicable laws

n

Thank you for your comment. Text has been edited in response to your 

comment.

DRMTDK-BL13-0237-5

National 

Historic 

Trails, 

cultural

2-85 Cultural and Heritage Resource-Management Common to Al Alternative 

Add a standard or acknowledgement for the following: The NPNHT is a 

congressionally designated historic trail and the potential for a national historic 

register status is possible. There is a need for a historic preservation protection 

plan for the corridor, designated high potential historic sites:? Bill Brockway 

Ranch? P.W. McAdow Sawmill? J.M.V. Cochran Ranch? Canyon Creek Battle 

Site? Crow Indian Raid? Musselshell Crossing? Sturgis and Howard Camps And 

associated side trail- Bozeman Trail Road that are cited in The Nez Perce (NeeMe-Poo) National Historic Trail Comprehensive Plan, Forest Service, Northern 

Region, 1990, page 26. The CMP revision will require the historic preservation 

plan

n

Thank you for your comment. 

The BLM can only make management decisions for those resources located on 

BLM managed public lands. The designated high potential historic sites 

mentioned in the comment are not located on BLM managed public lands 

managed by the Billings Field Office. 

As the segments of the NPNHT within BiFO (on BLM managed public land) 

have not been located on the ground or inventoried for cultural resources, no 

National Register nomination can occur. When the segments are located and 

inventoried for cultural resources, a national register nomination would occur. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-156 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

Please refer to table 2-6.3 National Historic Trails.

DRMTDK-BL13-0237-6

National 

Historic 

Trails, 

cultural

2-88 Table 2.6.1 Cultural Resources Use Allocation, Historic Roads/Trails and 

then throughout document in the cultural resource sections Include interpretation 

under all alternatives for National Historic Trails to meet the intent of the Act Sec 

7. (c) ". The appropriate Secretary may also provide for trail interpretation sites, 

which shall be located at historic sites along the route of any national scenic or 

national historic trail, in order to present information to the public about the trail, 

at the lowest possible cost, with emphasis on the portion of the trail passing 

through the State in which the site is located. Wherever possible, the sites shall 

be maintained by a State agency under a cooperative agreement between the 

appropriate Secretary and the State agency

n

Thank you for your comment. Text has been revised in table 2-6.3 National 

Historic Trails. 

There are five historic trails and two NHT within BiFO. The management in 

table 2—6.1 refers to historic trails. Management of NHTs is located in table 2-

6.3. 

DRMTDK-BL13-0237-7

National 

Historic 

Trails, 

visual 

2-91 Table 2.6.1, Visual Resources and then throughout the document The goal 

of a national historic trail is to protect the cultural, historic landscape in a 

condition that is duplicates the time period for which the trail was designated. 

Please classify the Nez Perce National Historic Trail (NPNHT) has a Visual 

Resource Management Class I or II throughout this document

n

Thank you for your comment. Please see table 2.12 Special Designations-NHT 

for VRM designations.

DRMTDK-BL13-0237-8National 

Historic 

Trails

2-109 Realty, Cadastral Survey, and Lands: Land Tenure Adjustment and 

Access- Management Common to All Alternatives and then throughout the 

document Add a standard: Participate and adopt National Historic Trails Land 

Acquisition Plans

n

Thank you very much for comment. The RMP text has been altered to reflect 

your comment and concerns

DRMTDK-BL13-0237-9

National 

Historic 

Trails, 

Travel mngt

2-127 Trails and Travel Management -“ Management Common to All 

Alternatives and then throughout the document Please add the following 

standard: The NPNHT (and Lewis& Clark NHT) is a non-motorized trail by 

Congressional designation except for auto tours, crossing, and approve 

motorized use dating prior to the enacting legislation

n

Thank you very much for comment. The RMP text has been altered to reflect 

your comment and concerns

DRMTDK-BL13-0245-2

Wildlife, Oil 

and Gas

COMMENT: As shown in Table 2 above, the planning prescriptions for surface 

occupancy and controlled surface use for the three planning areas (MCFO, 

HiLine, and Billings/Pompey's Pillar) are variable which raises questions of how 

NSO restrictions were determined. Based on review of the three draft planning 

documents, it appears that all three relied on same data sources to address 

impacts of oil and gas development on sage-grouse. All planning areas have 

similar sage-grouse habitat conditions (i.e., all are in Sage-Grouse Management 

Zone 1), and all are anticipating some level of oil and gas development. It is 

unclear how different NSO restrictions around leks were developed. NSO 

restrictions around leks vary among the planning areas, with buffers around leks 

being 0.6, 1, 2, and 3 miles. Why are these NSO restrictions different for the 

three planning areas when they all relied on similar sources to define potential 

impacts associated with oil and gas development? Does sage-grouse 

vulnerability to impact or population viability differ among BLM planning areas?

Y

Thank you for your comment. 

The BLM oil and gas stipulations are currently undergoing a consistency review 

between the field offices with RMP revisions underway. Any inconsistencies 

will be corrected.

DR- WILD On page 2-83, Wild Horses, FWP opposes any expansion of the Wild Horse N Thank you for your comment
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-157

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

MTDK-BL13-0246-

10

HORSES,

PMWHR

Range. Expansions proposed in either Alternative C or D would allow for 

increased horse use on important mule deer winter ranges.

DRMTDK-BL13-0246-

11

Fire 

Ecology 

and Mngt

On page 2-94, Fire Ecology and Management -” Management Actions by 

Alternative, FWP supports Alternative B whence prescribed fire would not be 

allowed in the greater sage grouse habitat ACECs, PPAs, or RAs. Alternatives C 

and D both allow prescribed fire in the sage grouse PPAs and RAs in the 

attempt to achieve age class diversity of the sagebrush. It has been shown 

repeatedly that big sagebrush does not come back quickly from fire and does not 

need to be manipulated to maintain age class diversity.

n

Thank you for your comment. Your comment will be considered by the Billings 

Field Office when selecting an alternative.

DRMTDK-BL13-0246-

12

Livestock 

Grazing

On page 2-116, Livestock Grazing -” Management Common to Action 

Alternatives - All allotments wholly located within sage-grouse PPA habitat would 

be considered for retirement where the base property owner relinquished their 

preference. FWP questions the value of retiring allotments to improve sage 

grouse habitat. It has been shown that grazing as a management tool can 

improve plant vigor and diversity, and that long-term undisturbed grass stands 

may become degraded and undesirable for nesting and brood rearing birds. 

However, poorly managed grazing can be detrimental to sage grouse. FWP 

prefers to see these allotments placed under a true Hormay rest-rotation grazing 

system that provides for grazing schematics based on the physiological needs of 

the vegetation, which includes a post-season grazing treatment, followed by a 

complete years of rest, followed by a traditional grazing treatment.

n

Thank you for your comment. Based on historical grazing administration in the 

Billings Field Office, grazing preference is rarely relinquished. Under 

Alternatives B, C, and D the BLM would consider retirement of these 

allotments. If current livestock use is compatible with sage grouse habitat 

requirements, and rangeland health standards are being achieved, BLM would 

have little basis to retire the allotment from grazing. Additionally, on Page 2-

116 under management common to all alternatives, it is stated BLM would “use 

livestock grazing to enhance ecosystem health, wildlife habitat, .... Where 

supported by site-specific environmental analysis.” This may or may not 

include the use of a rest rotation grazing system

DRMTDK-BL13-0246-

13

Livestock 

Grazing

Livestock Grazing Beginning on page 3-180, FWP offers the following general 

commentary: The only commitment to wildlife in the livestock grazing section is 

meeting Montana/Dakota's Standards for Rangelands Health and Guidelines for 

Livestock Grazing Management. This standard is fairly generic and basically 

says that native plant communities will be maintained or improved. There 

appears to be no standards that are specifically directed toward improving sage 

grouse habitat. For example, there are no standards for maintaining adequate 

residual grasses on the landscape to enhance nesting success. While most 

other resource uses discussed in the RMP include specific 

requirements/stipulations for the enhancement of sage grouse habitat, the 

grazing section includes no similar requirements. FWP would like to see more 

emphasis on grazing management to improve wildlife habitat through Hormay 

rest-rotation or similar systems.

n

The current standards for rangeland health (Appendix I) were approved by the 

Secretary of Interior on August 12, 1997 (pg. 3-181). Addition of new 

standards, or modification of existing standards would likely require a similar 

approval process and are not within the scope of an RMP level analysis. 

Additionally, Standard 5 (habitat) mandates “The environment contains all of 

the necessary components to support viable populations of a 

sensitive/threatened and endangered species in a given area relative to site 

potential.” This standard captures your comments regarding the need to 

manage for residual grass cover to enhance nesting success. 

The RMP does address specific requirements and stipulations for sage grouse 

habitat on page 2-116. Under all alternatives the BLM would develop site 

specific greater sage-grouse habitat and management objectives within greater 

sage-grouse priority areas. These objectives would be incorporated into the 

respective allotment management plans or livestock grazing permits as 

appropriate. This would include such actions as maintaining residual grasses. 

Additionally see Appendix AA (section F) for more specific livestock grazing 

conservation and mitigation measures for sage grouse habitat.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-158 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

Also, the BLM is currently assessing habitat, utilizing the protocol outlined in the 

Habitat Assessment Framework, (Instruction Memorandum No. 2012-043.) 

This framework is also listed in appendix AA Through this effort BLM has been 

collecting habitat data from public land inPHMAs, and where available, BLM 

has requested MTFWP habitat data collected for the ongoing sage grouse 

study being conducted in Musselshell County. Data is compiled to assess the 

present habitat, with the seasonal habitat requirements of the sage grouse to 

ensure that the proper requirement and stipulations are placed on grazing 

authorizations at the allotment and/or pasture level during site specific analysis, 

rather than at the RMP level.

DRMTDK-BL13-0246-

14

Wildlife

No mention is made of reducing/mitigating grizzly bear mortality that occurs on 

BLM allotments as a result of cattle depredations. The RMP should specify that 

allotment plans will be designed to minimize potential grizzly mortality. Failure to 

do so could trigger a grizzly status review and consultation with the US Fish, and 

Wildlife Service.

n

Refer to Table2-6.1,, under Wildlife Habitat- Management Common to All 

Alternatives, the statement “Assist in the restoration, reintroduction, 

augmentation, or re-establishment of T & E, special status, and priority species 

and other populations” etc. 

This is a recent issue and outside of the Grizzly Bear Recovery Zone. The 

grizzly bear mortalities occurred in 2011 and 2012 which was unusual. No 

mortalities had occurred until then and no grizzly bear/livestock conflicts 

occurred on BLM lands, but on adjacent private lands. BLM is currently 

consulting with USFWS on a grazing permit renewal and is recommending (in 

consultation with USFWS) several mitigation measures to reduce grazing and 

grizzly bear conflicts. BLM will continue to consult with USFWS, Endangered 

Species Office.

DRMTDK-BL13-0246-

15

Recreation 

Target Shooting On page 2-126, Pryor Mountain Wild Horse Range and East 

Pryor ACEC, FWP questions the closure of over 6,700 acres for the entire 

summer as shown in Alternative D, the preferred Alternative. No public safety 

issues are used as reason for closure, and we wonder what are the resource 

concerns.

n

Please note that on page 2-172 safety is noted as a specific concern and that 

the closure is in effect only during the period of peak visitation and only in the 

area where people and horses congregate in close proximity with a potential for 

conflict due to both vegetation and topography screening. 

DRMTDK-BL13-0246-

16

Travel mngt 

Travel Management On page 2-133, Pryor Mountain TMA, referring to map 146, 

FWP is not sure what the additional management designation means, but is 

opposed to any spring closure of the Burnt Timber Road and the Sykes Ridge 

Road, as this would preclude access for bear hunting to a significant portion of 

the Pryor Mountains.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

In regards to your comment on closing Burnt Timber and Sykes Ridge Road 

from April 15 to June 15, the decision was made to protect a number of 

resource values, not just wild horses. The final decision has been made to 

leave the Burnt Timber road closed during this time period while allowing 

access up Sykes Ridge Road. 

DRMTDK-BL13-0246-

Travel mngt

On page 2-132, Tin can Hill TMA, referring to map 134, FWP supports 

Alternative D, the preferred Alternative. This alternative provides reasonable 

motorized access while maintaining some secure areas for wildlife within the 

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-159

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

17 TMA. This area is in close proximity to Big Timber and is a popular area for 

hunting and outdoor recreation. Motorized recreation opportunities on this type 

of land are extremely limited in the Big Timber area, and allowing moderate 

motorized access as proposed in Alternative D would be beneficial. Alternative D 

recommends a seasonal road closure but doesn't specify closure dates. Most 

road/resource damage occurs during the wet months of late winter and spring. 

From a resource perspective a closure during this time period would be most 

beneficial.

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

In regards to your specific comment regarding access to and within the Tin Can 

Hill property the RMP has a range of possible decisions. In this case, the 

decision to ensure adequate public access and protect the resources resulted 

in the determination that the current management direction was appropriate. 

The majority of the routes will remain closed to OHV use but available for nonmotorized use.

DRMTDK-BL13-0246-

18

Travel mngt

On page 2-130, Horsethief TMA, it appears that in Alternatives B & D on maps 

112 and 114, that the road running north off of Golf Course Road into the south 

side of Lake Mason NWR (T8N, R24E, Secs. 1 and T9N, R24E, Secs. 34 and 

35) is proposed as for administrative use only. FWP believes this is a county 

road, and thus is open to public travel with no restrictions.

n

Thank you for your comments. The BLM has reviewed the information used in 

its earlier decision and found that the mentioned vehicle route (HT 1003) is 

indeed a county maintained road. The decision has been altered in the 

document to reflect this. 

DRMTDK-BL13-0246-

19

Travel mngt

On page 2-129 -” 130, Gage Dome/Colony Road TMA, the road known as 

Iverson Road on Maps 108, 109, and 110 is proposed for a variety of options 

from open to administrative use only, depending on the Alternative. FWP 

believes this is a county road, and thus open to public travel with no restrictions. 

There are also two other roads on the Graves BMA (T1ON, R25E, Sec. 6) and 

Gage Dome BMA (T1 1N, R26E, Secs. 32 and 33) that are proposed to change 

from open to administrative use only in the preferred Alternative D. FWP 

currently shows these as open for vehicular travel on the BMA maps, and we 

recommend that these remain as open roads to provide reasonable access on 

the BMA.

n

Thank you for your comment. BLM has no route identified as “Iverson Road” on 

its route inventory and cannot respond to this observation. (However, if the 

route in question is a county-maintained road then BLM will not designate it). In 

response to the comment regarding the routes in T. 11 N., R. 26E., Sections 32 

and 33 – believed to be actually route GD 1005 - the RMP has a range of 

possible decisions and that a reasonable level of motorized access exists 

without the public use of this route. 

DRMTDK-BL13-0246-2

Wildlife 

On page 2-44, Sage Grouse -” All Sage Grouse Habitat, Alternative D, the 

preferred Alternative: the winter stipulation of a two mile buffer around leks is 

inadequate. FWP prefers Alternative B which uses the TL within four miles of a 

lek, but if that Alternative is not selected, FWP recommends an alternative with 

at least a three mile buffer. Research data shows that many female grouse may 

be located up to three miles from a lek during winter.

n

Thank you for your comment. Text will be changed in Table 2-5 to Reflect 

Tables in 2.6.1

DRMTDK-BL13-0246-

20

Wildlife

Page 3-82, Grizzly Bears: Currently occupied grizzly bear range includes the 

public lands along the Beartooth Mountain foothills, especially the east and 

northeast face of the Beartooths. BLM allotments include seasonal home ranges 

of numerous grizzlies. Grizzlies have also been documented in the Meeteetse 

Spires area

n

Thank you for your comment. This information will be updated in the final. 

Map #21 will be updated. Refer to Table2-6.1, under Wildlife HabitatManagement Common to All Alternatives, the statement “Assist in the 

restoration, reintroduction, augmentation, or re-establishment of T & E, special 

status, and priority species and other populations” etc. 

This is a recent issue and outside of the Grizzly Bear Recovery Zone. The 

grizzly bear mortalities occurred in 2011 and 2012 which was unusual. No 

mortalities had occurred until then and no grizzly bear/livestock conflicts 

occurred on BLM lands, but on adjacent private lands. BLM is currently 

consulting with USFWS on a grazing permit renewal and is recommending (in 

consultation with USFWS) several mitigation measures to reduce grazing and 

grizzly bear conflicts. BLM will continue to consult with USFWS, Endangered 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-160 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

Species Office.

DRMTDK-BL13-0246-

21

Wildlife Page 3-84, Long-billed curlew: BLM lands on the east side of the Beartooth 

Mountains are nesting and breeding habitat for these birds. n

Thank you for the comment. This area will be added to the observation 

narrative on page 3-85.

DRMTDK-BL13-0246-

22

Wildlife 

Pages 3-85 -” 86, Sage grouse: Poor grazing management is conspicuously 

absent from the list of factors causing deterioration of sage grouse habitat. 

Grazing and sagebrush manipulation are two of the most important factors 

affecting the quality of sage grouse habitat in south central Montana. FWP 

believes that greater emphasis should be placed on grazing management in the 

maintenance of sage grouse habitat. Also, there are contradictory statements 

regarding fire, one stating that wildfire causes habitat loss, and another saying 

that disturbances such as fire allowed sagebrush to persist on the landscape. In 

general, fire results in the long-term loss of big sagebrush habitat.

n

Add the following underlined statement to page 3-85 referencing sage grouse 

threats at the end of paragraph 4. A summary of “Threats to Greater SageGrouse and Their Habitat” is described in Appendix AA (section B). 

Grazing management is listed as the second threat from the 2005 Management 

Plan and Conservation Strategies for Sage-Grouse in Montana.

The document states - “disturbances such as fire allowed sagebrush to persist 

on the landscape.” appears to be a poorly written statement when viewed out 

of context. The entire statement read, “Greater sage-grouse habitats in MZ1 

were historically a function of the interaction of physical factors(....) , and 

natural disturbance factors (e.g., fire, grazing, drought) that allowed sagebrush 

to persist on the landscape. These physical and natural factors combined to 

produce an interspersion and juxtaposition of different habitats that included 

large expanses of sagebrush patches favorable for greater sage-grouse 

occupation.” Also, later in the same paragraph on page 3-87 it states, “Big 

sagebrush is easily killed by fire at all intensities, ...”

DRMTDK-BL13-0246-

23

ACEC

Pompeys Pillar National Monument and ACECFWP had some difficulty 

distinguishing between management actions intended for each area specifically 

or for the area as a whole, and as such, the distinction between the Monument 

and the ACEC should be made clearer. In general though, FWP is concerned 

with the lack of emphasis on the FWP/BLM/Pheasants Forever Habitat 

Partnership to enhance wildlife habitat and increase recreational opportunities, 

including hunting, on the ACEC. Under Issue 10 from Chapter 1, page 1-14, it is 

stated that Pompeys Pillar National Monument and ACEC will be managed to 

provide for interpretation, use, and enjoyment while protecting the significant 

resource values, providing for user safety, and maximizing socio-economic 

benefits. FWP has made substantial investments of manpower and dollars to the 

Habitat Partnership, and we would like to see that stated more specifically. FWP 

would also like to see a statement in this document that clearly identifies the 

Habitat Partnership, habitat enhancement through agricultural practices, and 

hunting as long-term priorities on the ACEC.

N

Thank you for your comment. Text will be revised in chapter 3 in response to

your comment. 

DRMTDK-BL13-0246-

ACEC

On page 2-122, fourth paragraph from top, the following statements are made: 

Cultivation for wildlife habitat improvements at the Sundance Lodge Recreation 

Area and at Pompeys Pillar ACEC would continue. Changes in cultivation 

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-161

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

25 patterns, seasons of use, and type of activity, including termination of use, could 

occur during project level review. The first sentence states that wildlife habitat 

improvements will continue on both areas, but the second says that changes

may be made including termination of use. FWP Is unsure of the intent of this 

statement, and hope that it does not reflect a lack of commitment by BLM to the 

Habitat Partnership

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS.

DRMTDK-BL13-0246-

26

ACEC

On page 2-195, first paragraph, Under all Alternatives, Pompeys Pillar ACEC 

(432 acres) would continue to be managed to protect the historical, cultural, and 

biological values, including its outstanding viewsheds and unique resources of 

the area. Emphasis on providing opportunities for interpretation, education and 

enjoyment of the area would continue. Again, FWP would like to see mention of 

the Habitat Partnership and hunting somewhere in this paragraph.

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS.

The ACEC is being managed for the relevant and important values for which it 

was designated. 

DRMTDK-BL13-0246-

27

edits

On pages 2-139, at the bottom of the page under Management Zones, 

Alternative A lists the utilization of agriculture in the General Management Zone, 

but Alternatives B, C, and D (which include the preferred alternative) do not 

mention agriculture. Agricultural practices are vital components of managing the 

wildlife habitat in this area. FWP believes this could open the door to phasing out 

the use of agricultural practices by placing higher priority on visitor service needs 

(i.e., interpretive signs, trails, picnic areas, etc.) to the detriment of habitat and 

hunting, the primary emphasis of FWP's participation in the Habitat Partnership.

n

Thank you for your comment. Text has been changed in chapter 2 to address 

your concerns.

DRMTDK-BL13-0246-

28

Wildlife

On page 3-71, section 3.7.3.1.10, Primary threats to upland game bird 

populations in the planning area include habitat loss, habitat fragmentation, 

possibly West Nile virus, and adverse weather conditions. Hunting pressure can 

also affect upland game bird population locations where hunting pressure is 

concentrated, such as Pompeys Pillar. Hunted birds may move to adjacent 

habitat as hunting pressure increases. However, as with big game, MTFWP 

regulates upland game bird hunting. FWP is not sure about the intent of the 

statements concerning hunting pressure. While there may be some temporary 

displacement of individual birds as a result of hunting pressure, particularly in 

poor quality habitat, FWP disagrees that populations are shifted as a result of 

hunting pressure. The purpose of the Habitat Partnership is to provide high 

quality habitat that produces birds and maintains numbers on the area whatever 

the hunting pressure.

n

Thank you for your comment. Text has been changed in Chapter 3 to address 

your concerns.

DRMTDK-BL13-0246-

29

Wildlife

On page 3-191, section 3.21.2, An agreement with MTFWP and the Yellowstone 

Chapter of Pheasants Forever enables them to assist BLM with management of 

the property. FWP appreciates the mention of FWP and Pheasants Forever, but 

would like to see the Habitat Partnership described and emphasized in more 

detail.

n

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS. The issue raised in your comment will be considered by the Billings 
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Field Office during implementation of the Approved RMP when project-specific 

plans are prepared or evaluated. MTFWP and the Yellowstone Chapter of 

Pheasants Forever have agreed to de-emphasize by the end of 2014, 

management priority for Sundance Lodge due to conflicts between wildlife 

habitat and intense recreational use of the area. The area will remain open for 

hunting

DRMTDK-BL13-0246-3

Wildlife

On page 2-46, Big Game Winter Range, Alternative D, the preferred Alternative: 

CSU - Within big game winter range habitat (Maps 15-20), the proponent would 

be required to conduct big game inventories in the project area prior to 

conducting any operations. If big game concentrations are found, the following 

CSU constraint would apply to maintain the habitat, avoid habitat loss and 

minimize disturbance: surface occupancy and surface disturbance density and / 

or mitigation plan. FWP's experience indicates that the use of winter range in a 

given year depends on a variety of factors including winter severity, forage 

conditions, big game density, and land use practices on adjacent lands. Thus the 

number of animals present at any one point in time may or may not be an 

accurate depiction of winter range. If an area is mapped as big game winter 

range on the included maps, it should be treated as such regardless of the 

number of animals present at a particular time. FWP supports Alternative B 

which applies stipulations to all mapped winter range. FWP makes an exception 

to this recommendation for antelope. Antelope winter range is not mapped in the 

draft RMP, as FWP has not identified specific antelope winter range. However, 

all general antelope range is also potential winter range. If a lease/disturbance is 

proposed outside of existing defined big game winter range, we recommend the 

proponent conduct multiple antelope surveys during the winter period prior to 

conducting any operations. If antelope are present then the CSU (density and 

mitigation) for big game winter range should apply. If/when an antelope winter 

range map is developed by FWP, it could be incorporated into the RMP and 

treated like other big game winter range.

n

Instruction Memo No. MT-2010-004, 

“Guidance on Coordination with Montana Fish, Wildlife and Parks During Oil 

and Gas Lease Parcel Reviews,” 10/7/-2009. The new procedures were 

developed at the request of MTFWP and coordinated with the FOs, MTFWP, 

and the Montana State Office, BLM. All leasing decisions are coordinated with 

MTFWP. 

DRMTDK-BL13-0246-

30

Edits 

On page 3-212, section 3.26.4, In addition, the Pompeys Pillar property has 

been and remains a rich habitat for fish and wildlife resources. The wildlife 

species present there are typical of the riverine environment of the middle 

Yellowstone Valley in the early nineteenth century. FWP would like to see 

mention of the introduced species ring-necked pheasant and Merriam's turkey 

as contributing much desired recreational opportunities for the public.

n

Thank you for your comment.

Text has been changed in Chapter 3 to address your comment

DRMTDK-BL13-0246-

31

Edits

On page 3-213, section 3.26.5, Pompeys Pillar also offers exceptional 

recreational activities, including hunting, in the general management zone. 

Wildlife viewing, photography, and dispersed recreational opportunities are 

among the most frequently-use visitor uses. FWP appreciates the specific 

mention of hunting here. The other activities listed should be included, but these 

are not the most frequently-used visitor uses -” far more hunting occurs in this 

n

Thank you for your comment. Text has been edited in response to your 

comment.
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zone than any other activity. Additionally, the FWP acquisition should be listed 

as the Yellowstone Wildlife Management Area and Yellowstone River State Park 

rather than the Circle R.

DRMTDK-BL13-0246-

32

Wildlife

On page 4-7, section 4.1.1.4.4, Various treatments have been applied across the 

decision area to improve wildlife and fisheries habitat. The majority of the acres 

impacted include food plots which are planted on an annual basis at the 

Sundance Lodge SRMA and Pompeys Pillar ACEC. Since 2006, an average of 

84 acres per year has been planted collectively between the two areas. These 

treatments are expected to remain at this level over the life of this plan. FWP 

appreciates the statement that the food plot treatments are expected to continue 

over the life of the plan. Additional information could be provided about the 

conversion of crop and hay ground to permanent nesting cover. Also, it should 

be noted that these activities are largely being done through the Habitat 

Partnership.

N

Thank you for your comment. Text has been changed in Chapter 4 to address 

your concerns.

DRMTDK-BL13-0246-

33

NEPA

BLM Lands Within Or Adjacent To FWP WMAs FWP finds no reference to any 

special designation or protections given to BLM lands within or adjacent to FWP 

WMAs. There are BLM lands within or adjacent to Big Lake, Haymaker, Silver 

Run, and Yellowstone WMAs. Surface disturbing or other significant habitat 

altering activities on these lands could adversely affect the WMAs. FWP asks 

that BLM give some additional consideration to protecting these lands from 

development.

N

Thank you for your comment. 

Should development occur on the BLM parcels identified, site specific NEPA 

analysis would occur and the MT FWP would be invited to comment on the 

NEPA analysis.

DRMTDK-BL13-0246-

34

Fisheries

Fisheries comments on the Billings Area RMP: FWP recommends adoption of 

fisheries protections proposed in Alternative B including 1/2 mile NSO setbacks 

on blue and red ribbon trout streams, YCT populations and YCT suitable habitat, 

and 1/4 mile setbacks on riparian areas, wetlands, water bodies, all perennial 

streams, and flood plains of perennial streams. These stipulations provide the 

best protection for the important native and recreational fisheries and habitat 

located in this RMA, and also provide reasonable protection for all perennial 

streams and wetlands in the area. These setbacks not only provide good 

protection from disturbance of riparian areas and from the impacts of 

sedimentation due to development, but they also provide enough of a buffer 

zone to prevent contamination of important waterways from potential spills that 

can occur during development or operation. Setbacks also help protect the 

important recreational value of the rivers and streams in this RMA by protecting 

the scenic value for recreational users along these waterways. Similar protection 

for the aquatic environment has already been established in the Butte RMA plan 

and it is important to maintain consistency between adjoining RMAs. FWP 

admits that many of the streams shown on Map 28 Volume IV as YCT suitable 

recovery habitat are no longer suitable for recovering YCT due to dewatering, 

the presence of nonnative fish populations or other habitat changes, and these 

streams may not warrant a I/2 mile NSO setback. However, the final RMP 

n

Thank you for this comment.

During NEPA analysis conducted at the project level for any action with 

potential effects to the environment, BLM resource specialists will identify 

potential impacts to fisheries and fish habitat, including suitable recovery 

habitat.

In Section 2, pgs 2-80 and 81 of the DRMP, BLM incorporates multiple actions 

in the “management common to all alternatives” section. These actions 

correspond with guidelines set forth in the Conservation Strategy for YCT. With 

these management actions in place, NEPA analysis would identify impacts to 

YCT habitat, occupied or otherwise and ensure decisions are made that will 

protect that habitat.
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should specify that there will be a site-specific analysis on any potential lease 

involving any of these streams not protected by other designations before these 

leases are exempted from the 'A mile NSO.FWP has concerns with waiver, 

modifications and exemptions for all stipulations as written in the current 

document. Before the BLM modifies any stipulation, FWP recommends that BLM 

consult with other potentially impacted agencies including FWP to obtain 

concurrence on potential changes. The fisheries recommendations contained 

herein have already been established in other RMPs in Montana, and 

cumulatively, the fisheries recommendations will impact less than 10 % of the 

Federal fluid mineral estate in the Billings planning area. With today's technology 

including directional drilling, these stipulations should not prevent the 

development of any mineral resources in the management area, but will provide 

vital protection for the important aquatic resources in the area.

DRMTDK-BL13-0246-4

Wildlife 

Also, regarding big game winter range, acceptable levels of surface disturbance 

density are undefined in the plan. We request that FWP consultation be required 

under Alternatives B and D to determine acceptable levels of surface 

disturbance density for each proposed development site as needed.

n

Surface disturbance density would be coordinated with MTFWP. Density will 

be dependent on many parameters including habitat condition, terrain, animal 

species affected, development density, type of development, etc.

DRMTDK-BL13-0246-5

Wildlife 

Regarding Big Game Parturition Areas, in various places in the draft RMP there 

are TLs for "established big game parturition habitat". Since FWP has not 

mapped such areas, this designation in its present form is of limited use. 

Parturition habitat is typically rather dispersed across the landscape, frequently 

occurs on portions of the winter/spring range, and varies by species. This is not 

conducive to coarse scale mapping. One solution would be to continue the 

winter range stipulation through July 1, which for the most part, is what the 

Forest Service has done (at least locally). Another possible approach is to 

require consultation with the local biologist before permitting work during the 

spring period on any big game winter/spring range. Similar to antelope winter 

range, mention should be made that if FWP develops such maps in the future 

these can be incorporated into the RMP.

n

MTFWP would be consulted on any spring activity affecting big game 

parturition. Instruction Memo No. MT-2010-004, 

“Guidance on Coordination with Montana Fish, Wildlife and Parks During Oil 

and Gas Lease Parcel Reviews,” 10/7/-2009. The new procedures were 

developed at the request of MTFWP and coordinated with the FOs, MTFWP, 

and the Montana State Office, BLM. All leasing decisions are coordinated with 

MTFWP.

Other future research and data will be incorporated through the “Adaptive 

Management” approach described in Section 2.3.4, 

DRMTDK-BL13-0246-6

Wildlife 

On page 2-46, Bighorn Sheep, we support NSO on designated bighorn sheep 

range. FWP is confused about Alternative D (the preferred Alternative) that lists 

NSO, but also has a CSU. How there can be a CSU when an NSU is in place?

n

Note that on page 2-72, the NSO applies to bighorn sheep lambing and winter 

range. The CSU applies to all bighorn sheep habitat. “Lambing and winter 

range” will be added to clarify that statement.

DRMTDK-BL13-0246-8

Wildlife 

On page 2-72, Big Game Winter Range, Over the snow vehicles would be 

prohibited in big game crucial winter range. FWP has not used the designation 

'crucial winter range', but uses only the designation 'winter range'. The reference 

to 'crucial winter range' should be removed from this statement and other places 

where it is referenced in the document and replaced with 'winter range'.

n

The term “crucial” will be deleted in that statement. Although, designated 

Crucial Winter Ranges will be used in lieu of CAPS data when the data is 

available. If crucial winter range data is not available, CAPS data will be used. 

Any references to CAPS data will be updated when Crucial Winter Ranges are 

designated.

DRMTDK-BL13-0246-9

Wildlife 

On page 2-79, Sage Grouse, Alternative D (the preferred Alternative), the winter 

stipulation of a two mile buffer around leks is inadequate. FWP prefers 

Alternative B which uses the TL within four miles of a lek, but if that Alternative is 

not selected, FWP would like an Alternative with at least a three mile buffer. 

n Thanks for your comment. 
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Research data shows that many female grouse may be located up to three miles 

from a lek during winter.

DRMTDK-BL13-0247-1

NEPA

In addition to the DEIS comments I provide in this letter, I urge you to grant at 

least a 120-day extension to the DEIS comment period in order to give all the 

interested parties adequate time to provide meaningful comment upon the DEIS. 

This request comes for several key reasons. First, the sheer volume of the 

document makes it impractical for ordinary citizens to evaluate the DEIS and 

make informed comments. The DEIS consists of multiple volumes numbering 

several thousand pages. The maps, backup materials and cited references 

require additional research time and effort that extends the ordinary reader 

beyond a 90-day deadline for effective review. Second, as I understand the 

current document, it is at least partially incomplete. The Billings and Pompeys 

Pillar National Monument DEIS did not contain individual route reports for 

motorized and multiple-use recreation closures when it was published. BLM sent 

out an e-mail notice on May 13, 2013 with a web site link to the detailed route 

information. However, when my staff attempted to follow this web site link, the 

Internet browser could not display the information. Attached to this letter is a 

screen shot of the browser's attempt to retrieve this information. I have serious 

concerns about the public's ability to access information that is vital to their 

ability to review the BLM's proposed decision because this travel information 

was provided nearly halfway through the public comment period, and because it 

appears to be inaccessible even after it was posted. The National Environmental 

Policy Act and its implementing regulations require an agency to provide the 

detailed information on its proposed decision to the public. It appears BLM has 

failed to meet that standard in this instance. The third reason I request an 

extension is because I understand that a significant part of the BLM's plan is 

intended to protect sage grouse habitat and populations. While I support this 

goal, I fear the proposed plan is an unnecessarily onerous restriction upon oil 

and gas development, coal development, agricultural grazing and operations, 

multiple-use recreation, and other important public lands uses in this area. I 

believe there is a more effective way to protect sage grouse without drastically 

impacting Montana's major economic drivers in over one-third of the State. The 

area covered by this DEIS is one of the most important future economic 

development areas in Montana. BLM manages 3 million surface acres and 12 

million sub-surface acres. In addition to that, the activity or restrictions on BLM 

land affects neighboring private, state and Tribal land. In short, a poorly-crafted 

or overly-broad BLM land use restriction can have the effect of shutting down 

resource development on neighboring lands owned by others, including the 

State of Montana. Eastern Montana has vast untapped oil, gas, coal, wind and 

other resource potential, and I believe the BLM restrictions proposed in the DEIS 

could have untold consequences for current and future generations of Montana 

N Thank you for your comment.
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workers and families. As you may know, Montana Governor Steve Bullock 

recently appointed a Sage Grouse Advisory Council According to the Montana 

Department of Fish, Wildlife & Parks (FWP) Director Jeff Hagener, "The council 

will lead the effort to develop and carry out management options to ensure sage 

grouse are maintained as an integral part of Montana's wildlife heritage while still 

allowing other managed uses of the land." I strongly urge you to extend the 

DEIS comment period so the Governor's Sage Grouse Advisory Council and 

Montana FWP can have the appropriate time to review this proposal, provide 

additional substantive comment, and chart a plan for Montana to take the lead in 

protecting and managing this important species, rather than the BLM doing so in 

a manner that harms other vital state interests. The fourth reason this plan 

needs an extension period is because the BLM's land planning efforts appear to 

be exceeding its authority in the arena of air quality. Under the Clean Air Act, the 

Environmental Protection Agency and the State work hand in hand to manage 

for clean air standards, with the State as the primary and preferred air quality 

management sovereign. As you may know, Montana and the EPA have recently 

completed an air quality plan for the State. The BLM's management under the 

DEIS appears to have been created in isolation from the EPA / Montana plan, 

and is in fact more restrictive than that plan. I urge you to examine this issue, 

and to allow all parties more time to evaluate this troubling proposal. Finally, I 

have serious concerns about the way the DEIS cooperated with numerous 

Montana local governments, including county commissions and grazing districts, 

under the cooperating agency status provisions in federal law and regulations. 

As you are aware, land management documents like this must be consistent 

with local government resource plans. If they are inconsistent, the DEIS must 

disclose and discuss any inconsistencies with local plans and laws, and discuss 

how these inconsistencies will be reconciled. The DEIS must evaluate the 

environmental consequences resulting from its conflict with local resource plans. 

And perhaps most importantly for this document, the DEIS must evaluate and 

discuss the economic impact of its proposed action, and the impact of its 

inconsistency with local government resource plans. In this regard, numerous 

local governments have expressed to me that the DEIS did not evaluate their 

resource plans, did not evaluate inconsistencies with such plans, and did not 

adequately analyze the economic impacts of its restrictions compared to local 

government resource plans. These same concerned local government leaders 

also feel they were surprised by many of the provisions contained within the 

DEIS, which were contrary to what they had reviewed in their role as cooperating 

local government and agency representatives. I urge you to ensure BLM officials 

fully utilize the cooperating agency process in good faith, with full disclosure, and 

with respect to the role these local citizen representatives have under federal 

and state law. For all of these reasons outlined above, I urge you to give 
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Montana citizens and government leaders more opportunity to review this 

voluminous draft RMP. I believe a 120-day extension would assist all of us in 

evaluating and providing informed comments on this document. I look forward to 

your response, and I will appreciate the opportunity to work cooperatively with 

the BLM and Department of Interior officials on responsible land and resource 

management in Montana.

DRMTDK-BL13-0248-1

Air

DEQ is concerned that our federally approved authority to manage air quality 

resources within the State of Montana has not been properly considered or 

embraced within the resource management partnership reflected in the draft 

Billings and Pompeys Pillar Nation Monument Resource Management Plan and 

Environmental Impact Statement (RMP). As stated in the RMP, the 

Memorandum of Understanding Among the U.S. Department of Agriculture, U.S. 

Department of Interior, and U.S. Environmental Protection Agency, Regarding 

Air Quality Analyses and Mitigation for Federal Oil and Gas Decisions Through 

the National Environmental Policy Act [NEPA] Process (MOU) is an agreement 

designed to facilitate the completion of the National Environmental Policy Act 

environmental analyses for Federal land use planning and oil and gas 

development decisions. The MOU sets forth collaborative procedures that the Air 

Quality Technical Workgroup, consisting of representatives from Bureau of Land 

Management (BLM), EPA, U.S. Forest Service (USFS), U. S. Fish and Wildlife 

Service (FWS), and National Park Service (NPS) use to analyze potential air 

quality and air quality related value impacts and develop the adaptive 

management strategy outlined in the Air Resource Management Plan (ARMP). 

While DEQ appreciates the opportunity to review and comment on the draft RMP 

and work with BLM regarding monitoring and data sharing, the resource 

management partnership would be much better served if DEQ had the 

opportunity to be an active participant much earlier in the planning process. The 

following comments identify DEQ's concerns regarding inconsistencies with 

Montana's air quality program, policy, plans, and authority. BLM participates in 

the Montana-Idaho Interagency Smoke Management Coordination Strategy, 

along with other-Federal Land Managers and-DEQ. DEQ recommends 

incorporating information regarding the Montana-Idaho Interagency Smoke 

Management Coordination Strategy into the RMP. DEQ is concerned with the 

terminology used in the draft RMP. The draft RMP contains numerous terms with 

unique legal and technical meaning and implications under the CAA. In many 

cases, the draft RMP terminology is not clearly defined and may have different 

meanings than established by the CAA (i.e. -” adverse impacts, increment 

analysis, air quality related values, design value, etc.). NPS and FWS have 

asserted that all non-Class I areas under their jurisdiction should be considered 

to be sensitive Class II areas. The justification used to determine which areas 

should be considered sensitive Class II areas is unclear. Impacts to sensitive 

N

Thank you for your comment. See Appendix T, Air Resource Management 

Plan, Section 1.5. An additional description of the MDEQ air quality program 

and associated regulations has been added.
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Class II areas would be modeled in the same manner as Class I areas; this is 

inconsistent with CAA requirements. DEQ is concerned about the use of air

quality modeling at the planning stage. Without project specific information, 

several assumptions must be made to complete the modeling, which results in a 

quantitative analysis based on assumptions rather than an informed scientific 

evaluation. The draft RMP ARMP states that many small oil and gas emission 

sources are not required to obtain air quality permits from DEQ, unlike large 

stationary sources. This statement is misleading. As described above, DEQ 

implements a minor source program that requires sources with a PTE greater 

than 25 tons per year of any regulated air pollutant to apply for a permit to 

construct pursuant to the MAQP requirements or register with the DEQ pursuant 

to the registration requirements under the Administrative Rules of Montana. The 

vast majority of sources become regulated as a result of Montana's minor source 

permitting and 2 registration programs. In addition, many sources that fall below 

the 25 tons per year threshold have equipment standards and emission control 

requirements established through applicable New Source Performance 

Standards (NSPS). The draft RMP states that the oil and gas emission 

inventories were generally based on emission standards required by DEQ and 

EPA. The draft RMP identifies new Federal regulations and states that the oil 

and gas emission inventories will be updated in the final RMP to address these 

regulatory changes. However, it is not clear if BLM considered DEQ's 

reasonable precautions or emission control requirements in the inventory 

development. DEQ requests that BLM review their emission inventory 

assumptions and calculation for inconsistencies and ensure all applicable 

emission reduction requirements are considered and incorporated into the final 

RMP emission inventory as appropriate. Monitoring information provided in the 

draft RMP should be updated to reflect the current monitoring program. With the 

exception of the NCORE monitoring station, carbon monoxide monitoring was 

suspended throughout the state at the end of March 2011. In addition, the 

particulate monitor at the Billings St. Luke's Station is not a reference or 

equivalent method and the station does not meet EPA siting criteria. The Billings 

St. Luke's station is utilized for informational purposes only and does not meet 

the requirements to be officially used for NAAQS comparisons. DEQ requests 

that BLM review the monitoring station data provided within the draft RMP and 

supporting documents to ensure the ambient air quality concentration were 

calculated appropriately when comparing to the listed NAAQS standards. BLM 

has proposed monitoring-based mitigation measures in which monitoring data 

may trigger enhanced mitigation measures that are beyond BACT and NSPS. 

Under CAA authority, DEQ is required to take into account environmental benefit 

and economic and technical feasibility prior to requiring similar measures. In 

addition, DEQ is concerned that BLM may implement management strategies for 
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the entire planning area based on a single monitored exceedance. DEQ 

recommends that BLM consider establishing spatial limitations when requiring 

enhanced mitigation measures. It would be inappropriate to mandate mitigation 

measures for an entire planning area that are not consistent with the CAA. Prior 

to completion of the photochemical grid modeling (PGM), BLM would review 

NAAQS exceedances and determine if enhanced mitigation is warranted. BLM 

has proposed to monitor EPA's Air Quality System (AQS) database to determine 

if monitoring data is showing an exceedance. It is not clear what criteria BLM will 

use to determine if an exceedance has occurred. DEQ requests that BLM 

include an explanation of how an exceedance will be determined in the RMP. 

Additionally, once data is posted to the AQS, even though available for review, 

the data may not be certified for several months. It would be inappropriate to 

compare uncertified data to the NAAQS. Additionally, DEQ cautions BLM 

against imposing enhanced mitigation measures based on uncertified data. 

Following completion of the PGM, BLM has proposed to calculate site-specific 

design values for each pollutant monitored at a federal reference monitor within 

the planning area. If a BLM calculated design value is greater than 85 percent of 

the NAAQS, enhanced mitigation measures would be evaluated and selected by 

the BLM, in cooperation with DEQ, 3 etc., when appropriate. It is unclear to DEQ 

what criteria BLM will use to determine when it is appropriate or not appropriate 

to consult with DEQ. Additionally, establishing a threshold of 85 percent of the 

NAAQS does not appear to have any legal basis within the CAA. It is unclear 

under what authority BLM plans to implement mitigation measures based on this 

proposed threshold. It is unclear within the draft RMP who and how the 

proposed mitigation measures will be implemented and how DEQ would be 

involved in these efforts. DEQ must consider the implementation of any new 

requirements and ensure that these requirements are incorporated in a way that 

is consistent with DEQ's implementation authority. Furthermore, DEQ is 

concerned that BLM does not sufficiently recognize the potential conflicts and 

confusion certain proposed mitigation measures may cause with implementation 

of DEQ's air quality program.

DRMTDK-BL13-0249-1

NEPA

Impact Analysis Overall, FWP found the impact analysis section read more as a 

summary of the different alternatives and lacked specificity on the implications of 

a given action on a specific resource. We encourage the BLM to consider impact 

metrics that would specify the anticipated outcome to the resources. A metric, for 

example, might be density of well pads per section that can then be extrapolated 

to an estimated population response by sage-grouse. The lack of quantifiable 

impacts is not unique to the Billings Field Office; however, without a more 

detailed analysis it is difficult to support a particular action for a given resource.

N Thank you for your comment. 

DRMTDK-BLLivestock 

Grazing

Rangeland Health Standards FWP agrees that failure to achieve rangeland 

health standards negatively impacts the rangeland resource, and consequently n

Standards for rangeland health (Appendix I) were designed to cover the wide 

range of ecological sites, habitats, and individual species needs that occur 
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13-0249-2 sage-grouse. However, there is insufficient detail to ascertain how making 

progress toward or meeting rangeland health standards will contribute positively 

to sagegrouse habitat requirements. FWP has found variation in interpretation of 

rangeland health standards among BLM Field Offices in Montana. Quantifiable 

metrics are needed that allow the public to understand how rangeland health 

standards as applied in the Billings Field Office would affect sage-grouse 

habitats and ultimately populations.

throughout BLM managed public lands. Please refer to Standard 5. It is stated 

in this standard “The environment contains the necessary components to 

support viable populations of a sensitive/threatened and endangered species in 

a given area relative to site potential.” In 2012 BLM policy (Instruction 

Memorandum No 2012-043, listed in appendix A) regarding the greater sage 

grouse provided guidance, including quantifiable metrics, as to how the BLM 

would assess sage grouse habitat. This framework is listed in Appendix AA. If 

habitats do not provide the necessary components as outlined in the policy, the 

area fails standard 5. 

DRMTDK-BL13-0249-3

wildlife

The criteria used for designating sage-grouse habitat were provided for readers; 

however, FWP could not find a discussion of the site-specific factors that 

contributed to a particular designation. Specifically, most of the BLM lands in 

Yellowstone County and south Musselshell County were designated as Potential 

Restoration Areas, yet we found no text that described how the conditions in 

these areas differed from other sage-grouse habitat. Similarly, FWP could not 

find a description of how proposed management in Potential Restoration Areas 

would meet the stated objective of "...BLM would manage habitat so that sagegrouse populations can be restored over the long-term. BLM would strive to 

restore historical sage-grouse habitat functionality, or at a minimum, have no net 

loss of sage-grouse habitat, to support sage-grouse populations." We encourage 

BLM to more clearly articulate the differences between sage-grouse habitat 

designations and how the proposed management will meet the stated objectives.

n

Instruction Memorandum No. MT-2010-017, Nov. 30, 2009, “Guidance for 

Greater Sage-Grouse Management and Conservation in Resource 

Management Plan (RMP) Revisions in Management Zones 1 and 2 Within the 

Montana/Dakotas BLM” describes Montana BLM’s guidance for identifying and 

managing sage grouse habitat. More detail for Restoration Areas is described 

as: Restoration Areas: 

Maintaining populations is a priority for restoration because strong site fidelity in 

sage-grouse makes natural re-colonization slow and past precedence has 

documented that translocations into areas with no resident populations are 

unlikely to succeed. Therefore, in Restoration Areas, the goal is to achieve a 

balance between ongoing and future resource use so that enough quality 

habitat is maintained to allow some residual populations in impacted areas to 

persist. These remnant habitats and populations will likely decrease the time 

needed for restoration and reclamation efforts. In addition, maintaining

populations across the landscape will promote sage-grouse movement and 

genetic diversity so that sage-grouse habitat areas remain connected to one 

another in the future. The intent is to have connectivity between populations 

within and across management zones. In restoration areas, the variation in the 

density of current impacts may result in difficulties in applying universal 

stipulations that can meet the objectives for the area. Planning teams should 

consider options for varying stipulations across different levels/densities of 

impacts or quality of remaining habitat within the restoration priority areas (e.g., 

cluster development in the most impacted areas and have more stringent 

stipulations for the least impacted leks and habitat, or most important lek(s) 

needed for future restoration of sage-grouse populations).

Specific GIS data sources included: land ownership (surface and subsurface), 

vegetation/ habitat, surface disturbance, oil and gas activity, wildfire history, 

sage grouse lek locations and counts, etc.

Also, Page2-67, Sage-grouse habitat delineations may be modified as needed, 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-171

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

as local site conditions change or as new information becomes available.

DRMTDK-BL13-0249-4

NEPA

FWP requests that the BLM hold open sections of the RMP that address sage 

grouse conservation to allow inclusion of recommendations that arise from the 

Governor's Sage Grouse Habitat Conservation Advisory Council. The final 

recommendations from this Council will be released in January, 2014.

N Thank you for your comment. 

DRMTDK-BL13-0249-5

Wildlife 

FWP recognizes that development of land management plans takes multiple 

years, during which time new information can become available. We encourage 

BLM to incorporate more recent information in final Resource Management 

Plans, specifically: Montana Natural Heritage Program conducted Sprague's 

Pipit (ESA Candidate Species) surveys in 2012 and recently produced updated 

habitat suitability maps for the species. Habitat suitability maps show moderate 

to optimal Sprague's Pipit habitat in Wheatland, northern Sweet Grass, and 

northern Golden Valley Counties. FWP requests that BLM consult these data 

and address impacts of management actions on this species in priority 

Sprague's Pipit habitat. Montana Bird Distribution Committee. 2012. P.D. 

Skaar's Montana Bird Distribution, 7111 Edition. This document should be used 

in place of Lenard et al. 2003. Knick, S.T., Hanser, S.E., and K.L. Preston. 

2013. Modeling Ecological Minimum Requirements for Distribution of Greater 

Sage-Grouse Leks: Implications for population connectivity across their western 

range, U.S.A. Ecology and Evolution DOI- 10.1002/ece3.557. We encourage 

BLM to use and reference this paper where appropriate.

n

Thank you for the comment and references. Updated references will be added. 

BLM intends to rely on the latest research and best available science by 

utilizing existing research and incorporating other future research through the 

“Adaptive Management” approach described in Section 2.3.4, page 2-7.

. Refer to Table 2-6.1, page 2-70, “Surface-disturbing and disruptive activities 

would be avoided from April 15 through July 15 in Sprague’s pipit habitat. 

Surface use for oil and gas exploration, (including geophysical exploration) is 

prohibited from April 15 through July 15 in Sprague’s pipit habitat. (TL)

Sprague’s pipit habitat is defined as “Optimal or Moderately Suitable” habitat 

classes in MTNHP Maxent Inductive Model of Sprague’s pipit breeding habitat 

(2011, Map 25) 

Also, Sprague’s pipit needs to be added to Tables 2-5 and 2-6.2.

Note: There is a very small percentage of public land in Golden Valley and 

Wheatland counties. BLM can only manage habitat on public lands. 

DRMTDK-BL13-0256-1WILD 

HORSES,

PMWHR

the language in the preferred alternative seems to say BLM will manage to 

maximize resources for use of the horses. The horse range founding legislation 

calls for thriving natural ecological balance .. . a balanced program which 

considers all values without impairment to the productivity of the land". Words 

like balance, consideration of all values, appropriate management level seem to 

be in conflict with preferred alternative that repeatedly pushes the idea of 

increasing horse numbers and managing to maximize conditions for the horses.

N Thank you for your comment

DRMTDK-BL13-0256-

10

Travel mngt

Appendix 0 in the RMP speaks of "routes .. .. associated with specific recreation 

activities". Those listed include only "hunting, archery hunting, vehicle exploring, 

viewing wild horses and viewing wildlife." This short list leaves out many visitors 

who are looking for scenery, wildflowers, solitude, photography, butterflies, birds 

escape from hectic traffic and crowds, relaxation, clear skies for astronomy, 

complexity of plant communities, scientific studies and many more.

n

Thank you for your concern and your comment. The text has been amended to 

reflect your concerns

DRMTDK-BL13-0256-

11

Travel mngt

What about routes "associated with" foot or equestrian "exploring"? Or motorized 

routes for access to hiking routes? Comments have been made that people can 

just hike/ride anywhere - designated trails are not needed. What's a common 

question front line employees hear from walkers/hikers/horsemen? "Where are 

quiet trails I can use, where's the trailhead, do you have a map? I've never been 

here before and don't know where to go. My horse doesn't do well with ATVs." 

y

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-172 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

Most people would like a track to follow in the Pryors whether it's a loop or a 

destination with special views. The topography of the Pryor canyons does not 

lend itself to walking cross county unless the cross country travelers have 

advanced map skills and are knowledgeable about off trail travel in rugged 

terrain. The motorized roads, routes, two tracks, trails, travel ways, whatever 

they are called, have proliferated beyond reason in the Pryor Mountains. Wildlife 

secure areas and cover have become limited. Noxious weeds are spreading at 

an alarming rate. Any map will show a spaghetti-like tangle of motorized travel in 

the Pryors and its accompanying veil of noxious weeds. In BiFO's TMA the 

preferred alternative has130 miles designated for motorized users - ZERO miles 

are designated for non-motorized users.

The BLM Travel Plan section in the RMP has been altered to reflect the new 

BLM Manual 1626 prescriptions and guidance, which proscribes designating 

both motorized and non-motorized travel components. Please see Chapter 2 

and Appendix O for non-motorized changes.

DRMTDK-BL13-0256-

12

Travel mngt

Change the current method of providing motorized and non-motorized recreation 

opportunities which designates motorized routes now while "non-motorized 

routes would be considered .. [later]" Both need to be designated now in a 

balanced plan to provide diverse recreational opportunities and minimize use 

conflicts. The designation of certain tracks for motorized use now precludes their 

designation as nonmotorized routes later. Motorized routes should not get "first 

choice" with non-motorized routes getting the "left-overs". In making a travel 

plan, address the issue of conflict of uses as well as conflict of users. 

Acknowledge that motorized recreation consumes more of the resource than 

does non-motorized recreation per RVD.

n

Thank you for your concerns and comments. The BLM Travel Plan section in 

the RMP has been altered to reflect the new BLM Manual 1626 prescriptions 

and guidance, which proscribes designating both motorized and non-motorized 

travel components. Please see Chapter 2 and Appendix O for non-motorized 

changes. 

DRMTDK-BL13-0256-

13

Travel mngt

Recognize and explain to the public the difference between authorized and 

unauthorized motor routes. Removing an unauthorized route from public use is 

NOT closing a road - it is correcting a trespass.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

DRMTDK-BL13-0256-

14

Travel mngt

The initial segments of the Bear Can on Creek Trail from the BLM barricade (0.5 

mile) to the Forest boundary and the Bi S Trail (1 mile) should be designated for 

non-motorized use.. Walkers should not have to compete with 4WDs before they 

get to non - motorized trail.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed to motorized vehicles” while allowing motorized access by BLM 

administrative purposes. The route will be designated as a no-motorized trail. 

Refer to map 146

DRMTDK-BL13-0256-

Travel mngt

BLM's preferred alternative authorizes an additional motor vehicle route 

(Graham Trail) up the southwest slope of Big Pryor Mountain. Now is the time to 

designate non-motorized routes to ensure a balance. Bear Canyon, with its 

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-173

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

15 designation as an Audubon Important Bird Area, would be the best nonmotorized route beginning at the mouth of the canyon.and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed” for motorized use with the exception of administrative access. 

Refer to map 146

DRMTDK-BL13-0256-

16

Travel mngt

Demijohn Flat, both a National Register District and an Area of Critical 

Environmental Concern, should be non-motorized. Motorized travel on the 

Demijohn Flat route threatens an important cultural area. Designation of the 

route as non-motorized would provide a good non-motorized route while 

protecting the area. No need for 4WD to get to the trailhead, there is convenient 

access point on Crooked Creek Road.

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS. 

Demi-John Flat is a NR district, but only a portion of it is included in the Burnt 

Canyon WSA and East Pryor ACEC (alt A). Alt D includes all of Demi-John Flat 

NR district within either the WSA or the ACEC. 

In regards to the Demijohn Flat route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed” for motorized use with the exception of administrative access. 

Refer to map 146

DRMTDK-BL13-0256-

17

Travel mngt

The road (variously numbered 1082, 1077, 1076) that parallels Helt Road from 

its junction with Graham Trail in section 31, then crosses Stockman Trail in 

through section 5 to intersect with Bear Canyon Road and continues through 

sections 9 & 10 to intersect Horse Haven Road is redundant as a motorized 

route. The distance between the two tracks is variable but less than half a mile. 

The parallel road should be designated as a non-motorized route which allows 

non-motorized loop options

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

The road is presently closed and remains so in the final RMP. It will be 

available for non0motoirized use. Refer to map 146

DRMTDK-BL13-0256-

18

Travel mngt

Create an inventory of "redundant roads, tracks, travel ways, routes" for 

reclamation over the next five years and budget them into the general plan of 

work.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

The comment is appropriate to the follow-on Implementation-level Plan for the 

TMAs and will be incorporated into that Plan. 

DRMTDK-BL13-0256-

19

Travel mngt

Consider whether safety of the general public is being impaired by the lack of 

regulations or rules regarding age at which an individual can responsibly 

drive/ride a motor vehicle. Presently, there is no regulation or direction. I have 

seen children who appear to be under the age of 8 years driving ATVS in the 

n

Thank you for your concerns and comments. In regards to age restrictions for 

operating OHVs, the BLM defers to the State of Montana regulations. The 

enforcement or compliance of these regulations is not an RMP level issue. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-174 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

Pryors. See High Country News June 24, 2013; The ATV Culture Includes Loose 

Regulations and Kids’ Funerals by Ray Ring.

DRMTDK-BL13-0256-2WILD 

HORSES, 

PMWHR

the preferred alternative direction ignores the issue of special plants (Lequellera 

and Shoshonea) within the horse range. I strongly recommend this section in the 

alternatives on horse management be rewritten to reflect the intent of the 

founding legislation.

N

Special status plants would not be addressed under wild horse management, 

but rather Special Status Plants. No information has been provided that 

impacts to special status plants are actually occurring. 

DRMTDK-BL13-0256-

20

Vegetation 

Invasive 

Species 

and 

Noxious 

Weeds

Incorporate an aggressive program of weed control in the travel management. 

Consider emergency road closures on routes that have serious noxious weed 

infestations. New construction of any kind should have a line item in the 

construction budget for weed control. Any ground disturbing activity on or near a 

road/trail should be monitored frequently to catch and treat new starts of noxious 

weeds. Continue to map weed populations and use all appropriate controlpulling, spraying and biologic agents on weeds. Continue to provide information 

brochures on weeds for the public and provide in depth information on weed 

interpretive sites at BLM boundaries and other appropriate locations along 

heavily traveled routes.

n

Thank you for your comment. 

The type of issues raised in your comment will be considered by the Billings 

Field Office during implementation of the Approved RMP when project-specific 

plans are prepared or evaluated.

DRMTDK-BL13-0256-3

Locatable 

Minerals

Commodity uses and removals such as fluid minerals leasing, common salable 

minerals, timber harvests, grazing are extractive in nature. They take away nontangible resources of quiet, solitude and viewsheds as well as tangible resources 

of clean water, healthy productive ecosystems in the process of removing 

minerals. Commodity uses and removals must take a back seat when in conflict 

with protecting the Pryors landscape and ecosystems. Use No Surface 

Occupancy liberally

n

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS.

DRMTDK-BL13-0256-4

Vegetation 

Invasive 

Species 

and 

Noxious 

Weeds

Weeds can destroy a healthy ecosystem. Eradication of all noxious and invasive 

weeds must be a major priority for all managers and users of public lands. BiFO 

should develop a flexible emergency closure plan to close areas of high density 

weed infestations to motorized traffic until weeds are eradicated or brought 

under control. Or, a good management strategy may be keeping traffic out of 

weed-free areas.

n

Thank you for your comment. 

The type of issues raised in your comment will be considered by the Billings 

Field Office during implementation of the Approved RMP when project-specific 

plans are prepared or evaluated.

DRMTDK-BL13-0256-9Travel 

mngt, 

recreation

Allocations of recreation opportunities must concede and factor into a use plan 

the reality that motorized recreation uses are heavier on the land per Recreation 

Visitor Day (RVD) than non-motorized recreation. Four ATVs with drivers 

consume a greater quantity of solitude, quiet and open space because of higher 

speeds and larger areas covered than do four hikers in the same time period. 

There is a point at which the numbers of recreationists (particularly motorized) 

over-consume the limited quantities of the very qualities they have come to the 

mountains to experience. Think what carrying capacity implies with grazing and 

timber - then consider that concept of carrying capacity in regard to recreation 

use.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

DRMTDK-BLWater The "2007 Montana Nonpoint Source Management Plan" is obsolete. It was 

replaced in 2012 by the "2012 Montana Nonpoint Source Management Plan". n Updated, Thank you. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-175

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

13-0264-1 The current (2012) plan is available for download at the following DEQ website: 

http://deq.mt.gov/wqinfo/nonpoint/NonpointSourceProgram.mcpx

DRMTDK-BL13-0264-2

Water 

The 2010 Montana 305(b)/303(d) Integrated Report (for example, referenced on 

page 3-54) is outdated. Facts and figures from the 2010 report may have 

changed in later versions. The current version is the 2012 Montana 

305(b)/303(d) integrated Report. A copy may be downloaded from the following 

website:http://cwaic.mt.gov/wq reps.aspx?yr=2012qryld=101445

n Will Update 3-54 and reference to it.

DRMTDK-BL13-0264-3

Water 

Pages 1-22 and 1-23, Section 1.5.2 The Salinity TMDL for Sage Creek, 

Montana (MDEQ 2002) is referenced in this section. It was written for a 

geographical area well outside the planning area for the Billings DRMP

n Thank you, will delete.

DRMTDK-BL13-0264-4

Riparian 

Please include the "Priceless Resources, A Strategic Framework for Wetland 

and Riparian Area Conservation and Restoration in Montana, 2013 -” 2017". A 

copy of this document may be downloaded by clicking on the cover page photo 

in the lower right-hand quadrant of the following DEQ web page: 

http://deq.mt.gov/wqinfo/wetlands/default.mcpx

n Added to page 1-22 list of state plans.

DRMTDK-BL13-0264-5

NEPA

Page 1-27, Section 1.6.2 It is not clear if the Montana Department of 

Environmental Quality has been invited to be a cooperating agency. MDEQ's 

Watershed Protection Section, responsible for the State's Nonpoint Source 

Management Program has an interest in addressing and support water quality 

protection and restoration from nonpoint source water pollution, including 

grazing practices. The Section would be interested in future cooperating agency 

opportunities.

N

Thank your for your comment. MTDEQ was invited to become a cooperating 

agency but either did not respond or declined. See table 5-1 in Chapter 5 for all 

the agencies invited to become cooperating agencies on this document.

DRMTDK-BL13-0264-6Livestock 

grazing, 

riparian

Based on the Billings DRMP it appears that, in fact current policies and 

procedures for prescribing grazing BMPs DO NOT prevent riparian area 

degradation on approximately half of the riparian areas in the decision area. 

DEQ strongly recommends changes to the preferred alternative and the current 

grazing guidelines. They appear to have failed to meet the minimum 

requirements set forth in 43 CFR 4180.2(e) (see page 3-187 of the Billings 

DRMP) which include: Maintain or promote adequate amounts of vegetative 

ground cover Maintain or promote subsurface soil conditions Maintain, improve, 

or restore riparian-wetland functions Maintain or promote stream channel 

morphology Promote the opportunity for seedling establishment Maintain, 

restore, enhance water quality

n

Table 3-17 shows that 40 % of the riparian areas are in PFC, and 46% are in 

FAR. Therefore 86% of the riparian areas are Functioning. FAR is defined in 

the glossary as “A condition in which vegetation and soil are susceptible to 

losing their ability to sustain natural functioning biotic communities.” While 50% 

of the riparian areas are FAR they are still functioning. 

Table 3-17 shows that 40 % of the riparian areas are in PFC, and 46% are in 

FAR. Therefore 86% of the riparian areas are Functioning. FAR is defined in 

the glossary as “A condition in which vegetation and soil are susceptible to 

losing their ability to sustain natural functioning biotic communities.” While 50% 

of the riparian areas are FAR they are still functioning.

The BLM is required to make changes to the grazing permit, if livestock is a 

causal factor of riparian degradation. As permits are renewed or riparian 

conditions are identified, these changes are made. Further monitoring then 

allows managers to determine if the changes were successful in improving 

riparian conditions. At which point, more changes may be needed to reach 

objectives. With this information, you can see how the process could take some 

time to get the grazing and riparian system in balance. The key to this comment 

response, though, is the fact that only eight percent of riparian areas are rated 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-176 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

as non-functional. A degraded system, to a point, can still be rated as 

“functional”, but “at risk”.

A relatively new policy of analyzing impacts to livestock grazing permit renewals 

using NEPA Environmental Analysis will help identify issues with riparian health 

and promote livestock grazing and other activity decisions to improve or 

maintain riparian function.

DRMTDK-BL13-0272-1

Wildlife, 

It is difficult to maintain wildlife habitat i.e.: sage grouse if predators are allowed 

to continue destroying wildlife and domestic animals. The predators are out of 

control in the Grove Creek area. Every night we hear coyotes howling and have 

seen wolves and coyotes around the MT/WY lines. Coyotes and wolves love 

grouse eggs which are easily accessible for them. A hunting season for a bird 

that is supposedly considered scarce should be discontinued. Closing existing 

roads on BLM land is not the answer to saving the sage grouse.

n

Thank you for your comment. A discussion of “Predators in relation to sage 

grouse management” has been included in Chapter 3, pg.3-90.

DRMTDK-BL13-0272-2

Travel mngt

The present roads need to remain open for private land owners to access their 

property and homes by motor vehicle. As Grove Creek property owners, we also 

use these roads for recreational travel.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

BLM’s approach to Travel and Transportation management is set by BLM 

Manual 1626 and Technical Reference 9113-1 which has as its objectives the 

establishment of a sustainable multi-modal (including motorized, nonmotorized, mechanical, and even animal powered modes of travel) 

transportation system of roads, primitive roads, and trails that address public 

and administrative access, support the agency’s mission and provide resource 

protection, as well as to manage these resources and uses in accordance with 

law, Executive Order, proclamation and policy. The decisions in the RMP reflect 

these considerations, not just for the purposes of recreational or private land 

access. Please note that the RMP states that the goal for the Grove Creek TMA 

is to minimize impacts to geologic, visual attributes, sensitive plants, cultural, 

and wildlife values while providing access for the public, permittees, non-federal 

landowners, and administrative needs.

DRMTDK-BL13-0272-3

Fire 

Ecology 

and 

Manageme

nt

Full suppression needs to be maintained for fire equipment to travel thru to 

suppress fires. The sideboards on how fire suppression would be maintained 

needs to be clarified. Please clarify the ACES policy.

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS. 

Please see table 2-6.3 Grove Creek
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-177

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

Please see Appendix E for the resource evaluation on this ACEC. Also please 

refer to FLPMA Sections 103, 201, and 202 for the direction which it provides 

regarding the high priority BLM is to give in the designation and management of 

ACECs

In response to your comment, the text in Alternative D for the Grove Creek 

ACEC of the Proposed RMP and Final EIS has been revised to state: Wildfire 

management (natural ignitions) for resource benefit. Full range of fire 

management activities would be used in ACEC in response to human-ignited 

fires. Use of heavy equipment and retardant would be avoided unless approved 

by authorized officer. 

DRMTDK-BL13-0273-1

Travel mngt

In keeping this land whole and protecting the resource I hope you consider: 

Designating non-motorized trails at the same time motorized trails are 

designated. Keeping the BLM portion of the Big Sky Trail non-motorized. The 

small plants are often subspecies found in a limited number of areas and 

deserve protection. Designating the Bear Canyon route non-motorized. There 

are alternatives for motorized and the Audubon Important Bird Area deserves 

protection.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed” to motorized vehicles and will be designated as a non-motorized 

trail

Refer to map 146

DRMTDK-BL13-0274-1

cultural

The people of the Pawnee Nation thank you for submitting your project proposal 

for our review and comment. Given the information provided, you are hereby 

notified that there should be no Pawnee historic or archeological properties 

within your project site. Your proposed project location should have no potential 

to adversely effect any known archeological or historical Pawnee sites. 

Therefore, in accordance with 36 CFR 800.4(d)(1), you may proceed with your 

proposed project. However, should you encounter any unanticipated Pawnee 

human remains or cultural properties you must report them to us immediately as 

required by NEPA, NRHP and NAGPRA regulations.

N Thank you for your comment. 

DRMTDK-BL13-0276-1WILD 

HORSES, 

PMWHR

Removal of old/unused enclosures in this area should be a priority. As these 

become weather-worn and fall into disrepair, they pose a threat of accidental 

entrapment, in direct opposition to the animal welfare directives these pens were 

originally designed to uphold. Pens in disrepair are a liability issue on many 

levels, and should be attended to by careful inventory and scheduled dismantling 

plans.

N Thank you for your comment

DRMTDK-BL13-0276-2WILD 

HORSES, 

PMWHR

As we are all aware, rapid advances in genetic technology are providing new 

opportunities for inter-species discovery. Ensuring the widest diversity within 

natural populations is essential to optimal genetic research. When herd 

management in this area is necessary, please remain cognizant of the value of 

N Thank you for your comment
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each individual, and leave those exhibiting rare traits to propagate those alleles 

in future generations.

DRMTDK-BL13-0276-3WILD 

HORSES, 

PMWHR

Please include clear, strong language regarding public education and 

enforcement of policies, so the protected range inhabitants are not subject to 

unnatural disturbances in their habitat. Respectful use of these lands by all 

members of the public is a mandate from the founding documents that enabled 

us to establish these vast, irreplaceable resources for the citizens in our future 

generations.

N Thank you for your comment

DRMTDK-BL13-0277-1

Livestock 

Grazing

There are some problems in matching information between one volume and 

another. For instance, the grazing allotments are only listed by numbers and 

numbers of AUM's. Either the name of the allotment and/or a brief legal 

description would aid in determining what was going on. Further the maps of the 

allotments in Volume 4 are virtually indecipherable as to lay out. I think the map 

in Volume 4 shows our entire ranch as being a grazing allotment. I know that it is 

NOT. Federal land is a small minority of our ranch holding. There are other 

issues of federal control such as split estate, but certainly not grazing control. 

There is a list of abbreviations indicating what endangered or threatened species 

may be in an area, but since the listing of grazing allotments is only by number 

or AUM's it is difficult to tell what things are really affecting a given allotment.

n

Thank you for your comment. Map number 122 (Range Allotments) does not 

easily depict the allotments. Due to printing constraints, the size of this map will 

not be changed, however allotment numbers have been included on this map, 

as well as BLM surface. The allotment numbers are small, and are not easily 

read on the hard copy version. The digital versions (CD, or web page) allow 

the reader to zoom in on a particular area. Additionally, with the addition of the 

allotment number, the reader can then reference appendix S, which includes 

the threatened, endangered, or special status species known to exist within an 

allotment. 

Grazing allotment boundaries listed on map 122 were derived from current map 

layers. Grazing allotments are typically composed of public, private, and 

occasionally state lands used conjunction for grazing purposes. The BLM is 

continuously updating allotment boundaries to reflect changes that may have 

occurred, typically as the result of fencing on private lands. These revisions 

typically occur during the consultation process during the grazing permit 

renewal. 

DRMTDK-BL13-0277-2

Locatable 

Minerals

The cover letter states that BLM manages 1,839,782 acres of federal mineral 

and 434,154 acres of public surface, which would leave approximately 1,400,000 

acres of federal mineral under private surface under the management of the 

Billings BLM Field Office. I got notice of this plan revision because I have a 

couple of small grazing allotments. I did not get notice because the federal 

government experience that federal control of public mineral can have just as 

much or more impact on private surface as dealing with federal grazing 

allotments.

n

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS.

DRMTDK-BL13-0277-3

Coal

Where there are coal reservations, a lease can be similarly devastating. BLM 

assumes that the only surface effects of underground mining are where the 

processing area and tipple are located. From personal experience, I can attest 

there are many surface effects that are unforeseen

N

We appreciate your comment regarding the surface effects of underground 

mining.

DRMTDK-BL13-0277-4

NEPA

I find it interesting that the latest information on Signal Peak air quality is only 

2008 (p. 4-13) from 5 years ago or maybe 2009 (4-11). It took Signal Peak until 

2010 to really get revved up with the full longwall production. The 3rd full panel 

opened in the fall of 2012.

N Thank you for your comment
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DRMTDK-BL13-0277-5

wildlife

There have been many surface adventures with an underground mine that 

supposedly would have no surface effects, an opinion stated often over the last 

20 years since BLM traded away some of its best coal for deserts in Carbon 

County and fishing access on the Madison. December 1, 2011 Signal Peak ran a 

road in through a roadless area on our ranch, including on BLM surface, to claw 

portions of the face of Dunn Mountain down to stuff in cracks that opened two 

hundred feet down into the mine allowing Carbon Monoxide to form, and 

necessitating a massive nitrogen injection project complete with large trucks, lots 

of diesel storage, generators, lights and mancamps. The elk left their habitual fall 

hangout there and have been cautious about returning. Signal Peak has finally 

gotten a road permit across BLM surface and partially constructed the road. This 

right-of-way was not listed in the rights of way section. Signal Peak also plans to 

build a road across the face of Dunn Mountain, which will likely be visible as far 

as the scar for their emergency access of December 1, 2011. That scar is visible 

clear across the Yellowstone Valley. There are also holes for injecting gob sealer 

and nitrogen on top of Dunn Mountain, and the latest is another hole for gob 

injection where they had already injected, because the gob sealer had started 

leaking CO again. After December 1, 2011 nitrogen was injected into the mine 

for two months straight. Diesel motors ran fans on the south side of Dunn 

Mountain for over a year after that.

n

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and documented in the administrative record associated with the 

Billings RMP/EIS

DRMTDK-BL13-0277-6

Wildlife I didn't see that the agency had any plan to reconcile sage grouse recovery with 

mineral removal. n

Thank you for your comment. 

The BLM’s FLPMA (Section 103(c)) defines "multiple use" as the management 

of the public lands and their various resource values so that they are utilized in 

the combination that will best meet the present and future needs of the 

American people. Accordingly, the BLM is responsible for the complicated task 

of striking a balance among the many competing uses to which public lands can 

be put. The BLM’s multiple-use mandate does not require that all uses be 

allowed on all areas of the public lands. The purpose of the mandate is to 

require the BLM to evaluate and choose an appropriate balance of resource 

uses which involves tradeoffs between competing uses. The FLPMA also 

directs the United States (US) Department of the Interior, Bureau of Land 

Management (BLM) to develop and periodically revise or amend its Resource 

Management Plans (RMPs), which guide management of BLM-administered 

lands, and provides an arena for making decisions regarding how public lands 

would be managed and used. 

While FWS has responsibility for threatened and endangered species, the BLM 

and the Forest Service manage a significant portion of sage-grouse habitat. 

Thus, although it is the FWS’s responsibility to administer the Endangered 

Species Act, management of wildlife habitat is within the BLM and the Forest 

Service’s multiple-use mandate and is properly a resource to be managed in 

their planning decisions.
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DRMTDK-BL13-0277-7

NEPA Could you give a complete listing of all the substances that BLM might give a 

materials lease for extraction under a l916 Stockraising Homestead Patent? N Thank your for your comment. Non-substantive

DRMTDK-BL13-0277-8

NEPA

In Appendix M, BLM attempts to describe the coal estate which it owns. In many 

cases the exploratory work for its coal estate was done over 100 years ago, and 

the information obtained was not terribly complete. Some seams of coal have 

been fairly completely delineated before being put up for lease or trade

Y

Thank you for your comment. 

Appendix M and Chapter 3-Coal are being updated. 

DRMTDK-BL13-0283-1

Air

Chapter 3, Figure 3-2 provides ambient air quality concentrations in the Planning 

Area for years 2009¬2011. Although data are included for the 1-hour and 24-

hour SO2, National Ambient Air Quality Standards (NAAQS). footnotes 13 and 

14 seem to indicate that 3-hour and annual data are also available. We 

recommend including the 3-hour and annual data in this Figure. In addition. the 

1-hour SO2, concentration presented in Figure 3-2 is at 105% of the NAAQS. On 

p. 3-9, it is noted that the Montana Department of Environmental Quality 

(MDEQ) reported high monitored 1-hour SO2, concentrations during 2010 due to 

"events that are not likely to be repeated in future years." We recommend 

expanding this discussion to explain these "events- and why they would not he 

repeated

Y

The footnotes have been revised and data have been updated to reflect years 

2010-2012. The BLM refers readers to the MDEQ for additional information 

concerning SO2 events associated with industrial sources permitted by the 

MDEQ. Modeling results for the 3-hour SO2 NAAQS have been included in 

Section 4.1.1.3.1.

DRMTDK-BL13-0283-

10

Air

Appendix Y. Emissions Inventories, provides slightly different emissions 

inventory totals as compared to those presented in the ARTSD. In particular, the 

PM10 and PM2.5 emissions associated with Oil and Gas development appear 

more substantive. We recommend reconciling the two documents or explaining 

the differences

Y

Emission inventories were updated and the revised emission estimates are 

included in Sections 4.1.2.3–4.1.2.6, Appendix Y, and in the ARTSD.

DRMTDK-BL13-0283-

11

Air

It is important that the emissions controls and mitigation measures used to 

develop the emissions inventory be included as required mitigation measures for 

activities under the RMP. The alternative-specific emissions inventory includes 

an 84% control efficiency of gravel or scoria surfacing for calculating dust 

emissions. The ARTSD, p. 6, identifies assumptions used in this emissions 

inventory, including a 50% fugitive dust control efficiency but no mention of this 

84% control with gravel or scoria. If 84% surfacing control was used in the nearfield modeling, then we recommend that this control efficiency be added to the 

identified assumptions on p. 6 of the ARTSD and that gravel/scoria surfacing be 

added to the initial mitigation list of the ARMP., Section 6.1

N

The AERMOD emission inventory was based on a 50 percent fugitive dust 

control efficiency, which is a conservative estimate, while the alternativespecific emission inventories included 84% reflecting gravel or scoria surfacing 

which is standard practice in the planning area. The suggested change 

regarding receptor layout was incorporated into Section 4.1.1.3.1. Annual 

comparisons to the NAAQS and MAAQS were provided in this section for those 

pollutants with annual averaging times

DRMTDK-BL13-0283-

12

Air

recommendations for clarification of the ARTSD, as follows: pp. 14-15 -” Figure 

1 illustrates the well pad and receptor layout for PM10 and PM2.5 modeling. 

Please clarify whether this same receptor layout was used for the other criteria 

pollutants. p. 19 - Predicted criteria air pollutant concentrations were compared 

to the NAAQS, MAAQS. and Prevention of Significant Deterioration increments. 

For disclosure purposes, we recommend the annual comparisons for the 

NAAQS and MAAQS be discussed in this paragraph

N 

The AERMOD emission inventory was based on a 50 percent fugitive dust 

control efficiency, which is a conservative estimate, while the alternativespecific emission inventories included 84% reflecting gravel or scoria surfacing 

which is standard practice in the planning area. The suggested change 

regarding receptor layout was incorporated into Section 4.1.1.3.1. Annual 

comparisons to the NAAQS and MAAQS were provided in this section for those 

pollutants with annual averaging times

DR- Water Given the potential and existing groundwater use in the region, it is important to y previous comment responses regarding SWPAs and the new stipulation to 
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MTDK-BL13-0283-

13

characterize the groundwater resources within the Planning Area. We 

recommend expanding the discussion in the Final RMP/EIS to include the 

following information: A description of all aquifers in the study area, noting which 

aquifers are Underground Sources of Drinking Water (USDWs). Federal Safe 

Drinking Water Act regulations define a USDW as an aquifer or portion thereof: 

(a)(1) which supplies any public water system; or (2) which contains a sufficient 

quantity of ground water to supply a public water system; and (I) currently 

supplies drinking water for human consumption; or (ii) contains fewer than 

10,000 mg/1 total dissolved solids; and (h) which is not an exempted aquifer 

(See 40 CFR Section 144.3); Maps depicting the location of sensitive 

groundwater resources such as: municipal watersheds, source water protection 

zones (available from the Montana Department of Environmental Quality-MDEQ, 

Joe Meek, see contact information below), sensitive aquifers, and recharge 

areas; and description of and locations of groundwater use (e.g., public water 

supply wells, domestic wells, springs, and agricultural and stock wells)

protect them address this comment. Generally, MT DEQ provides standards 

and guidance in managing activities that could impact drinking water resources, 

which the BLM complies with through various agreements/MOUs. A SWPA 

stipulation has been developed. It stipulated NSO within SWPAs, with the 

objective to: “To protect human health by minimizing the potential 

contamination of public water systems. Source water is untreated water from 

streams, rivers, lakes, or aquifers used to supply public water systems. 

Ensuring that source water is protected from contamination can reduce the 

costs of treatment and risks to public health. This stipulation would protect the 

State-designated Source Water Protection Areas that protect public water 

systems from potential contamination.”

DRMTDK-BL13-0283-

14

Water 

The Draft RMP/EIS states that no current, comprehensive quantification or 

quality measurements have been made for groundwater in the Planning Area. 

Page 3-39 notes that "the following guidance" sets forth foundations for BLM 

management of aquatic resources, but no discussion of such guidance follows: 

We recommend the Final RMP/EIS include disclosure of any future plans for 

gathering groundwater data in the Planning Area and discussion of the 

referenced guidance

n

The BLM does not plan to gather comprehensive planning area ground water 

data. If a Plan Of Development is submitted that would warrant data collection, 

it would occur. 

The “guidance” is referring to a number of plans and recommendations from 

BMPs to state and federal water quality standards. To clarify, the paragraph 

referred to will be written as:

“Best management practices, state and federal guidance concentrate on 

protecting water resources, which sets the foundation for BLM management of 

both surface and groundwater resources.”

DRMTDK-BL13-0283-

15

Water 

The EPA recommends that the Final RMP/EIS analyze potential impacts to 

groundwater quality and quantity related to oil and gas well drilling, including 

leaks and spills; associated production and disposal of produced water, including 

potential use of pits, underground injection control (UIC) wells, and evaporation 

ponds; impacts associated with production wellbore integrity and pipeline use; 

and impacts associated with restimulation and abandonment of existing wells. 

The EPA also recommends that the Final RMP/EIS discuss measures the BLM 

will require at the project level to minimize the potential for these impacts to 

occur. Appropriate groundwater protection measures can vary depending on 

hydrologic conditions and the presence of drinking water resources. Depending 

on the level of oil and gas development, lease stipulations may be necessary 

due to the disproportionate effect on water resources from such development

y

The commenter states, “Appropriate groundwater protection measures can vary 

depending on hydrologic conditions and the presence of drinking water 

resources. Depending on the level of oil and gas development, lease 

stipulations may be necessary due to the disproportionate effect on water 

resources from such development.” Relevant to this, the BLM cannot address 

every potential specific issue that may arise throughout the field office in a 

programmatic document such as this RMP. The impacts mentioned will be, if 

scoping identifies them, analyzed at the project level during NEPA analysis. A 

series of stipulations are available to managers to minimize impacts to water 

resources. 

Additionally, since this draft was produced, a new stipulation has been 

developed to conserve water quality in Source Water Protection Areas (SWPA). 

An NSO for all SWPAs is stipulated. SWPAs were identified by MT DEQ data.
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Concerning municipal water supplies, MT DEQ regulates activities with 

potential to affect municipal water supplies. The BLM works under an MOU to 

follow MT DEQ guidelines in these circumstances. 

DRMTDK-BL13-0283-

16

Water

BLM analyze and disclose potential groundwater protection, monitoring and 

mitigation measures, including: BMPs and other mitigation measures such as 

closed loop drilling, monitoring of water quality and water levels, closure and 

monitoring of reserve pits, and lining and monitoring of evaporation ponds; 

Setback stipulations, such as No Surface Occupancy (NSO), to minimize the 

potential for impacts to potential drinking water resources, including domestic 

water wells and public water supply wells. EPA recommends a minimum 500-

foot setback for private wells. Setbacks are effective health and environment 

protection tools because they provide an opportunity for released contaminants 

to attenuate before reaching a water supply well. They may also afford an 

opportunity for a release to be remediated before it can impact a well, or for an 

alternate water supply to be secured, We note that the North Dakota Oil and Gas 

Commission has adopted a 500-foot setback from occupied dwellings (and by 

default, the associated domestic well); A mitigation plan for remediating future 

unanticipated impacts to drinking water wells, such as requiring the operator to 

remedy those impacts through treatment, replacement, or other appropriate 

means; and A general production well schematic that depicts the following: 

casing strings; cement outside and between the various casing strings; and the 

relationship of the well casing design to potentially important hydro-geological 

features such as confining zones and aquifers or aquifer systems that meet the 

definition of a USDW. Discuss how the generalized design will achieve effective 

isolation of USDWs from production activities and prevent migration of fluids of 

poorer quality into zones with better water quality

y

The commenter states, “Appropriate groundwater protection measures can vary 

depending on hydrologic conditions and the presence of drinking water 

resources. Depending on the level of oil and gas development, lease 

stipulations may be necessary due to the disproportionate effect on water

resources from such development.” Relevant to this, the BLM cannot address 

every potential specific issue that may arise throughout the field office in a 

programmatic document such as this RMP. The impacts mentioned will be, if 

scoping identifies them, analyzed at the project level during NEPA analysis. A 

series of stipulations are available to managers to minimize impacts to water 

resources. 

Additionally, since this draft was produced, a new stipulation has been 

developed to conserve water quality in Source Water Protection Areas (SWPA). 

An NSO for all SWPAs is stipulated. SWPAs were identified by MT DEQ data.

Concerning municipal water supplies, MT DEQ regulates activities with 

potential to affect municipal water supplies. The BLM works under an MOU to

follow MT DEQ guidelines in these circumstances. 

DRMTDK-BL13-0283-

17

Water 

The EPA recommends the Final RMWEIS describe the current water quality 

conditions, if available, for each surface water body in the Planning Area, 

including perennial, intermittent and ephemeral streams, rivers, lakes, reservoirs, 

and surface water drinking water sources. The EPA also recommends the Final 

RMP/ EIS disclose the following information: A map and list of Clean Water Act 

(CWA) impaired or threatened water body segments within, or downstream of, 

the Planning Area, including the designated uses of the water bodies and the 

specific pollutants of concern; a map of municipal watersheds and designated 

source water protection zones; and Maps and descriptions of topography and 

soils, specifically steep slopes and fragile or erodible soils, especially near 

surface waters and intermittent/ephemeral channels

n

Oil and Gas leasing EAs (NEPA) will identify SWPAs with regard to proposed 

parcels, making developers and resource managers aware of potential issues. 

The EA will analyze the impacts of leasing parcels to SWPAs. The commenter 

states, “Appropriate groundwater protection measures can vary depending on 

hydrologic conditions and the presence of drinking water resources. Depending 

on the level of oil and gas development, lease stipulations may be necessary 

due to the disproportionate effect on water resources from such development.” 

Relevant to this, the BLM cannot address every potential specific issue that 

may arise throughout the field office in a programmatic document such as this 

RMP. The impacts mentioned will be, if scoping identifies them, analyzed at the 

project level during NEPA analysis. A series of stipulations are available to 

managers to minimize impacts to water resources. 

DRMTDK-BL13-0283-

Water 

We recommend that the Final RMP/EIS be updated to reference Montana's 

2012 Clean Water Act (CWA) Section 303(d) Impaired Waters List, as approved 

by the EPA, and discuss water quality trends to more fully describe current 

n

The BLM uses its own data, as well as MT DEQ data, to evaluate water quality 

of given water bodies when needed. Riparian evaluations and MT DEQ 303d 

lists are used in conjunction to determine management needs for various water 
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19 conditions in, and downstream of, the Planning Area. We recommend this 

discussion include a description of any Total Maximum Daily Loads completed 

by MDEQ for streams in the Planning Area. in addition, if MDEQ has not 

assessed the water quality in all water bodies within the Planning Area, then we 

recommend that the Final RMP/EIS list such water bodies and indicate that the 

water quality condition has not yet been assessed by MDEQ

resources.

A list of impaired water bodies is present in Chapter 3 of the draft document. 

The MT DEQ 303d list, easily accessible on their website, has maps and 

descriptions depicting available information regarding water quality and 

impaired water resources throughout the Billings Field Office, and the state of 

MT. 

Source water protection areas (including municipal watersheds) have been 

identified. A new stipulation places an NSO within an SWPA to protect drinking 

water resources in the planning area.

A steep slope and erodible soil layer has been developed for the field office with 

a new “sensitive soil” stipulation that places a CSU on areas with sensitive 

soils. The CSU requires an approved plan to avoid or mitigate impacts to 

resources from development on sensitive soils.

Impacts from soil disturbance, especially near surface waters, is covered by 

three stipulations, including the new sensitive soils CSU, the 300’ CSU for 

riparian and water setbacks, and the water/ riparian NSO. 

TMDLs and subsequent monitoring are controlled by MT DEQ, with BLM 

contributing data as available. When NEPA analysis of proposed projects 

identify issues pertaining to water quality, the BLM determines assessment and 

monitoring needs to maintain or improve water quality. 

DRMTDK-BL13-0283-2

Air

BLM conducted near-field modeling to disclose potential impacts to the NAAQS 

in the Planning Area. However, it appears that the 3-hr SO, NAAQS analysis 

was omitted from the near-field modeling runs for the Draft RMP/EIS although it 

was included in the modeling protocol agreed to through the AQTW. Given the 

presence of the Laurel SO, Nonattainment Area within the Planning Area. it is 

particularly important that BLM disclose potential impacts to the 3-hr SO, 

NAAQS

y Modeling results for the 3-hr SO2 standard were added to Section 4.1.1.3.1.

DRMTDK-BL13-0283-

20

Water 

The Draft RMP/EIS notes that increased sediment from surface disturbance may 

degrade water quality. Because sediment loading has already caused 

impairment of water bodies in the Planning Area, and future activities that may 

be authorized under this RMP, including oil and gas development, livestock 

grazing and use of off-highway vehicles (which is expected to double by 2015), 

would result in surface disturbance that may contribute to erosion impacting 

watersheds, it is important the Final RMP/EIS include additional information 

about this concern. It is difficult to determine from the Draft RMP/EIS, Chapter 3, 

Affected Environment, whether the Planning Area contains sensitive soils, but it 

y

A Sensitive Soils layer has been developed and a new sensitive soils 

stipulation, a CSU, has been drafted. The description of the sensitive soils will 

be inserted into the soils section in Ch. 3. 

In BiFO, a large proportion of sensitive soils are in arid regions with distant 

proximity to any surface waters, minimizing the impact these disturbances 

would have on water resources. 

Threats to water quality from sedimentation, due to various activities, is 
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does note that some soils in the Planning Area have high susceptibility to 

erosion. Because erodible soils could represent a source of pollutants in the 

Planning Area, we recommend the Final RMP/EIS include a map depicting areas 

of steep slopes and fragile or erodible soils and proximity to surface waters

addressed on the project level through NEPA analysis. For oil and gas 

development, stipulations help minimize these impacts. For livestock grazing, 

Land Health Standards and Guidelines are used to promote water quality 

through protecting riparian health.

Comprehensive travel management is being conducted and analyzes and 

addresses impacts from OHV travel to water quality.

DRMTDK-BL13-0283-

21

Water 

Oil and Gas Leasing Stipulations to Protect Water Resources: The Draft 

RMP/EIS includes two different descriptions of the water resource protections 

provided by the Preferred Alternative through oil and gas leasing stipulations. 

Specifically, the Draft RMP/EIS Chapter 2, p. 2-49, and Chapter 4, p. 4-101, 

describe the Preferred Alternative to include a NSO stipulation within 300 feet of 

riparian areas, wetlands, 100 year floodplains, water bodies and perennial 

streams. However, Appendix C, Oil and Gas Stipulations, indicates that the 

Preferred Alternative proposes the following stipulations: NSO - "Surface 

occupancy and use is prohibited within perennial or intermittent streams (as 

indicated by obligate wetland species or hydric soils); lakes, ponds, and 

reservoirs; floodplains; wetlands; and riparian areas." in addition, a Controlled 

Surface Use (CSU) stipulation is proposed to ensure that special operating 

procedures are required within 300 feet of riparian and/or wetland areas. We 

recommend that the inconsistency be resolved in the Final RMP/EIS and also 

suggest several modifications to enhance and clarify the water resource 

protections. If the Appendix C proposed stipulations are the intended version: 

We recommend against using "obligate wetland species or hydric soils" as 

indicators for intermittent streams, since this will result in an unnecessarily 

narrow definition of intermittent stream that would likely result in excluding many 

of these streams from protection. We recommend further clarification of the 

"streams" language by including ephemeral streams in the list of water 

resources to be protected by the NSO stipulation. This is important because the 

Draft RMP/EIS identifies 1,002 miles of perennial, intermittent, and ephemeral 

streams in the Planning Area. We recommend clarifying the NSO language to 

be applicable to "100-year floodplains" in order to provide certainty for operators

n

The consistency for water and riparian stipulations have been addressed and 

are represented accurately in the text of the document and in Appendix C, 

where stips are described. There will be a water/riparian/floodplain NSO and a 

300’ CSU. 

When parcels are nominated for leasing, resource specialists conduct GIS 

investigations and if necessary site visits to determine what resources may be 

impacted if the lease is developed. During these investigations, the drainages in 

the area will be classified as perennial, intermittent or ephemeral, depending on 

many characteristics. If a riparian obligate species is present in a dry channel, it 

will be classified as intermittent. Soil surveys indicating hydric soils will also 

result in intermittent classification. Office personnel, with local expertise often 

times have knowledge of flow regimes in drainages as well, which can 

supplement on the ground investigations and data queries. 

Ephemeral drainages are runoff channels, only flowing in direct response to 

precipitation events and/or snowmelt. Except in gentle terrain, ephemeral 

drainages are simply too numerous and rarely active to afford the same 

protections as intermittent and perennial streams. During the permitting 

process, ephemeral drainages that are recognized as a potential problem for 

water quality issues will be identified and conditions will be put on the permit to 

minimize issues that may arise due to the proximity of development to the 

ephemeral channel.

100 year floodplains will be used in place of “flood plains”. 

The WEMs for the water and riparian resources stipulation were developed with 

regard to “protecting the unique biological and hydrological features and 

functions associated with perennial and intermittent streams, lakes, ponds, 

reservoirs, floodplains, wetlands, and riparian areas.”

Resource managers have discussed the appropriateness of NSO vs CSU for 

these riparian/water setbacks. Within the MT/Dakota BLM, it was decided that 

the 300 foot CSU would meet resource objectives. The MT DEQ 303d list of 
Billings and Pompeys Pillar National Monument

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impaired waters shows only two streams that are impaired with oil and gas 

development as the causal factor. There is very little reference material 

supporting specific setback distances as most effective at mitigating impacts

from oil and gas development. With the minimal impact documented in the 

state, and the CSU stipulation requiring a development plan that ensures 

resource objectives will be met, a CSU is deemed acceptable in protecting 

water resources.

DRMTDK-BL13-0283-

22

Water 

We recommend removing the exceptions clause from the NSO stipulation given 

the importance of preventing disturbance within water bodies and wetland areas. 

In reviewing numerous oil and gas leasing stipulations contained in other BLM 

EISs, we have not seen an exception process to allow drilling within water 

bodies or wetlands. It is our understanding that a "no exceptions approach" 

within a water body or wetland is BLM's standard procedure

n

The consistency for water and riparian stipulations have been addressed and 

are represented accurately in the text of the document and in Appendix C, 

where stips are described. There will be a water/riparian/floodplain NSO and a 

300’ CSU. 

When parcels are nominated for leasing, resource specialists conduct GIS 

investigations and if necessary site visits to determine what resources may be 

impacted if the lease is developed. During these investigations, the drainages in 

the area will be classified as perennial, intermittent or ephemeral, depending on 

many characteristics. If a riparian obligate species is present in a dry channel, it 

will be classified as intermittent. Soil surveys indicating hydric soils will also 

result in intermittent classification. Office personnel, with local expertise often 

times have knowledge of flow regimes in drainages as well, which can 

supplement on the ground investigations and data queries. 

Ephemeral drainages are runoff channels, only flowing in direct response to 

precipitation events and/or snowmelt. Except in gentle terrain, ephemeral 

drainages are simply too numerous and rarely active to afford the same 

protections as intermittent and perennial streams. During the permitting 

process, ephemeral drainages that are recognized as a potential problem for 

water quality issues will be identified and conditions will be put on the permit to 

minimize issues that may arise due to the proximity of development to the 

ephemeral channel.

100 year floodplains will be used in place of “flood plains”. 

The WEMs for the water and riparian resources stipulation were developed with 

regard to “protecting the unique biological and hydrological features and 

functions associated with perennial and intermittent streams, lakes, ponds, 

reservoirs, floodplains, wetlands, and riparian areas.”

Resource managers have discussed the appropriateness of NSO vs CSU for 

these riparian/water setbacks. Within the MT/Dakota BLM, it was decided that 

the 300 foot CSU would meet resource objectives. The MT DEQ 303d list of 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-186 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

impaired waters shows only two streams that are impaired with oil and gas 

development as the causal factor. There is very little reference material 

supporting specific setback distances as most effective at mitigating impacts 

from oil and gas development. With the minimal impact documented in the 

state, and the CSU stipulation requiring a development plan that ensures 

resource objectives will be met, a CSU is deemed acceptable in protecting 

water resources. 

DRMTDK-BL13-0283-

23

Riparian/ 

wetlands

the EPA recommends BLM consider revising the Appendix C Preferred 

Alternative CSU setback for riparian and wetland areas to a 500 foot NSO 

setback for perennial, intermittent and ephemeral streams, lakes, ponds, 

reservoirs, riparian and wetland areas. Other BLM Field Offices have required a 

500 foot setback to minimize potential deterioration of water quality and to 

maintain natural hydrologic function of stream channels, stream banks, 

floodplains, and riparian communities (e.g., see Grand Junction Field Office 

Draft RMP/EIS, NSO-1, Major River Corridors; NSO-2, Streams/Springs). We 

also recommend adding "springs" to the list of water resources protected by 

these stipulations in order to maintain proper function of these susceptible 

resources (e.g., see Grand Junction Field Office, NSO-4, Lentic Riparian Areas -

” which includes springs, seeps and fens).

y

Thank you for your comment. We have considered your suggestion and altered 

our preferred alternative to include both an NSO and a CSU.

DRMTDK-BL13-0283-

24

Livestock 

Grazing, 

vegrangelands

We understand from conversations with the BLM Miles City Field Office that 

BLM's process is to prepare environmental assessments to assess the effects of 

alternatives developed to ensure that Rangeland Health Standards are met 

through grazing allotment goals and objectives. If livestock grazing levels or 

practices are a significant factor in failing to meet Rangeland Health Standards, 

the BLM has committed to take action no later than the start of the next grazing 

year to initiate progress toward meeting the Standards. Since such action must 

be taken quickly, we recommend that the Final RMP/EIS include a list of 

potential measures that could be implemented at the project level to meet 

Rangeland Health Standards. This list could include measures that the BiF0 has 

taken in the past, as well as the .following suggestions: Require special 

protections for high quality wetland resources such as springs and fens. Such 

protections might include development of alternative water sources, fencing to 

exclude livestock from a spring source, and redirection of spring water to a 

trough for watering; To avoid possible infiltration of groundwater with 

contaminants resulting from congregation of livestock, require adequate 

separation between a livestock water well and a water trough or tank; Specify 

steps to protect and/or repair any existing exclusions and upland water 

developments, and develop new range improvements to protect water 

resources; Monitor impacts from grazing adjacent to high value water 

resources; Adjust the timing of grazing by delaying Spring turnout, increasing 

rotation, and focusing grazing on areas less intensely used in the previous year; 

n

Grazing does have the potential to impact water resources, and BLM is 

committed (required by regulation) to take action before the start of the next 

grazing season if it is determined that an allotment is failing to achieve one or 

more of the standards, and livestock grazing has been determined to be a 

causal factor. Guidelines (Volume III, Appendix I) have been developed to 

address many of the common causal problems associated with land health 

standards and livestock grazing. These guidelines are typically selected, 

analyzed, and if appropriate implemented following site specific NEPA analysis 

at the appropriate level (pasture, allotment, area, or watershed). These 

guidelines may be used independently and/or in conjunction with others. The 

existing guidelines incorporate many of the potential remedy measures you 

suggest as well as others. Because site specific conditions may vary widely 

among allotments, there is no comprehensive list approach that will address 

problems in all situations. In addition “Other Terms and Conditions” are 

commonly applied to grazing authorizations to facilitate site specific 

management and unique circumstances.

The use of adaptive management is commonly implemented on a site specific 

basis and has been addressed in this document. 

Monitoring and evaluation is typically scheduled based on the management 

category of an allotment. The current management category of specific 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-187

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

and Develop a monitoring plan and schedule to assess effectiveness of range 

improvements in protecting aquatic resources

allotments can be found in Volume III, Appendix S. Proposed changes to 

management category by alternative can be found in Volume I, Table 2-6.2, Pg. 

2-118. As directed by existing policy, should an allotment be determined to not 

be meeting the water quality standard and livestock grazing is determined to be 

a causal factor, the allotment would be re-categorized to an “I” management 

category which would prioritize that allotment for monitoring and evaluation.

DRMTDK-BL13-0283-

25

NEPA

In addition, we recommend the Final RMP/EIS identify the general features of an 

effective adaptive management plan that could be employed at the project level, 

including the following: Decision tree with achievable and measurable objectives 

to provide accountability and guide future decisions; Specific decision 

thresholds with identified indicators for each impacted resource; Targets that 

specify a desired future condition; Commitment to implement and fund a 

monitoring plan with protocols to assess whether thresholds are being met; 

Commitment to use monitoring results to modify management strategies as 

necessary; and Designated timeframes for completion of necessary 

management modifications

Y

Thank your for your comment. Beyond the scope of this document 

(implementation level planning)

DRMTDK-BL13-0283-

26

NEPA

We recommend clarifying Appendix 0 and the Final RMP/EIS, Section 1.4.1. I., 

Travel Management Planning, to confirm that site-specific NEPA analyses will be 

conducted for individual Travel Management Plans

N

Thank you for your comment. As per BLM Handbook H-8342-1 and Travel and 

Transportation Manual 1626, Section 1626, site specific analyses will be 

conducted for travel management plans. Text has been changed in 1.4.3.1.2 

to address your concerns.

DRMTDK-BL13-0283-

27

Water 

In order to ensure that public drinking water supply sources (e.g., surface water 

sources, including groundwater under the direct influence of surface water 

(GWUDISW) sources, and groundwater sources) are protected from potential 

impacts associated with BLM-authorized activities in the Planning Area, it is 

important to identify where these sources are located. Therefore, the EPA 

recommends that the Final RMP/EIS include a map delineating source water 

protection areas for public water supply wells. Please contact Joe Meek, MDEQ, 

via the contact information below for a map of the Public Water Supply Inventory 

Regions in the BiFO. We also recommend identifying reservoirs that are drinking 

water sources and disclosing potential impacts to these sources

y

Additionally, since this draft was produced, a new stipulation has been 

developed to conserve water quality in Source Water Protection Areas (SWPA). 

An NSO for all SWPAs is stipulated. SWPAs were identified by MT DEQ data.

DRMTDK-BL13-0283-

28

Water 

In order to ensure public drinking water supply sources (e.g., surface water 

sources, including GWUDISW sources, and groundwater sources) are protected 

from potential impacts associated with oil and gas leasing, the EPA recommends 

the following NSO language: Municipal Supply Watersheds- NSO within any of 

the following areas, as deemed appropriate by the BLM: The entire watershed; 

or Local Source Water Protection Planning Areas where delineated in a Source 

Water Protection Plan; or Surface Water Spill Response Region or Groundwater 

Inventory Region defined by Source Water Assessments that have been 

delineated or evaluated by the State Surface Water Spill Response Regions are 

'A-mile-wide zones (on both sides of rivers or streams, upstream of drinking 

water intakes. They include the water body with the surface water intake and 

y

A SWPA stipulation has been developed. It stipulated NSO within SWPAs, with 

the objective to: “To protect human health by minimizing the potential 

contamination of public water systems. Source water is untreated water from 

streams, rivers, lakes, or aquifers used to supply public water systems. 

Ensuring that source water is protected from contamination can reduce the 

costs of treatment and risks to public health. This stipulation would protect the 

State-designated Source Water Protection Areas that protect public water 

systems from potential contamination.”

Oil and Gas leasing EAs (NEPA) will identify SWPAs with regard to proposed 

parcels, making developers and resource managers aware of potential issues. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-188 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

significant tributaries, for 10 miles upstream of the drinking water intake. For 

lakes and reservoirs, they include a 'A-mile-wide zone around the water body 

Groundwater Inventory Regions are based on a three-year time of travel or a 

fixed radius of 1,000 feet (concentric buffer) around the public water supply well

The EA will analyze the impacts of leasing parcels to SWPAs

DRMTDK-BL13-0283-

29

Water 

For surface water sources, if the Municipal Supply Watersheds NSO stipulation 

is not deemed feasible by the BLM, then at a minimum we recommend a 1000-

foot NSO or CSU setback on both sides of the river or stream, for 10 miles 

upstream of the intake. For lakes and reservoirs, this would include a 1000-foot 

NSO or CSU setback around the water body. For groundwater and GWUDISW 

sources, if the Municipal Supply Watersheds NSO stipulation is not deemed 

feasible by the BLM, we recommend a minimum 1,000-foot CSU concentric 

buffer for these sources. We make this recommendation based on consultation. 

with Joe Meek, the Source Water Protection Program Manager with the MDEQ. 

He may be contacted for additional information at 406Â¬444-4806 or 

jmeek@mt.gov.

y

A SWPA stipulation has been developed. It stipulated NSO within SWPAs, with 

the objective to: “To protect human health by minimizing the potential 

contamination of public water systems. Source water is untreated water from 

streams, rivers, lakes, or aquifers used to supply public water systems. 

Ensuring that source water is protected from contamination can reduce the 

costs of treatment and risks to public health. This stipulation would protect the 

State-designated Source Water Protection Areas that protect public water 

systems from potential contamination.”

Oil and Gas leasing EAs (NEPA) will identify SWPAs with regard to proposed 

parcels, making developers and resource managers aware of potential issues. 

The EA will analyze the impacts of leasing parcels to SWPAs

DRMTDK-BL13-0283-3

Air

The Air Resources Technical Support Document (ARTSD), p. 6, states that Tier 

4 emission standards were assumed in the Draft RMP/EIS near-field modeling 

analysis in order to demonstrate compliance with the 1-hr NO2 NAAQS. We note 

that the ARMP, Section 6.1, initial mitigation requirement for diesel drill rig 

engines >200 hp to meet Tier 4 emission standards for non-road diesel engines 

indicates that "oil and gas operators may use drill rig engines that exceed Tier 4 

emission standards if modeling demonstrates compliance with the NAAQS and 

protection of AQRVs." We assume that this caveat means that additional nearfield modeling will be required at the project-level if higher-emitting engines will 

be used. We recommend the Final RMP/EIS and ROD include this commitment

Y

See the discussion in Appendix T, Section 6.1. Text has been modified to state 

that modeling or monitoring may be used to demonstrate compliance if non-Tier 

4 engines are used. Demonstrations may be made at the project level or at a 

programmatic level.

DRMTDK-BL13-0283-

30

Water 

The EPA also recommends the BLM include a commitment in the Final EIS and 

ROD to provide notice to lessees regarding these important areas in the 

Planning Area. Lease notices for drilling within Source Water Protection (SWP) 

Zones of public water supplies are now being used for all wells drilled under 

BLM authority within SWP Zones in Utah

y SWPA Stipulation established.

DRMTDK-BL13-0283-

31

Water 

The Draft RMP/EIS indicates that although only 3.5% of the Planning Area is 

comprised of riparian and wetland areas, the importance of the riparian zone to 

water quality and quantity is recognized. With this in mind, we recommend 

clarifying p. 3-55 to describe "the following guidance" that is referenced for 

setting the foundation for BLM management of riparian habitat, function and 

water quality

n

The BLM does not plan to gather comprehensive planning area ground water 

data. If a Plan Of Development is submitted that would warrant data collection, 

it would occur. 

The “guidance” is referring to a number of plans and recommendations from 

BMPs to state and federal water quality standards. To clarify, the paragraph 

referred to will be written as:

“Best management practices, state and federal guidance concentrate on 

protecting water resources, which sets the foundation for BLM management of 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-189

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

both surface and groundwater resources.”

DRMTDK-BL13-0283-

32

Water 

Springs often contain rare or unique plant and animal species in addition to 

being important contributors to hydrologic function. Therefore, the EPA 

recommends that the RMP include a commitment for further analysis of springs 

at the project level, including evaluation of function or condition prior to 

authorizing any activities in these areas. To ensure that springs, as well as 

perennial seeps and wetlands, are identified to facilitate their protection, we 

recommend delineation and marking of perennial seeps, springs and wetlands 

on maps and on the ground before development.

n

Concerning municipal water supplies, MT DEQ regulates activities with 

potential to affect municipal water supplies. The BLM works under an MOU to 

follow MT DEQ guidelines in these circumstances. Springs are included in 

riparian assessments and are afforded the protections any riparian area is. Will 

check text to ensure this is clear. Will update if needed.

DRMTDK-BL13-0283-

33

Water 

We recommend expanding the Final RMP/E1S Chapter 4 discussion of potential 

mitigation measures that may be applicable at the project level for oil and gas 

construction, drilling and production activities to prevent adverse impacts to 

these aquatic resources. These could include silt fences, detention ponds and 

other stormwater control measures. Other potential mitigation measures, 

including oil and gas leasing stipulations and measures to protect water 

resources front grazing impacts, are discussed above under Surface Water 

Mitigation

n

Thank you for the comment. The RMP includes appendices that describe Best 

management practices, which are used to mitigate impacts from activities on 

federal lands, including oil and gas development and livestock grazing. 

These BMPs and related practices to conserve natural resources are constantly 

being developed and added to the tool box. 

DRMTDK-BL13-0283-

34

Water 

Water demand associated with the drilling and completion of new wells in the 

Planning Area is an important consideration that will benefit from analysis and 

disclosure. Although the oil and gas reasonably foreseeable development (RFD) 

for the Planning Area is relatively low, the Draft RMP/EIS Â notes that (a) 

depletion of surface water in the Planning Area watersheds may affect major 

rivers, including the Yellowstone, and (b) produced water from oil and gas 

development may affect groundwater. We recommend that the Final RMP/ EIS 

include a general discussion of the following: Based on predicted well depths, 

formation characteristics, and well designs (and fracturing operations, if used), 

estimate a range of water demand per well developed in the Planning Area; 

Possible sources of water needed for oil and gas development; and Potential 

impacts of the water withdrawals (e.g., drawdown of aquifer water levels, 

reductions in stream flow, impacts on aquatic life, wetlands, and other aquatic 

resources).In addition, the EPA recommends the Final RMPOEIS include a 

general discussion of how flow back and produced water will be managed 

including: Estimated volume of produced water per well; Options and potential 

locations for managing the produced water (i.e., UIC wells, evaporation ponds, 

and surface discharges); Possible target injection formations, formation 

characteristics and depth of any UIC wells; and Potential impacts of produced 

water management

n

The level of development seen and forecasted in the BiFO precludes a need for 

detailed analysis of these issues. As development occurs, NEPA analysis of 

proposed projects would identify issues that may affect the environment and 

determine the impacts thereof. Attempting to analyze these impacts 

preemptively is not feasible due to the wide range of conditions coupled with 

the low forecast for development. The scenarios are too varied concerning 

geology and development location.

In the event a large development is proposed, a thorough and detailed analysis 

would be conducted of issues that are identified through internal and external 

scoping. These issues are not within the scope of this RMP level document.

DRMTDK-BL13-0283-

35

NEPA

A general framework for implementation and monitoring of the RMP is provided 

in Appendix X. Implementation and Monitoring. We recommend expanding this 

appendix, similar to the Miles City Draft RMP example, to include detailed 

monitoring measures and identification of frequency, remedial action triggers 

Y

Thank your for your comment. Beyond the scope of this document 

(implementation level planning)
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-190 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

and management options

DRMTDK-BL13-0283-

36

Water 

the EPA recommends that BiFO require all BLM authorized oil and gas multi-well 

projects to conduct groundwater and surface water monitoring, similar to RMP 

requirements included by other BLM Field Offices, e.g., White River and Grand 

Junction in Colorado. To that end, we recommend that the Final RIM'/EIS 

describe the components of water resource monitoring that will be expected of 

new projects in the Planning Area, including how water quality monitoring will 

occur prior to, during, and after such development to detect impacts to both 

surface water and groundwater resources, including private wells. The EPA 

encourages BLM to include monitoring frequency expectations to ensure water 

quality changes are detected in a timely fashion to address any increased 

pollutant levels in streams and to verify expected improvements from changes in 

management practices. Streams could be prioritized for monitoring frequency 

where some streams (e.g., 303(d) listed impaired water bodies) would receive 

yearly or seasonal monitoring and other streams would be monitored much less 

frequently. Evaluations of water quality could also fallow this time schedule as 

appropriate. A recent example of a water quality monitoring plan is the "LongTerm Plan for Monitoring of Water Resources" developed by BLM for the Gasco 

Energy Inc. Uinta Basin Natural Gas Development Project Final EIS2. Also. the 

National Ground Water Association's Water Wells in Proximity to Natural Gas or 

Oil Development Brief' provides information on the importance of baseline 

sampling for private wells and types of analysis recommended.

n

The level of development seen and forecasted in the BiFO precludes a need for 

detailed analysis of these issues. As development occurs, NEPA analysis of 

proposed projects would identify issues that may affect the environment and 

determine the impacts thereof. Attempting to analyze these impacts 

preemptively is not feasible due to the wide range of conditions coupled with 

the low forecast for development. The scenarios are too varied concerning 

geology and development location.

In the event a large development is proposed, a thorough and detailed analysis 

would be conducted of issues that are identified through internal and external 

scoping. These issues are not within the scope of this RMP level document.

DRMTDK-BL13-0283-

37

WSR

Draft RMP/EIS, Chapter 4, Environmental Consequences, notes that the 

Preferred Alternative would recommend two of the eligible segments as suitable, 

and the other eligible segments would be determined non-suitable (and no 

longer afforded management protection for wild and scenic purposes). We 

recommend that the Final RMP/EIS disclose how the suitability analysis was 

conducted and how the suitability determinations were made. In addition, we 

recommend revising Map #165, Eligible Wild and Scenic Rivers, to include 

identification of segments with proposed suitability determinations

n

Thank you for your review of the draft RMP and your comments. The BIFO did 

do a Suitability Study as part of this planning effort. It appears that the 

document was inadvertently left out of the document. It has been inserted into 

Appendix R, after the Eligibility Study Report.

DRMTDK-BL13-0283-

38

WSR

We also recommend that the Final RMP/EIS ensure consistency between 

Chapter 4 and Appendix C, Oil and Gas Stipulations. Currently for the Preferred 

Alternative, page 4-442 identifies NSO within 0.5 mile of WSR-eligible and 

suitable segments, but Appendix C identifies NSO within 0.5 mile of WSReligible segments. We recommend using the same terminology in both sections 

to avoid any confusion

n

Thank you for the review of this document and your thoughtful comments

The text will be changed to ensure consistency between the mentioned 

sections of the document

DRMTDK-BL13-0283-

39

Social/econ

The Draft RMP/EIS discloses that American Indians represent nearly 9% of the 

population in the Montana portion of the Planning Area with a high percentage 

living in poverty. Depending on the county, percentages of persons living below 

the poverty level in the Montana portion of the Planning Area range to 24%. The 

Environmental Consequences chapter of the Draft RMP/EIS states that no 

n

Thank you for your comment. Environmental Justice is considered/analyzed 

during the project-level NEPA analysis.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-191

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

alternative will result in identifiable disproportionate effects specific to any 

minority or low income population or community. To confirm this determination, 

we recommend additional environmental justice analysis at the project-level 

stage of NEPA given the demographics of the area and the potential impacts 

from oil and gas development

DRMTDK-BL13-0283-4

Air 

To disclose BLM's intent, we recommend that the Final RMP/EIS include the 

following: Clarification regarding which mitigation measures were necessary to 

ensure compliance with the NAAQS; and An explanation as to why BLM 

believes requiring drill and completion engines >750 hp to meet Tier 4 generator 

set emission standards is not necessary to demonstrate compliance with the 1-

hour NO2 NAAQS.

N

In response to an earlier EPA request under the MOU that larger drill rig and 

completion engines be modeled, the BLM modeled the largest engines 

expected to be operating in the planning area. Based on research and 

discussions with BLM fluid minerals staff, the BLM determined that these 

largest engines are generator set engines. Smaller non-generator set engines 

may be used for some wells. At the planning stage, the BLM cannot model 

every size/type engine combination that could conceivably be used. The BLM's 

approach is reasonable, but conservative, and predicts compliance with the 

NAAQS. Both generator set and non-generator set engines are subject to 

EPA’s non-road diesel engine regulations. The BLM is requiring drill rig and 

completion engines to meet the most stringent EPA emission standards for both 

generator set and non-generator set engines, with the exception that future 

modeling or monitoring may demonstrate that the use of non-Tier 4 engines 

may be used if adequate air quality protection is demonstrated.

DRMTDK-BL13-0283-

40

Air

Pursuant to draft Council on Environmental Quality (CEQ) guidance and 

Executive Order 13514, BLM has included an analysis and disclosure of 

greenhouse gas (GHG) emissions and climate change. We note that the GHG 

emissions inventory does not include oil and gas emissions from "downstream" 

activities such as refining that will occur outside the Planning Area. Because 

information on these "downstream" indirect GHG emissions from activities may 

be of interest to the public in obtaining a complete picture of the 

GHGÂ emissions associated with BLM-authorized activity in the Planning Area, 

it may be helpful to estimate and disclose them

N

The BLM does not have sufficient information to estimate GHG emissions from 

downstream activities. 

DRMTDK-BL13-0283-5

Air

the ARMP Section 6.2. Monitoring-Based Mitigation, indicates that prior to 

completion of the photochemical grid modeling (PGM) analysis, monitoringbased thresholds for determining enhanced mitigation would be based on 

evaluation of monitored exceedances of the NAAQS. However, in the discussion 

of modeling-based thresholds for evaluating enhanced mitigation (Section 6.3), it 

is stated that "potential future impacts" on NAAQS or Montana Ambient Air 

Quality Standards (MAAQS) will be considered. To provide clarity regarding the 

trigger and consistency within the ARMP, we recommend replacing this 

language with "NAAQS or MAAQS exceedances" predicted via future PGM

Y See Appendix T. Section 6.3.1

DRMTDK-BL13-0283-6

Air

Section 1.5 of the ARMP includes a detailed discussion of requirements for oil 

and gas activities that were developed through the 2008 Montana Statewide Oil 

& Gas EIS (Statewide), some of which are being integrated into the BiFO ARMP. 

We note that two of the Statewide requirements that are not "carried forward" 

N

Natural-gas-fired or electrical compressors or generators are included as initial 

mitigation in Appendix T, Section 6.1. Due to the low level of development in 

the planning area and a decrease in compression throughout the area, the 

requirement to maximize the number of wells connected to each compressor 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-192 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

into this ARMP are requirements to (1) maximize the number of wells connected 

to each compressor and (2) utilize natural gas fired or electrical compressors or 

generators. We recommend that BLM provide its rationale for discontinuing 

these emission-reducing requirements

has become a moot point. 

DRMTDK-BL13-0283-7

Air

ARMP pp.T-11-12: We understand that BLM intends to run the PGM to cover the 

full 20 year planning cycle of the RMP rather than performing an initial PGM run 

followed by periodic reassessments as described in Section 5.1.2Â on p. T-12. 

We recommend revising the text to clarify this point. In addition, we recommend 

revising Table 2, p. t-11 to include time in the schedule for the AQTW to review 

results from emissions modeling

Y

Suggested clarifications have been addressed in relevant portions of Appendix 

T.

DRMTDK-BL13-0283-8

Air

Section 6.2.3 indicates that following PGM completion, BLM would calculate 

design values for each pollutant monitored at a federal reference monitor within 

the Planning Area. For completeness, we suggest revising this language to 

include federal equivalent method monitors since data from these monitors could 

be used in an identical fashion to the data collected from federal reference 

monitors

Y

Suggested clarifications have been addressed in relevant portions of Appendix 

T.

DRMTDK-BL13-0283-9

Air

Section 6.2.4: After the PGM is completed, we recommend a 1-year timeline for 

implementation of measures after selection of enhanced mitigation, similar to the 

timeline provided for implementation of enhanced mitigation measures prior to 

PGM completion (see Section 6.2.2: "Selected mitigation measures would be 

implemented within one year after the BLM decision to apply additional 

mitigation").

Y

Suggested clarifications have been addressed in relevant portions of Appendix 

T.

DRMTDK-BL13-0284-1

Travel mngt

ON roads or ATV routes that provide the primary or exclusive access to a 

section or more of BLM lands but are unavailable to public travel due to private 

landownership, we expect your agency to CLOSE THE ROUTE AT THE POINT 

IT ENTERS BLM LAND beyond the private land to travel except for certain 

administrative use. In the event of grazing or other special uses (other than 

outfitting) limited travel by the permit or lease holder can occur. Permitted travel 

must be confined to that deemed necessary to properly administer the operation 

covered by the permit or lease. No road or ATV route should be open to 

outfitters or to landowners who do not allow the public to use of that route to 

access BLM land. On roads that pass thru both public and private land that are 

critical for your agency to carry out its mandate (such as access for fire 

suppression and enforcement of laws such as the Antiquities Act) should be 

opened to your agency and the public as a result of the BLM filing a Prescriptive 

Easement in the name of the public. Don't claim you can't file Prescriptive 

Easements because we (PLWA) do it all the time. The Goetz Law firm says your 

agency can file a prescriptive easement the same as anyone else

n

Thank you for your comments.

Regarding access to isolated parcels of public lands, the BLM designates Areas 

in its RMPs. Specific routes are addressed in the Travel Plan, which has a 

separate decision record than the RMP. Guidance for route decisions can be 

found in the BLM Manual 1626, Travel and Transportation. BLM can also 

consider access concerns during site specific NEPA actions and under a variety 

of programs, including the range, realty, and recreation Manuals. 

DRMTDK-BL13-0287-1

Travel mngt

First, I believe that all the current roads and trails that are closed to OHVs, 

remain closed to OHV traffic. If one looks at a road that has been closed for a 

few years, one can see nature beginning to return the road to a natural state.

n

Thank you for your comments.

In regards to your comment, 

While statements of opinion (including agreement or opposition) do not require 
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specific responses or text revisions under NEPA regulations, they have been 

considered by the Billings Field Office and Montana State Office and 

documented in the administrative record associated with the Billings and 

Pompeys Pillar National Monument RMP/EIS

DRMTDK-BL13-0295-1

NEPA

The Billings and Pompeys Pillar RMP (BPPRMP), which includes travel 

management planning, is voluminous. The four RMP volumes are 5.5 inches 

thick and do not include the 2,549 on-line pages of Background & Supporting 

Material for Travel Plan, nor all necessary travel mapping. 40CFR part 1500.4 

states "Agencies shall reduce excessive paperwork by: Reducing the length of 

environmental impact statements (1502.2), by means such as appropriate page 

limits (1501.7(b)(1) and 1502.7). The BPPRMP must fall into the excessive 

paperwork category. I've had trouble going through the material, the BLM staff 

had troubles finding things in the RMP when asked questions, and the average 

person has very little chance of making sense of the material. The time spent 

reviewing the material has been beyond ridiculous. We do not feel the spirit or 

intent of 40 CFR 1500.4 has been followed.

N Thank you for your comment.

DRMTDK-BL13-0295-2

Travel mngt

Page 3-197 has a table entitled Estimated Number of Vehicles Used OffHighway in Montana (1990-1998), which was used to project regional 

recreational use to 2015. The data is not only out of date but also makes some 

flawed conclusions.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

DRMTDK-BL13-0295-3

Travel mngt

-Route PM1023 is listed as an Open to 50" or Less route. This is a route used by

all sized vehicles as not only a loop, but a cut across from Helt Road to Crooked 

Creek Road. If this is not changed, some visitors would have to go 

approximately twelve miles out of the way. -There is a switchback north of 

PM1023 which has been used for many years by many recreationists to go from 

Red Pryors Road to Crooked Creek Road. Reading your latest route numbered 

maps, it looks like it goes from PM1017 to PM1025. Alternative D shows the 

route as being closed. This is an important loop and access route which should 

be kept open.

n

Thank you for your comments. The BLM staff has reviewed your and others 

and several decisions have been altered, including the one for PM 1023. This 

route will be designated as “open” for all size vehicles, not just those less than 

50” in width. 

DRMTDK-BL13-0295-4

Travel mngt

-Routes PM1071 and PM1072 should be considered for opening to OHV travel. 

This is a connector loop which ties into Bear Canyon Road PM1067. Neither 

route indicates habitat or cultural issues. -Routes CW2024 and CW2025 should 

be open to motorized users. This would allow access to state land from the west 

and south for hunting purposes. Creating a positive future for off-highway vehicle 

recreation

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the mentioned routes, (PM 1071 and 1072) the route inventory 

evaluated their use and determined that there are resource concerns and 

alternate routes more suited for OHV use. In regards to routes CW 2024 and 

CW 2025, the staff reviewed these decisions and determined that while both 

routes offer the same access CW 2024 offers the most advantageous access. 

The route will be designated as “open” for motorized use. Refer to map 146
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DRMTDK-BL13-0299-1

Social/econ

In review of the BLM RMP/EIS being proposed it is clear your agency is not 

adequately considering the social and economic impact of the decision in any of 

the alternatives presented in the DRMP/EIS. It is common practice to use the 

IMPLAN (page 4-594) modeling system for analysis of social and economic 

impacts but this modeling analysis is highly dependent on the accuracy of the 

data input in order to generate any form of reliable output. It is clear your agency 

has used input data which is based on "assumptions, estimates, predictions, 

potentials, could be, may be, expected, approximately, and about" as all of these 

words are used throughout the report. The DRMP/EIS is full of these words and 

lacks sufficient supportable facts to make a justified decision to close vast 

acreages of federally managed BLM land in Montana. It appears the writer with 

or without management direction had a pre-conceived agenda to limit public 

access, mineral development and recreation use in this area. The writer states 

the conclusion then sets out to prove the assumption using a process of 

manipulating data or making existing scientific data support the pre-conceived 

conclusion. A report based upon "my opinion", "assumptions", "estimates", 

"predictions", "potential", "could be", "may be expected", "approximately" and 

"about" not supported by peer reviewed scientific studies has no credibility. It 

reads as though BLM is making a stock market offering by using forward looking 

statements. Where is the hard data? Typically agencies gather data from reliable 

sources such as interviews and information from local residents which the BLM 

has failed to do. I request your agency follow their own requirements and gather 

more reliable peer reviewed scientific studies to support the conclusion before 

completing the final RMP/EIS. Failure to gather true data on the social and 

economic impacts of this decision and to incorporate this information into the 

document would result in the decision being arbitrary and capricious.

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS. 

The IMPLAN data are comprehensive - it includes data from both metropolitan 

and non-metropolitan areas. It is neither feasible nor desirable to conduct 

economic impact analyses on very small scales (e.g., zip code level) due to the 

economic linkages between communities. A small-scale IMPLAN analysis 

would fail to capture the labor and trade flows between communities and the 

economic consequences would be underestimated. As a result, consequences 

particular to small communities are addressed in the social analysis. The social 

analysis addresses environmental justice considerations on pg. 4-590, which 

describe the potential for disproportionately adverse effects on low income 

individuals and communities.

DRMTDK-BL13-0300-1

Social/econ

Because of your lack of accurate and peer reviewed input data into the IMPLAN 

modeling system. On page 4-589, under Impacts common, the DRMP/EIS 

makes the following statement: "No alternative would affect the major social 

trends or social organizations in the local communities of the planning area." 

And on page 4-590 under Environmental Justice, "no alternative considered 

would result in any identifiable disproportionate effects specific to any minority or 

low income population or community." How are you able to make these 

statements when the majority of local citizens were not consulted and the few 

that did comment on this plan have explained the large negative impact of 

closing large areas of BLM managed land to recreation, agriculture and resource 

development? This statement is false and should be changed to reflect the true 

negative impact to local communities. Very small towns in the planning area are 

highly dependent upon agriculture, recreation and mineral development, yet their 

importance is discounted by the above statements.

n

Opinion: Response: No text revision necessary (Thanks for the comment. 

Resource outputs are the amount of a resource (e.g., AUMs, recreation visits, 

tons of locatable minerals, etc.) that would be available for use under each 

alternative. Resource specialists projected annual resource outputs based on 

the best available information and professional judgment. Based upon public 

comments, resource specialists have reviewed assumptions used in this 

analysis to see if they need to be changed or updated. These revised 

assumptions have been incorporated into the analysis contained in the DEIS. 

The purpose of the economic analysis is to compare the relative impacts of the 

alternatives and should not be viewed as absolute economic values. Previous 

modeling experience has shown that the data contained in the IMPLAN 

modeling system for the various sectors are accurate representations of 

impacts. )

DR- Coal In addition page 2-20, table 2-1 specifically states "coal acres closed in each n Thank you for your comment. A map showing the areas for open and closed 
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MTDK-BL13-0300-2plan", with alternate A = 26,131; B = 290,048; C = 264,450; and D = 280,971 

and on page 2-27-A it states "No coal leasing on 26,131 acres". For the 26,131 

acres there is no map reference so the reading public can identify what is 

actually being proposed. Why are these acres not clearly identified? Please 

identify these acreages with maps of such scale as to be readable.

will be included

DRMTDK-BL13-0300-3

Social 

/econ

The major problem with your use of the IMPLAN system is it uses data and 

information from major urban areas and no information from small communities 

are gathered or included. Please take a hard look at these statements and 

consider the fact that you are imposing environmental injustice to these very 

small communities by closing thousands of acres to recreation and development. 

An example is failure to address the very real possibility of an active coal mine 

which has a certified 43-101 "Standards of Disclosure for Mineral Projects" in 

process incorporating over 12,000 acres of private land in the Bear and Grove 

Creek drainages. These acres and adjacent acres (including BLM) contain over 

1.2 billion tons of "high volatile bituminous" mineable coal in six or more beds. 

This tonnage is documented by numerous scientific geological studies by 

Woodruff(1907), Rawlins(1974), Skelly & Loy(2004), Roberts & Rossi (1996) and 

Grubber (2006 & 2010). Whether we like it or not coal is the primary energy 

choice for the nation in decades to come until an affordable alternative becomes 

available.

n

Thank you for your comment. The IMPLAN data are comprehensive - it 

includes data from both metropolitan and non-metropolitan areas. It is neither 

feasible nor desirable to conduct economic impact analyses on very small 

scales (e.g., zip code level) due to the economic linkages between 

communities. A small-scale IMPLAN analysis would fail to capture the labor and 

trade flows between communities and the economic consequences would be 

underestimated. As a result, consequences particular to small communities are 

addressed in the social analysis. The social analysis addresses environmental 

justice considerations on pg. 4-590, which describe the potential for 

disproportionately adverse effects on low income individuals and communities.

DRMTDK-BL13-0302-1

Social/econ

The DRMP/EIS refers to a study done by Rasker, Alexander, Van den Noort, 

and Carter 2004 which attempts to display the benefits and need for open space. 

The study is not definitive and was done in response to increased subdivision 

activity in high density areas of western Montana. Carbon County is several 

hundred miles removed from western Montana and has never been a high 

density population area therefore applying this study is flawed.

n

Opinion: Response: No text revision necessary (Thanks for the comment. 

Resource outputs are the amount of a resource (e.g., AUMs, recreation visits, 

tons of locatable minerals, etc.) that would be available for use under each 

alternative. Resource specialists projected annual resource outputs based on 

the best available information and professional judgment. Based upon public 

comments, resource specialists have reviewed assumptions used in this 

analysis to see if they need to be changed or updated. These revised 

assumptions have been incorporated into the analysis contained in the DEIS. 

The purpose of the economic analysis is to compare the relative impacts of the 

alternatives and should not be viewed as absolute economic values. Previous 

modeling experience has shown that the data contained in the IMPLAN 

modeling system for the various sectors are accurate representations of 

impacts. )

DRMTDK-BL13-0303-1

NEPA

Many members of the public including myself have in the past hunted, and 

recreated in this area. The DRMP/EIS is not sufficient in conveying to the pubic 

a clear picture of what roads and trails are proposed to be closed or remain 

open. The maps associated with the DRMP/EIS in many cases are of such scale 

as to be worthless to a user in that they do not indicate road and trail numbers 

which are necessary for the public to provide substantive comments on specific 

roads and trails. An example Gold Creek is mentioned several times relating to 

ACEC's yet I cannot locate it on even one map. When BLM representatives were 

N

Thank your for your comment. Gold Creek can be found on any topographic 

map. It begins in T. 9 S., R. 20 E., section 9 (USFS CNF), runs through 

sections 10, 11, 2, & 1 of T. 9 S. R. 20 E., section 6 of T. 9 S., R. 21 E., and 

sections 31, 32, and 33 of T. 8 S., R. 21 E.

With regards to road identification, only BLM managed roads were identified on 

the maps at the open house events. 
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asked about the lack of road and trail identification at the open house events we 

were told these maps were "a work in progress" and that maps of adequate 

scale included in the report "would cost too much as over $200,000 had already 

been spent on printing", quote from Jim Sparks, Area Manager at a public 

meeting! Why was the document released for public review when it was not 

finished?

DRMTDK-BL13-0303-2

NEPA

A record of decision to implement the DRMP/EIS before the access information 

is provided and failure to address private property rights is contrary to the 

requirements of NEPA and would be a violation of NEPA.

N Thank your for your comment.

DRMTDK-BL13-0304-1Travel 

mngt, 

recreation

In the planning area of the DRMP/EIS I would submit that all of the uses 

described require some type of motorized access of roads to achieve enjoyment 

of these activities. You have not clearly identified the way people have 

historically accessed these lands for the activities listed. I request you address 

this discrepancy in your analysis to reflect how people really access these areas.

n

BLM’s approach to Travel and Transportation management is set by BLM 

Manual 1626 and Technical Reference 9113-1, which has as their objectives 

the establishment of a sustainable multi-modal (including motorized, nonmotorized, mechanical, and even animal powered modes of travel) 

transportation system of roads, primitive roads, and trails that address public 

and administrative access, support the agency’s mission and provide resource 

protection, as well as to manage these resources and uses in accordance with 

law, Executive Order, proclamation and policy. 

The decisions in the RMP reflect these considerations, not a biased approach. 

Information regarding both the historical and actual uses of specific routes can 

be found in the Route Inventory Files, and throughout the RMP. 

Please also note that the RMP states that the goal for the Grove Creek TMA is 

to minimize impacts to geologic, visual attributes, sensitive plants, cultural, and 

wildlife values while providing access for the public, permittees, non-federal 

landowners, and administrative needs.

DRMTDK-BL13-0304-2

Wildlife 

Your analysis and conclusions are flawed in proposing that human presence and 

surface occupancy is the primary cause of possible Sage Grouse extinction. 

Clearly history shows that both food source and predator populations cycle 

historically. Low food source results in a die off of predators from starvation and 

the predator die off results in a slow increase of food source animal populations. 

The increase of food source animals results is a slow increase of predator 

population until the predators overwhelm the food source and reach 

unsustainable levels and begin to die off, this cycle will continue through all of 

time. The DRMP/EIS fails to evaluate if man or nature is the problem. I request 

the BLM include an analysis and science based information regarding trends in 

food source animal populations in comparison to predator populations

n

Thank you for your comment. Predator control was not included as a threat in 

the FWS’s listing decision; however, the BLM and the Forest Service 

acknowledge that localized predation may be a factor in the conservation of 

greater sage-grouse in some areas. In these areas, the states possess primary 

authority and responsibility for managing the wildlife within the state and the 

BLM and the Forest Service are responsible for managing habitat. 

Montana Fish, Wildlife and Parks manage wildlife within Montana, while the 

BLM and Forest Service focus on managing habitat. Consistent with a 

Memorandum of Understanding between the BLM and the US Department of 

Agriculture, Animal and Plant Health Inspection Service-Wildlife Services, the 

BLM and Forest Service will continue to work with Montana Fish, Wildlife and 

Parks to meet state wildlife population objectives. Predator control is allowed on 

BLM- and Forest Service-administered lands and is regulated by the MT FWP 

and Animal Plant and Health Inspection Service (APHIS). APHIS conducts 

environmental analyses in accordance with the National Environmental Policy 
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Act (NEPA). The BLM and Forest Service will continue to work with agencies to 

address current predation of greater sage-grouse, and BLM and Forest 

Service-administered lands in the planning area will remain open to predator 

control under state laws. Additionally, the BLM and the Forest Service will 

continue to work with the involved states to meet state wildlife population 

objectives. 

While adding management actions specifically to manage predators is outside 

the scope of the amendment, the BLM and the Forest Service have authority to 

manage the habitat and have provided numerous management actions across 

the range of alternatives. Altering the sagebrush habitat of the greater sagegrouse can create an influx of predators into an area and lead to a population

decline. Roads, fences, power lines, trails and other disturbances may make 

access easier for potential predators and increase risks to the species. The 

Draft EIS calls for measures that will substantially reduce disturbances in the 

bird’s habitat, thus reducing predation risk. The Draft EIS also calls for careful 

monitoring of grazing allotments within sage-grouse nesting habitat to ensure 

suitable grass and forb cover is reserved so we can minimize the associated 

predation risks. 

Predation is cited as a threat to sage grouse on pages AB-2, and AB-22 in the 

Appendices.

DRMTDK-BL13-0305-1

Wildlife

On page 4-398 the DRNP/EIS states:" Because the long-term decline in wildlife 

habitat would continue under this alternative". BLM has offered scant evidence

based on scientific research to support their proposed action. However, the no 

action alternative A, must be attacked by BLM and painted as not acceptable in 

order for the BLM to justify changing management direction. Please take a hard 

look at this statement and provide me with the information and science used in 

your determination that this statement is true.

n

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS

DRMTDK-BL13-0306-1

Social/econ

Agriculture is the number one industry in Montana. Sage Grouse population 

numbers have flourished because of the benefit of agriculture to their habitat. 

Man's contribution to these improvements include grains and seeds from 

farm/ranch activities resulting in stubble fields from grain and hay production, 

water facilities and haystacks for feeding and cover. These benefits must be 

recognized and the Sage Grouse strategy must include a cost benefit analysis of 

the restrictions or potential removal of thousands of acres from the agricultural 

landscape.

n Opinion: Response: No text revision necessary (Thanks for the comment. 

DRMTDK-BL13-0306-2

Social/econ

Any acres closed to recreation and energy development must consider 

economic benefits (jobs) lost from energy production to communities, counties 

and the state as required by both MEPA and NEPA. Social and economic 

analysis is critical. A strong local social and economic environment is critical in 

preserving wildlife habitat and wildlife populations.

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS. 

DR- Wildlife Other examples that should be part of the evaluation include the naturally n Thank you for expressing your concerns. While statements of opinion 
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MTDK-BL13-0306-3occurring mortality rate of sage grouse compared to the mortality rate associated 

with recreation and mineral development. The evaluation and disclosure to the 

public must include the analysis and a comparison of the magnitude of impacts 

to naturally occurring impacts for all resource areas used to assess impacts 

based on site-specific data. Lack of comparison of impacts to naturally occurring 

levels combined with the lack of site-specific data could allow inaccurate 

statements and opinions due to the lack of an adequate sense of magnitude by 

being arbitrary and capricious.

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS.

DRMTDK-BL13-0307-2

NEPA

The legislature passed and the governor signed HB 169. This will become law 

on October 1, 2013. HB 169 codifies in state law, Title 76, the use of a Growth 

Policy as the legal document a local county may use to coordinate with federal 

agencies on land planning action that affect their county. Many of the Montana 

counties affected by the BLM DRMPs have growth policies in place including 

most of the counties affected by the three BLM RMPs. In the list of participants 

in this proposal there are many cooperating and collaborating agencies but not 

one coordinating agency. Coordination is required by federal agencies if local 

governments wish to engage and have a resource plan in place. HB 169 makes 

the Growth Policy the legal document the county can use to coordinate. The 

BLM must contact all counties affected by these DRMPs and ask if they wish to 

coordinate. Failure to make this effort on the part of the BLM would be in 

violation of several federal laws and acts.

N

Thank your for your comment. Please see Section 1.5.1 of this document. It 

contains a list of the county plans reviewed as part of a consistency review. 

The Billings and Pompeys Pillar National Monument RMP/EIS has 15 

cooperating agencies involved in the B&PPNM RMP/EIS. Invitations were sent 

to 43 federal, tribal, state, and county agencies inviting them to participate as a 

cooperating agency. 

DRMTDK-BL13-0307-3

NEPA, 

wildlife 

The Governor of Montana has set up a task force to study the Sage Grouse 

issue and formulate a plan to enhance their habitat and range. This task force 

seems worthless and a waste of time if the BLM develops and implements 

several RMP plans without first considering the outcome of the task force. 

People on this task force are more familiar with the landscape, the resources, 

the surface and mineral owners, the issues related to habitat and animal 

populations, local economies and economic drivers. BLM has woefully failed to 

address any cause for the decline in Sage Grouse numbers except man.

N Thank you for your comment.

DRMTDK-BL13-0307-4

NEPA

The 63rd Legislature passed SJ15 which is a study bill. This study will analyze 

the current management practices on federally managed public land in Montana 

and the possibility of changes to these management practices. The study will 

look at the relationship between federal land management agencies and the 

state of Montana. I believe it is premature for the BLM to complete the three 

BLM RMPs before the Montana Environment Quality Council (EQC) has a 

chance to complete their work in regards to SJ15. I request the BLM delay their 

decision a minimum of six (6) months or until such time as the EQC provides 

recommendations to the BLM on the proposed plan and subsequent 

implementation of this plan. The first meeting of the EQC is scheduled for June 

19-20, 2013.

N Thank you for your comment.

DR- Lands w/ Bear Creek does exhibit wilderness characteristics by the BLM standards. Given n Thank you for expressing your concerns. While statements of opinion (including 
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MTDK-BL13-0313-1wilderness 

characteristi

cs

that there is an active Bentonite mine in the southwest portion of the unit, we 

propose to modify the boundaries to focus on the central and southeast portions 

of Bear Creek. The proposed lines are marked by a dashed line on the map. The 

line beginning at point 26 follows an established fenceline which would change 

the size to approximately 5,400 acres and the line stemming from the state land 

is a possible minimum suggestion for avoiding any disturbances by the Bentonite 

mine which would change the size of the unit to approximately 6100 acres. 

There are a number of user created ways in the unit, but most appear to be for 

ranching purposes. I spent 4 hours in the unit yesterday, June 27, 2013 and 

encountered no other humans in the unit and the only contact I had on these 

routes were ranchers going out to work on a fence or fill a stock tank, both of 

which are not pervasive or omnipresent nor do they substantially detract from 

the wilderness characteristics. This exhibits the nature of the routes, which show 

no evidence of blading, as well as the opportunity for solitude based on the low 

levels of human contact and primitive recreation. There are in fact low levels of 

vegetative screening in the western portion of the unit with several enjoyable 

lookout points, but the central and southeast portions of the unit provide a rolling 

topography which would allow for visitors to find solitude. Because Petroglyph

Canyon exists within the unit, there is adequate opportunities for primitive 

recreation with supplemental cultural value. Based on this information, it is my 

recommendation that Bear Creek be managed as a Lands with Wilderness 

Characteristics

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

The BLM Field Office staff has reviewed the field work and documentation 

which was done previously for this unit, both by BLM and the documentation 

submitted by your organization in your review and comments. In light of this 

new data and the review, the team has determined that there are further 

impacts (an old vegetation treatment – with plowing and non-native seeding, 

active bentonite mining claims being developed along the southern border) and 

these reduce the wilderness values in some areas in the unit, particularly along 

the southern border and in the western region, but using your proposed pointpoint boundary (which is the further west of the two alternative boundaries) the 

area which does have wilderness qualities is approximately 5,658 acres, which 

exceeds the required minimum size of 5,000 acres for lands with wilderness 

characteristics inventory consideration. This core area is in a substantive 

natural condition (although there are some existing but little-used vehicle 

tracks), has an outstanding level of opportunity for solitude and primitive 

recreation (at least in parts of the unit) and has supplemental features present 

(cultural). This area within the initial inventory unit will be addressed in the RMP 

has an for lands with wilderness characteristics unit. 

DRMTDK-BL13-0320-2

Wildlife 

Two recent studies have used radio-telemetry to assess impacts of energy 

infrastructure on sage-grouse. LeBeau (2012) investigated the impacts of wind 

facilities and an associated transmission line in Wyoming, and Nonne et al. 

(2013) released a final report of a 10-year study of a transmission line in 

Nevada. The Nonne study is currently the only long-term study conducted that 

specifically evaluates potential impacts of a power line on sage-grouse. The 

LeBeau study indicated that habitat quality is a significant influencer of sagegrouse occupancy, regardless of the presence of a transmission line. Sagegrouse selected for nesting habitat closer to transmission lines at Simpson 

Ridge, where the lines have existed for over 10 years and are within quality 

habitat. Also, female survival in the study area was greatest at closer proximity 

to the transmission lines. In February 2013, the final progress report of a 10-year 

research study of sage-grouse near the Falcon- Gondor transmission line in 

central Nevada was released. This report noted correlations between annual 

plant production, related to annual climatic fluctuations, and sage-grouse 

survival, reproductive success, and population growth. Wildfire impacts on 

habitat also influenced the population. The report found "no negative effects on 

demographic rates (i.e., male survival and movement, female survival, 

prefledging chick survival, and nest survival) that could be explained by an 

n

BLM intends to rely on the latest research and best available science by 

utilizing existing research and incorporating other future research through the 

“Adaptive Management” approach described in Section 2.3.4, 
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individual's proximity to the transmission line". APLIC requests that the BLM 

consider these studies, which use current telemetry techniques and specifically 

investigate sage-grouse responses to power lines, when addressing power lines 

in its RMP updates.

DRMTDK-BL13-0320-3

Wildlife

APLIC submits that stipulations for sage-grouse included in the BLM RMP 

revision should not include any mitigation requirement unless it is based on valid 

science, not anecdotal or casual observation, and is specific to sage-grouse (not 

surrogate species such as prairie chickens). APLIC encourages the BLM to 

apply the APLIC/agency sage-grouse BMPs, much like the BLM has for APPs, 

to serve as the current best practices for sage-grouse issues related to electric 

utility facilities.

n

Thank you for your comment. A BMP Appendix is being revised for the Final 

RMP/ EIS. Otherwise, the subject of this comment is beyond the scope of the 

Billings and Pompeys Pillar National Monument RMP/EIS and does not require 

further agency response. 

DRMTDK-BL13-0320-4

Wildlife 

Installing new power lines underground or converting existing lines from 

overhead to underground are often raised as possible permit stipulations or 

mitigation options. However, underground power lines result in significant cost 

increases, reduced reliability, greater ground disturbance during construction 

and repairs, longer outage periods for customers, and may not always be 

feasible from an engineering and operations perspective. Underground power 

lines can result in impacts to other federally listed species, pose a threat of 

negative impacts on cultural resources, and may have a negative impact to 

waterways. Underground power lines require a continuous excavation, including 

blasting in rocky terrain, through all habitat types. In sagebrush habitat, this 

would result in ground disturbance for the entire line route and associated 

access roads. This is in contrast to overhead lines, which result in a disturbance 

only at the structure locations, and the power line's associated access. 

Underground lines would also require excavation for repairs or maintenance, 

which would result in ground disturbance occurring temporally over the life of the 

line, not just during initial construction. Ground disturbance during construction, 

repairs, and maintenance can result in large, permanent displacement of 

excavated soil and subsequent issues with re-establishing native vegetation and 

preventing the overgrowth of invasive species. A University of California study 

(Bumby et al. 2009) found that underground power lines have more 

environmental impacts than overhead power lines for all categories and most 

scenarios in southern California. For more detailed discussion of environmental 

and engineering constraints associated with underground power lines, see 

Reducing Avian Collisions with Power Lines: The State of the Art in 2012 (APLIC 

2012), pages 62-63.

n

Note that in Appendix AA (section F) that burial of power lines is the final 

option. See the statements,” Emphasize the following if perch prevention 

modifications do not work to protect sage-grouse and sage-brush habitat:

1.) reroute the line using distance, topography, or vegetative cover; or

2.) bury the line.” This type of issue raised in your comment will be considered 

by the Billings Field Office during implementation of the Approved RMP when 

project-specific plans are prepared or evaluated through NEPA analysis.

In addition, “Reducing Avian Collisions with Power Lines: The State of the Art in 

2012” will be added as a Reference on page 6-35; Section 2-6.1, page 2-69; 

Section 2-6.2, page 2-112; B.4, page 6; Section B.11, BMPs, page B-25, and 

Appendix AA (section F), Mitigation Measures and Conservation Actions for 

Greater Sage-Grouse Habitat”. Reference to APLIC Guidelines, 2006, will also 

be added to AB-6 and remove the statement,” Avian Power Line Action 

Committee, 1994. 

DRMTDK-BL13-0320-5

Wildlife 

Perch discouragers were originally designed to reduce raptor electrocutions by 

moving birds from an unsafe (electrocution risk) perching location to a safer 

alternative, either on the same structure or a nearby structure on the same line. 

Recent data has documented poor effectiveness in perch discouragers and 

greater effectiveness of covers for preventing electrocutions (see Â Suggested 

n

Thank you for the comment. References to “Fit transmission towers with antiperch devices” (Lammers and Collopy 2007). Page AB-13, “Installation of raptor 

anti-perch devices in greater sage-grouse habitat”, B-34, and several locations 

in Chapter 2, Alternatives, will be revised. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-201

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

Practices for Avian Protection on Power Lines: The State of the Art in 2006 

[APLIC 2006], pages 17-18). Despite their declining use by electric utilities, 

perch discouragers have been required by resource agencies and installed to 

dissuade raptors and corvids from perching or nesting on power poles in areas 

with sage-grouse or other special status species. Perch discourager research 

has shown limited effectiveness in preventing perching. Discouragers actually 

increase the potential for nesting on structures because they provide a firm 

foundation for nest material. Furthermore, use of discouragers to avoid perching 

on a structure increases electrocution risk by forcing raptors to perch in unsafe 

areas. In areas where raven predation on sage-grouse nests is a concern, perch 

discouragers may aid in the accumulation of nest material (APLIC 2006), and 

could potentially increase raven predation pressure due to nest construction on 

discouragers in sensitive areas. The negative impacts of perch discouragers 

must be weighed against the limited benefits, if any, they may provide, 

particularly if they are contributing to mortalities of protected birds and facilitating 

increases in predator nesting opportunities. Hunting techniques and strategies of 

avian predators of sage-grouse should also be considered, because they differ 

for different prey species. For example, golden eagle diet is largely mammalian 

(80-90%, Kochert et al. 2002). Golden eagles prey on sage-grouse 

opportunistically, and typically hunt sage-grouse by stooping from a high soar 

(Watson 1997, Kochert et al. 2002). Consequently, power poles may not play an 

important role in eagle predation of sage-grouse. Golden eagles are vulnerable 

to electrocution mortality (APLIC 2006) and perch discouragers have been 

correlated with increased eagle electrocution risk (PacifiCorp, in prep.). Common 

ravens are known predators of sage-grouse nests, yet ravens are able to 

overcome perch discouragers, will perch on wires, and may experience higher 

nesting rates on poles with perch discouragers.

DRMTDK-BL13-0320-6

Wildlife 

APLIC recommends the BLM adopt the same conservation measures that the 

Montana Greater Sage-grouse Advisory Council is developing in order to 

maintain as much consistency with requirements for electric and gas distribution 

and transmission line as possible. The Montana conservation measures are 

expected to be developed for adequate protection of the species and to avert a 

final listing decision from USFWS. Applying the same conservation measures 

will avoid much confusion and will be much more efficient for industry to manage 

and implement.

n

Thank you for the comment. APLIC guidelines are recommended for 

management on 2-69, 112. Adaptive management is described in Section 

2.3.4.

DRMTDK-BL13-0320-7

Wildlife 

Many electric utility companies have Avian Protection Plans (APPs), which are 

voluntary company-specific documents that guide their activities related to bird 

issues, particularly electrocution and collision impacts. In fact, APLIC hosted a 

course in 2012 in Montana geared at educating utilities about the development 

and implementation of APPs. An APP would typically include avian-safe design 

standards and areas where they would be applied based on bird use and 

n

Thank you for your comment. Your recommendations will be taken under 

advisement. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-202 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

habitat. These standards would include collision-reduction methods, such as line 

marking. Because each utility's APP will differ based on local engineering, 

biological, and environmental variations, APLIC recommends that the BLM 

reference the use of a utility's APP in regards to collision and electrocution 

minimization, rather than including blanket stipulations in the RMP.Â

DRMTDK-BL13-0320-8

Wildlife 

In the alternatives of the Billings Draft RMP, the use of "bird flight diverters" is 

noted "to prevent bird strikes and perching by birds of prey". These statements 

do not correctly reflect the intended use of bird flight diverters. Bird flight 

diverters are not used to prevent perching -“ rather, they are installed on 

conductors to make lines more visible to birds in flight. In addition, "bird flight 

diverters" are a specific product type (one of numerous line markers), and the 

RMP should not specifically identify product types or manufacturers.

n

Thank you for the comment. The reference to “bird flight diverters” will be 

removed and replaced with the language such as “perch, collision, and 

electrocution prevention measures” -

DRMTDK-BL13-0329-1

Travel mngt

I would ask that the Demijohn Flat route not be open to motorized use, This 1 

Â1⁄2 mile route from Crooked Creek Road threatens a culturally sensitive area 

which is designated as both a National Register District, and an Area of Critical 

Environmental Concern (ACEC). Motorized use of this route fractures the Burnt 

Timber Canyon LWC* from the Burnt Timber Canyon WSA** and thus weakens 

both. The route is also a good non-motorized route with a trailhead accessible to 

people without 4WD vehicles.

n

In regards to the Demijohn Flat route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed” for motorized use with the exception of administrative access. 

Refer to map 146

DRMTDK-BL13-0329-2

Travel mngt

I would ask that Bear Canyon be non-motorized. BLM is proposing motorized 

traffic for Graham Trail up the southwest slope of Big Pryor Mountain. That 

makes three redundant parallel motor vehicle routes within less than three miles. 

(The other two are Bear Canyon and Stockman Trail.) One of the three routes 

should be designated for non-motorized use. Of the three routes Bear Canyon, 

through an Audubon Important Bird Area, would be the best non-motorized 

route. (There would still be abundant motorized access to Big Pryor Mountain 

with four more motor routes up the west slope, and two more nearby on the 

south slope.)

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed”

Refer to map 146

DRMTDK-BL13-0333-1

lands with 

wilderness 

characteristi

cs

Please use your power to protect Yellowstone River Islands, Clark's Fork River 

Islands, Weatherman Draw and Bad Canyon like other lands identified as having 

wilderness qualities.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

Please see the end of Table 2.6.1 for Lands with Wilderness Characteristics 

management prescriptions and then refer to other sections in the table for the 

specific areas and their management prescriptions – many have the same 

regardless of designation

DRMTDK-BLTravel mngt 2. I ask that the Big Sky trail and Bear Canyon Creek Trail be designated only for 

nonmotorized use.. Walkers on these increasingly popular trails should not need n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-203

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

13-0338-1 to hike to the end of 4WD/ATV routes to get to quiet trails. (Many people do not 

have 4WDs or prefer to walk.) 3. I ask that the Demijohn Flat route not be open 

to motorized use. 4. I ask that Bear Canyon be designated for only nonmotorized use beyond the mouth of the canyon.

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed”

Refer to map 146

DRMTDK-BL13-0343-1

Travel 

mngt, 

ACEC, fire 

mngt

I am writing in regards to the ACEC area. My Husband and I are PRIVATE land 

owners in the Belfry Area on the Grove Creek RD. We are concerned with the 

recent proposal of the changes of the land use that can affect our property. My 

understanding is that this alternative D would involve shutting off the connection 

from Grove Creek over to Meeteetse Trail to get to the Spires. Since we are 

private land owners we are very concerned with the problems this can cause. 

We feel it should not be designated an ACEC AREA, because there is too much 

private land mixed in and management of the whole ACEC would adversely 

affect us an others as private property owners. We feel you need to take into 

consideration the fire management you are proposing for this area. Letting it 

naturally burn and not allowing mechanized on ground fighting of the fire. With 

the wind that this area gets it would be dangerous to our families and our homes, 

and property.

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS. 

See travel management map 150 for route designations. The BLM can only 

make route designations on BLM managed public lands. Routes across private 

land are not shown on the maps. 

Please see Appendix E for the resource evaluation on this ACEC. Also please 

refer to FLPMA Sections 103, 201, and 202 for the direction which it provides 

regarding the high priority BLM is to give in the designation and management of 

ACECs. Thank you for expressing your concerns. While statements of 

opinion (including agreement or opposition) do not require specific responses or 

text revisions under NEPA regulations, they have been considered by the 

Billings Field Office and Montana State Office and documented in the 

administrative record associated with the Billings and Pompeys Pillar National 

Monument RMP/EIS.

In response to your comment regarding access, please refer to the Travel 

Section, Appendix O and related Maps. Alternative D has provided for 

motorized access through a number of designated routes. There are also a 

number of county-maintained roads in the area, over which BLM has no 

authority. 

In response to your comment, the text in Alternative D for the Grove Creek 

ACEC of the Proposed RMP and Final EIS has been revised to state: Wildfire 

management (natural ignitions) for resource benefit. Full range of fire 

management activities would be used in ACEC in response to human-ignited 

fires. Use of heavy equipment and retardant would be avoided unless approved 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-204 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

by authorized officer. 

DRMTDK-BL13-0344-1

Travel mngt

Specifically, I would like to see both the Bear Canyon Trail as well as the Big Sky 

Trail, be designated for non-motorized use. In addition, I urge you not to open up 

the Demijohn Flat route to motorized use. To do so, would seriously impair the 

beauty, solitude and quiet of this area.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed”

Refer to map 146

DRMTDK-BL13-0348-1

Livestock 

Grazing

As quoted in the Draft RMP: Preferred Alternative: "Action 3 -“ The allotments in 

Table 1 (see the Livestock Grazing Appendix), in which the Standards for 

Rangeland Health were not met (including Sage-grouse Habitat), livestock 

grazing was a causal factor in the failure to meet these standards, and there was 

no progress towards meeting Standards for Rangeland Health in the allotments 

within 5 years of the initial determination would be eliminated and closed to 

livestock grazing." Please show solicitors opinion, regulation, or statute that 

allows you this authority.

n

These actions are not proposed or listed in any livestock grazing alternative 

within the Billings DRMP

DRMTDK-BL13-0348-2

Livestock 

Grazing

The economic impacts on a community will be far reaching into the future 

livelihoods for agriculture if a continuation of decreased allotments were to 

continually take place on BLM lands. You are messing with our historic way of 

life. Your EIS does not even touch on the possible negative economic 

consequences that future BLM management will be responsible for under this 

alternative. I am assuming that you should have addressed this in the 

"environmental consequences" of you Draft Resource Management Plan.

n

The RMP/EIS assesses the economic contributions of BLM’s grazing program 

on the Billings and Pompeys Pillar National Monument planning area and 

Chapter 4 analyzes potential impacts of alternative management actions which 

may affect future livestock grazing. This analysis has been updated in the 

Proposed RMP/Final EIS with better use data to more accurately quantify 

potential impacts to the local economy.

DRMTDK-BL13-0348-3

NEPA

The Montana Constitution says: "Right of participation. The public has the right 

to expect governmental agencies to afford such reasonable opportunity for 

citizen participation in the operation of the agencies prior to the final decision as 

may be provided by law." State constitutions must follow federal law! So, you 

must follow our constitution. Your comment period is way too short by anyones 

standards to be defined as "reasonable opportunity" and should be extended at 

least another 90 days or more.

N

Thank your for your comment.

NEPA requires a 60 day comment period for EISs. The BLM normally extends 

this 60 comment period for an additional 30 days for RMP/EISs. 

DRMTDK-BL13-0351-1

lands with 

wilderness 

characteristi

cs

The BLM failed to properly analyze the alternative identifying all available land 

as includable in the designation of lands with wilderness characteristics. The 

preferred alternative leaves out Weatherman Draw, Bad Canyon and 

Yellowstone River Islands and Clark's Fork River Islands. These landscapes 

should be managed for their wilderness qualities.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

Please see the end of Table 2.6.1 for Lands with Wilderness Characteristics 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-205

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

management prescriptions and then refer to other sections in the table for the 

specific areas and their management prescriptions – many have the same 

regardless of designation

DRMTDK-BL13-0351-3

Travel mngt

Special landscapes should be managed with at least the following management 

proscriptions: Close the areas to oil and gas leasing or allow leasing with no 

surface occupancy Identify areas where utility rights of way are excluded 

Designate areas which are closed to development of wind farms Close wildlands 

from new road construction and off-road vehicle traffic Close wildlands from 

mineral exploration and entry

n

Thank you for your concerns and comments. BLM follows Manual 6301 in 

conducting its wilderness inventories and Manual 6302 when considering lands 

with wilderness characteristics during planning. These Manuals implement 

Secretarial Order 3310 and incorporates principles from BLM guidance 

(Organic Act directives) and legal rules developed as part of BLM’s original 

wilderness inventories.

Please compare the lands with wilderness characteristics Unit maps (maps 42 

to 45) with BLM Manual 6302 and maps for Oil and Gas leasing, ROWs, etc (50 

to 78 and 152 to 156) most areas which have been found to possess 

wilderness characteristics have a measure of restrictions or are not allowed. 

Please see the end of Table 2.6.1 for Lands with Wilderness Characteristics, 

management prescriptions, and then refer to other sections in the table for the 

specific areas/units not found to possess wilderness characteristics and their 

management prescriptions – many have the same regardless of designation

DRMTDK-BL13-0351-4

Travel mngt

Off highway vehicle use should be restricted and ORV use should be limited to 

existing roads where the use is compatible with other landscape amenities. As 

part of its travel management, the draft RMP should: Close the Demijohn Flat 

route to motorized use because of ORV effects on cultural sites and the adjacent 

Burnt Timber Canyon WSA Close to motorized use the two-track leading into 

Bear Canyon past the mouth of the canyon. There is already sufficient access 

into this part of the Pryors. Include an analysis in the RMP of designating routes 

as "non-motorized"

y

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed”

In regards to the Demijohn Flat route due to the conditions you mentioned the 

Alternative D has been modified to reflect the current conditions. The route will 

be designated as “closed” for motorized use with the exception of administrative 

access. 

Refer to map 146

In regards to the designation of non-motorized trails in the RMP, the new BLM 

Manual 1626 Travel and Trail Management prescriptions have been 

incorporated into the document and there is a section on non-motorized trails

DRMTDK-BL13-0351-5

wildlife

Management of the sage grouse priority protection areas should include 

restrictions on oil and gas leasing. Leasing should only be permitted with no 

surface occupancy and no construction of new permanent roads.

n

Thank you for your comment. Please see Appendix C - Oil and Gas Lease 

stips.

DRMTDK-BLNEPA You currently have three "suppositions" (Jerri Tillett, Nikki and Douglass Spotted 

Eagle) in Federal Court (Ninth Circuit Court of Appeals: #13-35139) arguing N Thank you for your comment.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-206 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

13-0352-1 malfeasance on your part.

DRMTDK-BL13-0352-2

WSR CROOKED CREEK: I have been actively requesting the BLM to designate the 

whole of the Creek -WILD (down to my fence line); in order to protect the creek. n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses of text revisions 

under NEPA regulations, they have been considered in the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

Crooked Creek is a high priority for resource conservation on all of BLM 

ownership. Various special designations and the presence of the pure 

Yellowstone Cutthroat trout population ensures the stream and its corridor are 

conserved. 

DRMTDK-BL13-0352-3Cultural, 

WILD 

HORSES

Douglass Spotted Eagle: Full blooded Cheyenne (and speaks fluent Cheyenne), 

(former) bundlekeeper (i.e.: Shaman/ Medicine Man) - which is akin to the Pope 

(in our culture); warrior (decorated for his service in Vietnam), etc. He has 

specifically told you that the PMWHR wild horses are a Cultural Heritage (for 

them as well as "us" - BLM recognized the wild horses as such, as recently as 

the early 1990's). Please review IBLA #: 2012-163 (as well as #13-35139). And 

yet the BLM/ IBLA! 001 has stated (in IBLA'S Judgment): "Appellants advance 

the argument that the horses on the PMWHR are a Native American cultural 

resource and that BLM erred in not considering them as such. ... However,

appellants do not point to any statutory provision that would justify categorizing 

the horses as cultural resources."

N Thank you for your comment.

DRMTDK-BL13-0352-4WILD 

HORSES, 

PMWHR

bring up the AML to the appropriate viable number which is 180+ and allow the 

wild horses genetic viability over the long-term. [As long as horse numbers are 

below 200, grazing impacts to the range (PMWHR) are acceptable." --IBLA 

Judgment 2001. - AND - "That reducing the population below 140-150 over the 

long term, could have negative effects on its genetic viability." --- BLM (BiFO) a 

decade or more ago. - AND - An ADULT horse is 4-5 years of age or older (NOT 

A YEARLING!)]

N

Thank you for your comment however detailed objectives are addressed within 

implementation level documents such as Herd Management Area Plans

DRMTDK-BL13-0352-5WILD 

HORSES, 

PMWHR

BLM is tenacious in adhering to the "safe" negative attract~ field matrix. (Below 

the vibratory rate of 200. Note: Domestic horses (as a whole) are something like 

50 "points higher" than the DOl on the Map of Consciousness Scale. They are 

located in the positive attractor field/ matrix.

N Thank you for your comment

DRMTDK-BL13-0352-6WILD 

HORSES, 

PMWHR

The following resources or resource uses have been determined to have little or 

no impacts to the wild horses or the Pryor Mountain Wild Horse Range from 

BLM authorized uses and management: ..... Climate Change." Climate Change 

affects the whole world. How did the PMWHR manage to escape?

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS. 

DRMTDK-BL13-0352-7WILD 

HORSES, 

PMWHR

The designation as a wild horse range mandates wild horses as the principal 

multiple use but not necessarily the exclusive use." So why doesn't the BLM 

PROTECT the wild horses as a valuable and GENETICALLY VIABLE species!!!

N Thank you for your comment
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-207

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

DRMTDK-BL13-0352-8WILD 

HORSES,

PMWHR

"Impacts to Wild Horses and the Pryor Mountain Wild Horse Range would likely 

result from actions proposed under the following resources or resource uses: .... 

Livestock Grazing." Then you go on to explain that it is ONLY TRAILING ("that 

individually last less than a day but occur numerous times in the spring and fall. 

").

N Thank you for your comment

DRMTDK-BL13-0353-1WILD 

HORSES,

PMWHR

I ask you please carefully take into account the bloodlines, genetics and colors 

of the horses that are caught. Continue to preserve. I fully support a 15 mph 

speed limit mountaintop, prohibiting of people privately feeding the horses.

N Thank you for your comment

DRMTDK-BL13-0353-2Travel 

mngt, 

recreation

Between April 15-June 15, use signs to explain penalties for off road use. 

Volunteers would be happy to move timber and such to block unapproved roads. n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

BLM has an existing sign plan in place and uses different methods of blocking 

roads as part of its routine operations. 

DRMTDK-BL13-0355-1WILD 

HORSES,

PMWHR

Your roundups of wild horses are unnecessary, cost tax payers More money in 

the long run, as opposed to leaving them be. N

Thank you for your comment however this document is not tied to any gather as 

gathers are implementation level documents. 

DRMTDK-BL13-0355-2WILD 

HORSES,

PMWHR

the videos I've seen of these roundups is the most cruel and outright sadistic 

thing I've ever watched. The foals and other horses trample each other in their 

attempt to escape because they are Terrified. And it doesn't stop there. 

Afterwards they are electrically shocked, beaten, then kept in holding pens only 

to await another terrifying event of being beaten again then butchered.

N

Thank you for your comment however this document is not tied to any gather as 

gathers are implementation level documents. 

DRMTDK-BL13-0356-2

Wildlife 

Also it is very important to do what we all can to keep the Sage Grouse off of the 

endangered species list because this would create huge if not impossible 

obstacles moving forward.

n Thank you for the comment.

DRMTDK-BL13-0358-1WILD 

HORSES,

PMWHR

There is ample proof that these animals are harmed during your round-up. Is 

that really necessary. Your choppers chase horses off cliffs. Why? What is the 

point? Can you please explain it to me? I ask that we find an alternate plan to 

control this "horse population"

N

Thank you for your comment however this document is not tied to any gather as 

gathers are implementation level documents. 

DRMTDK-BL13-0359-1

Social/econ

MLC produces annual sales of 650,000 tons of chemical limestone, with annual 

sales of $10 million to various customers. WLP annual sales are approximately 

$14 million. The combined limestone and lime operations directly impact the 

region's economic base with $2.4 million in payroll and benefits for 33 

employees.

n

Thank you for your comment. MLC’s operations dobenefit Carobn County’s 

economy. However the table you reference has to do the amount of BLM 

federal minerals contributing to Carbon county’s economy. 

DRMTDK-BL13-0359-2

NEPA

We believe that with proper development and management of the Dakota Coal 

and MLC resources and claims, the RMP/EIS goals and objectives for habitat 

management can be met while maintaining a valuable regional economic 

resource that ultimately contributes to cleaner air and water for Montana and the 

surrounding region.

N Thank you for your comment.

DR- edits 1. Executive Summary. Section 1.6.1.12.1. and for all subsequent occurrences n Thank you for your comment.
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MTDK-BL13-0359-3of these statements and conclusions in the RMP/EIS. We respectfully request 

that revisions to two paragraphs in this section be incorporated into the final 

RMP/EIS: Suggested revisions (in italics) for completeness and clarification: 

"With the exception of bentonite and chemical grade limestone, the development 

potential for other locatable minerals in the planning area is low. Large areas of 

commercially viable chemical grade limestone deposits in the planning area are 

located just northeast of Warren in southern Carbon County, occurring in the 

exposed upper Madison Umestone strata of the southwest flank of Big Pryor 

Mountain. Current and future bentonite and chemical grade limestone surface 

mining operations would not be affected under any of the alternatives because 

the mining claims are valid, existing rights and the areas recommended for 

withdrawal do not coincide with areas having development potential. "The BLM 

anticipates only limited development for locatable minerals (except for moderate 

development for bentonite and chemical grade limestone), fluid minerals, coal, 

and mineral materials during the life of the plan and, therefore, effects to the 

development of these resources from the alternatives are expected to be 

minimal to moderate. "Rationale: Based on the 50-plus year history of highcalcium limestone production from the Warren (Bighorn) Quarry now operated 

by Montana Limestone Company (MLC) in Carbon County, we believe this 

section and the conclusion statement should be amended to point out the 

significant viable locatable chemical grade limestone deposits in the 

southwestern Warren Pryor Mountains area. MLC is a division of the Dakota 

Coal Company (Dakota Coal), which acquired and improved the quarry 

operation in 2002 to provide chemical grade limestone products required by its 

customers. The quarry is recognized as one of the region's leading names in the 

production of chemical grade limestone which is provided at a level of over 95% 

calcium carbonate.

DRMTDK-BL13-0359-4

Coal 

Dakota Coal believes that the RMP/EIS does not adequately address the fact 

that this valuable locatable mineral - chemical grade limestone - is currently 

being mined in significant quantities with substantial reserves, contributes 

millions of dollars to the local economy, has a strong regional market, is 

supported by existing transportation infrastructure, and can continue to be mined 

well into the future given the multiple valid claims existing to the north and eastsoutheast boundaries of the current mining operations.

n Thank you for your comment.

DRMTDK-BL13-0359-5

Wildlife 

Section 2.5.2 Alternative B Dakota Coal believes that Alternative B is overly 

stringent and over-reaching in its approach to regional resource management. 

The closing of vast areas of the planning area to access, development, and use 

for private, public and commercial purposes does represent a reasonable 

balance of conservation objectives and resource yield management objectives 

for a majority of affected parties. Although the threat of an endangered species 

listing necessitates increased management of resources and 

N

Thank you for the comment. Your comment will be considered when 

alternatives are selected in the Final RMP/EIS decision. Note that Alternative B 

is a conservative alternative and is not the Preferred Alternative.
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restoration/mitigation efforts, this all or nothing approach would precipitate undue 

economic stress and quality of life impacts throughout the planning area. Yet, 

more measured approaches based on incremental steps, data gathering, 

monitoring and re-assessment would likely offer substantial, meaningful 

improvements to general and critical habitat over time without the immediate 

long-term deleterious economic and human impacts.

DRMTDK-BL13-0359-6

Travel mngt

Trails and Travel Management Areas (Table 2-6.2, Maps 143-146) Dakota Coal 

finds that the Alternative C TMA unnecessarily closes critical access roads to the 

Big Pryor Mountain through its southwestern flank from Warren, effectively 

channeling all OHV to one main open east-west route (Helt Road) rather than 

three managed routes as allowed under Alternative D. The funneling of all 

vehicles onto Helt Road would greatly increase the traffic load on this route and 

would lead to increased conflicts between administrative, recreational, and 

industrial/commercial vehicles. Ultimately, the OHV load could result in greater 

off-designated route traffic and associated habitat degradation. In addition, 

Alternative C keeps Graham Road closed, which would unduly limit access to 

unpatented mineral claims in BLM and USFS lands open for locatable and 

mineral materials rights, as well as recreational uses. Alternative D offers greater 

flexibility in designated routes to adequately service this destination area. Please 

give priority to opening Graham Road, keeping Helt Road open, and creating 

adequate access to the west Pryor Mountain area through multiple designated 

routes. These decisions could help prevent OHV traffic conflicts, reduce overuse 

of limited designated routes, and help prevent off-route traffic that could 

deteriorate habitat.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

In response to your comments, the BLM staff reviewed the decisions in the

Pryor Mountains TMA Alternatives. The decision on Graham Trail is to open the 

road, ensuring access to the mining claims and to be consistent with adjacent 

FS decisions. Helt Road is open for all travel. 

DRMTDK-BL13-0359-7

edits

Affected Environment, Section 3.17.4.5 "Locatable Materials We respectfully 

request that the following revisions be made to this section. Suggested revisions 

(in italics) for completeness and clarification: "There are currently two approved 

3809 mine plans for bentonite. Development potential for additional bentonite, 

gypsum, uranium, and limestone exist in the decision area. Locatable minerals 

related mining activity consists of two active bentonite mines and one active 

chemical grade limestone quarry, located in Carbon County. Two mining 

companies have both patented and unpatented claims for bentonite located on 

the west and southwest flanks of the Pryor Mountains in southern Carbon 

County. One mining company has patented and unpatented claims for chemical 

grade limestone on the southwest flanks of the Pryor Mountains near Warren in 

Carbon County. "Please add to end of the section the following specific company 

information: The Montana Limestone Company (MLC), a subsidiary of Dakota 

Coal Company (Dakota Coal), operates the Warren (Bighorn) Quarry about four 

miles northeast of Warren, Montana located in Carbon County, Montana. The 

Warren Quarry operation produces about 650,000 tons of chemical grade 

limestone each year, with average sales of about $10 million. MLC also owns a 

n Thank you for your comment.
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limestone fine grind plant and rail load-out facilities. Bighorn Limestone 

Company (BHLC) has an operating permit issued in 1972 by the State of 

Montana's Department of Environmental Quality (DEQ). BHLC controls over 

1,500 acres of patented claims in the Warren Quarry area. MLC owns 50% of 

BHLC and controls the mining rights on the BHLC patented claims as regulated 

by the DEQ operating permit. Dakota Coal controls 390 acres of unpatented 

claims on BLM and USFS land. [NOTE: Table 3-50 lists the following claims,

which do not appear to include Dakota Coal.]Lode Claims Carbon Placer Claims 

82Saleable Minerals 151 Permits 12

DRMTDK-BL13-0359-8

Social/econ

Affected Environment Suggested revisions (in italics) for completeness and 

clarification: Section 3.32.2.1 Demographic and Economic Characteristics and 

Trends On Table 3-71, please include chemical limestone production under the 

"Major Population Center(s) and BLM Land/Mineral Uses" Column for Carbon 

County.

n

Thank you for your comment. MLC’s operations dobenefit Carobn County’s 

economy. However the table you reference has to do the amount of BLM 

federal minerals contributing to Carbon county’s economy. 

DRMTDK-BL13-0359-9

Coal

Section 3.32.2.2.2 Mineral Development and Production "Federal mineral 

activities include oil and gas leasing and production, mineral materials (sand and 

gravel and decorative stone), and some unpatented bentonite claims. There may 

also be a federal coal lease sale in 2011 . Mining of private minerals includes 

these same minerals as well as coal, sand and gravel, chemical limestone, and 

platinum group minerals."

N A federal coal lease sale was conducted in the planning area in 2012.

DRMTDK-BL13-0360-1WILD 

HORSES, 

PMWHR

I strongly urge you to save the Pryor Mount Wild Horse Range in particular at 

this time. I urge you to look again at the practices and procedures currently in 

use and adjust your thinking to encompass the best possible outcome for the 

animals and the environment as a whole for all areas under your supervision.

N Thank you for your comment 

DRMTDK-BL13-0362-1

lands with 

wilderness 

characteristi

cs

We believe that Pryor Mountain Unit, Tract 4 (455 acres) should also be 

designated as an LWC. It is currently a strange "island" entirely surrounded by 

two adjacent Wilderness Study Areas (WSAs). The only reason it is not already 

part of one or the other WSA, and the only reason it is not designated as an 

LWC in the RMP, is because two redundant motorized routes go on opposite 

sides of it. The fact that the area between the two routes is only 455 acres is 

strong evidence of the unnecessary

n

Thank you for your concerns and comments. BLM follows Manual 6301 in 

conducting its wilderness inventories and Manual 6302 when considering lands 

with wilderness characteristics during planning. These Manuals implement 

Secretarial Order 3310 and incorporates principles from BLM guidance 

(Organic Act directives) and legal rules developed as part of BLM’s original 

wilderness inventories. Tract 4 of the Pryor Mountain Unit does not currently 

meet the size criteria. Please see Appendix K for details. The lands are not 

contiguous with either WSA and are isolated by the roads. 

DRMTDK-BL13-0362-

10

Travel mngt

Route PM1006 and part of PM1001. (Mostly in sections 27 & 28 T9S R28E)PM 

1006 is a 2 mile route from PM 1001 and back. The two routes are redundant. 

One route should be closed. We recommend closing PM 1006 and designating it 

as a non-motorized trail. The 445 acres inside the loop should be designated 

and managed as an LWC.1. Since the two routes are redundant closing one will 

not inhibit motor vehicle traffic up and down Sykes Ridge.2. This would reduce 

the many resource concerns identified on the Route Inventory Sheet.3. The 445-

acre island between the routes, excluded from WSA status could become an 

LWC.4. The Route Inventory Sheet identifies hiking as a "primary" use of route 

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

Regarding the Sykes Ridge routes (PM 1001 and PM 1006) the BLM staff has 

determined that both route segments will remain as open for motorized use in 

the RMP. 
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PM 1006. Access to this hiking route is not difficult for people without a 4WD. It 

is about a 1-mile cross country hike from paved Highway 37 in BCNRA to this 

route. Constructing a connecting trail might be considered in the future.5. The 

Route Inventory Sheet for PM 1006 claims the route is not "redundant" and that 

its uses cannot be met by another route. But the use of driving up Sykes Ridge 

can be met by PM 1001. One identified primary use of hiking can be better met if 

PM 1006 is designated as a non-motorized route

Regarding the potential construction of a non-motorized trail from Bad Pass 

Highway (state route 37) much of the lands are not managed by the BLM and 

the decision is beyond the scope of this plan.

DRMTDK-BL13-0362-

11

Travel mngt

Lisbon - Dandy Mine Loop This is an opportunity to designate a non-motorized 

loop route. (We can't determine all the BLM route inventory numbers from the 

BLM map. The loop includes routes PM 1023 and PM 1024. The loop is mostly 

in sections 4 & 9 T9S R27E. (See map.) The route (PM 1023) in section 9 from 

Crooked Creek Rd up to the Dandy Mine and Red Pryor Mountain Rd is 

designated open for motor vehicles in Alt D. This route should be designated for 

non-motorized use only. The rest of the loop including the switchback route, 

mostly in section 4, from Crooked Creek Rd up to the Lisbon Mine is closed in 

Alt D. This entire loop should be designated for non-motorized use only. Some 

Reasons:1. There are an abundance of motorized routes for access to the 

Pryors, but a scarcity of non-motorized routes.2. There are four other motorized 

routes up Red Pryor Mountain. Besides Red Pryor Mountain Rd itself, there is 

the switchback road from Crooked Creek Rd on Custer NF about 1 Â1⁄2 mile to 

the north of this loop, and two routes up from Horse Haven Rd to the west. 

These contribute to the many loop routes available for motorists.3. The trailhead 

for this hiking loop is accessible without a 4WD vehicle. Yet the hike provides 

outstanding views of Demijohn Flat, Crooked Creek Canyon and the East Pryor 

Mountain block

n

Regarding the potential for a non-motorized trail using segments of PM 1023 

and PM 1024, the BLM has reviewed the preliminary decisions in the RMP and 

has left all segments of PM 1024 as closed, with the exception of a segment 

from Red Pryor Road (PM 1025) to the top of the ridgeline (which could 

potentially serve as a staging area.). The BLM review determined that PM 1023 

would remain as “open” in the RMP. BLM will consider further the 

establishment of a designated non-motorized trail using components of PM 

1024 and other routes in its follow-up Implementation Plan. Also note that nonmotorized use is allowable on all open motorized, administrative only motorized 

routes, and closed vehicle routes

DRMTDK-BL13-0362-2

ACEC

The Pryors Coalition endorses the Montana Native Plant Society's (MNPS) 

recommendation that the Pryor Foothills ACEC be expanded to the west to 

include sections 30 and 31. We greatly respect MNPS expertise and concern 

that this expansion is needed to help protect important and rare plant 

communities

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS. Please refer to 

Appendix E. Areas Of Critical Environmental Concern in the Draft RMP/EIS for 

a discussion of ACEC Nominations for East Pryor ACEC (BLM nomination), 

Pryor Foothills Research Natural Area/ACEC (public nomination), and Sykes 

Ridge Rare Plant ACEC (nomination by Peter Lesica). 

Please see the 1998 ACEC Assessment and Proposed amendment to the 

Billings, Powder River and South Dakota RMPs here:

http://www.blm.gov/style/medialib/blm/mt/blm_programs/

planning/billings_rmp/amendments.Par.94086.File.dat/acecEA.pdf

pages 74-76 are the nominations evaluations for the Billings RMP and page 
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103 shows the map of the nominated vs. recommended ACEC.

DRMTDK-BL13-0362-3

ACEC, 

WSA

We do not approve of BLM's recommendation to remove area in the three WSAs 

from the East Pryor ACEC. WSA designation does not "provides adequate 

protection" (E-14, 33)1 for these areas. WSAs and ACECs are established for 

very different reasons and managed with different objectives. We see no reason 

to "eliminate the overlapping designations" (E-14). These compatible 

"overlapping designations" serve an important purpose of identifying and 

protecting multiple resource values. The Nomination Evaluation for the East 

Pryor ACEC (E-12 to 14) clearly identifies an amazingly broad range of reasons 

for this ACEC that are not part of WSA designation and management. Congress 

could at any time release the WSAs on East Pryor. Then the WSA surrogate for 

ACEC\ protection would vanish. We do not think the language that this area 

"would be managed as an ACEC" (2 169) is adequate. It should BE an ACEC.

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS

ACECs are proposed where special management attention is required 

to protect the important and relevant values in relationship to management in 

the BLM preferred alternative in the RMP. Should existing management be 

present (like a WSA) that protects the relevant and important values then ACEC 

designation is not necessary. Language is included in the RMP that should 

congress (ever) make a decision on wilderness in the Pryors, and this area not 

be designated wilderness, then it would be managed as an ACEC.

As WSAs contain the most restrictive management, there is no need for an 

ACEC to overlap the WSA. The relevant and important values of the East 

Pryor ACEC are addressed through the management of the WSAs. Thank 

you for your comments.

In regards to the overlapping designations of ACEC/Wild Horse Range/WSAs, 

the actual management prescriptions (No Oil and Gas development, etc.) are 

intended to be in place regardless of the land’s designation.

Please see table 2.63; Page 2-168 for WSA management prescriptions and 

page 2-147 for management prescriptions in the East Pryor ACEC, as well as 

page 2-171 for management prescriptions in the PMWHR.

DRMTDK-BL13-0362-4

Travel mngt Nothing in this RMP addresses the need for designated non-motorized routes in 

the Pryors y

In regards to your comment, BLM Manual 1626 (Travel and Transportation) 

specifies that BLM establish a comprehensive program for both motorized and 

non-motorized travel. This will be done in this RMP. See Appendix O. 

DRMTDK-BL13-0362-5

Travel mngt

A. The north end 1⁄2 mile of Bear Canyon "road" (In north 1⁄2 of section 3, 

PM1070)This section in the bottom of the canyon was washed out by a flood in 

spring 2011. It is currently signed closed to motorized use and barricaded. This 

is the only designated non-motorized route in any alternative (Alt B, map 144). In 

Alt D this section is designated open to motorized use (map 146).Several 

reasons why this route should be designated for non-motorized use only.1. This 

route is in a sensitive and rare (in the Pryors) riparian area. Bear Canyon is one 

of the few canyons on the south side of the Pryors that has intermittent to 

perennial water available for wildlife. It is also part of a National Audubon 

Society-designated Important Bird Area. Motorized use would significantly 

disturb birds and other wildlife using and dependent on the area.2. This area is 

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS
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infested with invasive weeds. Efforts to manage those weeds are beginning. 

Motorized use will seriously handicap this effort. Also motor vehicles making a 

quick 1 mile round trip tour into this canyon before going on up the Bear Canyon 

Ridge Rd (PM1069) would collect weed seeds to distribute throughout the rest of 

Big Pryor Mountain.3. This route is part of an increasingly popular hiking route 

for people who wish to escape motorized commotion. It has been used several 

times already in 2013 by MWA hiking groups. The presence of new cairns 

marking the descent into Bear Canyon indicate additional use by other hikers.4. 

This is a dead end route for motorized use. The old (and illegal) track on north 

into Custer NF is closed to motorized use

DRMTDK-BL13-0362-6

Travel mngt

we suggest the non-motorized route be Bear Canyon (PM1068) beginning at the 

canyon mouth 1⁄2 mile from Helt Rd for a number of reasons.1. It is an 

ecologically sensitive area and a National Audubon Society IBA, (See above)2. It 

is part of an increasingly popular hiking trail.3. Bear Canyon is the roughest of 

the three routes for motorized access.4. Although the route does connect with a 

motorized route on Custer NF, that CNF route is easily motor accessible from 

Stockman Trail.5. Equestrians, including the Beartooth Back Country Horsemen, 

are very concerned about safety issues related to mixing horses with 

motorcycles and ATVs. This would provide separate staging areas and trails for 

motorized use and horses.6. The inventory sheet for this route (PM1068) 

identifies many "special resource" concerns with regard to this route including 

birds, plants, soils, and archeological sites. The inventory sheet claims 

"Mitigation will be achieved by employing adaptive management monitoring of 

the status and/or integrity of the potentially impacted sensitive resources or 

resource issues identified above as they relate to various factors (e.g. climate 

cycles, exotic species introduction, visitor use levels [type, intensity, season of 

use])." This vacuous bureaucratese does not identify any specific action that can 

or will be taken to mitigate impacts of motorized use on the identified 

resources.7. The closure of PM1071 to public motorized use would do a lot to 

minimize impacts to Bear Canyon's special resources and make it a better place 

for hikers and equestrians. There would be public access to Bear Canyon rather 

than a motorized thoroughfare through Bear Canyon to the rest of Big Pryor 

Mountain. (Stockman Trail and perhaps Graham Trail would serve that 

purpose.)8. The Route Inventory Sheet for PM 1068 includes the question: "Can 

the ... uses of this route be adequately met by another route that minimizes 

impacts to the sensitive resources identified above ...?" BLM answers "No." We 

think the correct answer is obviously "Yes" because Stockman Trail goes to the 

same place. The only motorized use of this route that can't be met by Stockman 

Trail is motorized use of this route. (This would be true of any route.)

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed”

Refer to map 146

DRMTDK-BLTravel mngt This route should be closed to motorized use and designated as a nonmotorized route because:1. It is the beginning of an increasingly popular hiking nThank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 
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13-0362-7 route informally called the "Big Sky Trail." The trailhead is near a good gravel 

road (Helt Rd) and is accessible without 4WD. Although a moderately high 

clearance vehicle is desirable for the 1.8 mile distance on Horse Haven Rd, 

someone with only a highway vehicle could park near Helt Rd and still access 

the trail with a 1 1⁄2 mile extra walk on Horse Haven Rd.2. People do not want to, 

and should not have to walk a mile on route PM1034 before escaping motorized 

commotion and impacts.3. There is no particular purpose for this to be a 

motorized route. It dead ends at the CNF boundary. None of the old tracks north 

of the fence on Custer NF are legal for either public or administrative motorized 

use. CNF has a "no motor vehicles" sign at the fence and the gate is locked.4. If 

motor legal, this route would be an "attractive nuisance" tempting people to 

illegally drive further on BLM or on north into CNF where extensive illegal driving 

is possible. Having this route open to motorized use would cause an 

enforcement problem. How often will the scarce BLM and CNF law enforcement 

people make the 2 mile round trip in to the fence to check for violations? The 

fence was cut fall 2012. The cut fence was neither discovered nor repaired by 

BLM or CNF. Appropriate closure to motorized use at Horse Haven Rd means 

any vehicle tracks from that point indicate illegal activity, and would thus be a 

great aid in simple, efficient enforcement of ORV use regulation.5. According to 

the BLM Inventory Sheet for this route it is a "connector" route and provides 

property access to the Forest Service. But the 2008 CNF TMP does not 

designate the tracks north of the fence (on CNF) for either a public or 

administrative motorized use. So PM1034 does not "connect" to any other 

motorized route, public or administrative.6. There are a number of "Special 

Resource" issues identified in the Inventory Sheet related to this route.7. The 

inventory Sheet answers "No" to the question, "Can ... uses of this route be 

adequately met by another route that minimizes impacts....?" This question 

presumes motorized use. Since it is a dead end motorized route the answer 

should be "There aren't many motorized uses of the route." However the nonmotorized use of this route can be better met by closing it to motorized use

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

DRMTDK-BL13-0362-8

Travel mngt

Redundant Routes connecting Horse Haven, Bear Canyon, Stockman, and 

Graham Rds parallel to Helt Rd. (PM1076, PM1077, PM1082 ?)This 

approximately 4 mile route (three segments connected end to end) is proposed 

to be open for public motorized use in BLM's preferred alternative (D). It is not 

motor legal in Alt A and is currently signed "closed." It is also closed in Alt B. The 

entire route should remain closed to motorized use.1. This is a classic example 

of unneeded parallel routes. For most of its length it is less than Â1⁄2 mile north 

of, and in sight of Helt Rd. It follows the base of Big Pryor Mountain at the edge 

of the flat.2. The eastern 1 Â1⁄2 (approx.) mile between Bear Canyon and Horse 

Haven Rd (PM1076), provides a loop hiking route connecting the Bear Canyon 

and the Rocky Juniper Trails. (This 6 mile loop includes about 1 Â1⁄2 mile of 

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

The routes along the base of the mountains (PM 1082, PM 1077, and PM 1076) 

which you have expressed concerns with have been reviewed by the BLM staff 

and the determination is that they will remain as closed. The RMP has been 

altered to reflect this decision. PM 1076 will be specifically designated as a nonmotorized trail component?
Billings and Pompeys Pillar National Monument

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motor legal route in Bear Canyon and a short section of Horse Haven Rd., but 

with this newly proposed motorized route the 6 mile hiking loop would include 

3.3 miles of motorized route.)3. There is no need for the slight shortcuts these 

route segments provide for motor vehicles between Horse Haven, Bear Canyon, 

Stockman, and Graham. Helt Rd provides the needed access.4. The claim in 

BLM's Route Inventory Sheets that these routes are not redundant because they 

have public (motorized) uses that can't adequately be met by other routes is 

simply false. However the non-motorized public use of especially PM1076 

cannot be met by another route

DRMTDK-BL13-0362-9

Travel mngt

Demijohn Flat Route PM 1019 (SE from Crooked Creek Rd just south of 

BLM/CNF boundary.)This route is designated open in Alt D, but should be 

closed to public motorized use and designated for public nonmotorized use. (It 

could still be an administrative route as in Alt B.)1. This route encourages public 

motorized access to a culturally sensitive area designated as a National Register 

District and an ACEC. The preferred alternative proposes expanding the ACEC 

to include all of the Demijohn Flat National Register District. (E-14) That is a 

compelling reason to make the route nonmotorized.2. To the NE of this route is 

the Burnt Timber Canyon WSA. To the SW of this route is a proposed LWC. This 

route forms the boundary of both. There is no good reason for this motorized 

corridor. Closing this route to motorized use would allow a 1 Â1⁄2 mile common 

boundary between the WSA and LWC greatly strengthening both.3. This dead 

end route provides an "attractive nuisance" tempting people to drive beyond the 

designated end. Monitoring and enforcement will require regular 3 mile round trip 

excursions from Crooked Creek Rd by BLM LEOs. This is unlikely to happen 

often due to staff limitations. Efficient, effective monitoring and enforcement 

would be much easier if PM1019 was designated non-motorized from the 

junction with\ Crooked Creek Rd.4. This route could provide an easy hiking 

opportunity from Crooked Creek Rd, with a trailhead accessible without 4WD 

vehicles. Most people can walk. We have seen people in the Pryors park their 

UTV and go for a hike; it is likely that many riders, as with automobile drivers, 

would take advantage of the opportunity to complement their ride with a chance 

to stretch their legs. It is no more logical to assume that ORV users are 

incapable of walking than it is to assume that people in cars cannot do so. Many 

people like to walk and visit the Pryors specifically to hike -“ especially away 

from motor vehicles; the cultural and archeological values of the Demijohn Flats 

area are clearly enhanced by the opportunity to experience and contemplate 

them free from the distraction of vehicle noise and dust. Longer hikes south into 

the Burnt Timber Canyon LWC (Penney Peak area) are also possible beginning 

on this route

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

The BLM staff has also reviewed the preliminary decision for PM 1019 

(Demijohn Flat Road) and has changed the route status in the RMP from 

motorized to motorized (administrative access only) and along with PM 1022, 

PM 1038 and PM 1021 will also be designated as a non-motorized trail for 

general public use.

DRMTDK-BLEdits I note that BLM maps such as the key map at: 

http://www.blm.gov/mt/st/en/fo/billings_field_office/rmp/drmp/travel_management n

Thank you for your comment. Text has been edited in response to your 

comment.
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13-0363-1 /pryors.htmlshow some CNF roads that are not motor legal and do not show 

some CNF roads that are motor legal. Furthermore the map gives incorrect and 

nonexistent names for some routes. (e.g. FS 73 on two different roads and 

incorrect on both, Cty 282B on two different roads) (The reverse is true of CNF 

maps and BLM roads.)

DRMTDK-BL13-0363-2

Travel mngt

Sykes Ridge Rd is now as challenging to drive with my4Runner as it was with 

the Subaru. And it continues to get worse. What has changed? ATVs -“ lots of 

ATVs. ATVs (and UTVs) do not have a differential. Unless they are going 

absolutely straight (almost never on such roads), one wheel on each axel must 

be slipping on the ground because the two wheels are tracking on circles of 

different radius. Thus ATVs are constantly wearing on the road in a way that 

standard 4WD vehicles with differentials do not. Cumulatively they have the 

same impact as tracked vehicles which are forbidden. It would probably be 

impossible to see the effect of one pass or even ten passes. But with many 

hundreds of passes over a period of years there is a major erosional impact. 

This effect is multiplied by the fact that typically ATVs carry only one rider, while 

4WDs typically carry 2, 3, or more. This increases the impact per visitor by a 

factor of 2 or 3 beyond the fact that each ATV wears the road surface more than 

a 4WD

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

DRMTDK-BL13-0371-1

Travel mngt

Close Demijohn Flat route to motorized travel to protect the Burnt Timber 

Canyon ACEC. 3. Deny motorized access past the mouth of Bear Canyon 

because 2 other routes leading to the same general area are less than 3 miles 

away. 4. Designate Bear Canyon Trail and Big Sky Trail for quiet, non-motorized 

users.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed” to vehicle use and as a non-motorized trail.

Refer to map 146

Also note that BLM Manual 1626 (Travel and Transportation) specifies that 

BLM establish a comprehensive program for both motorized and non-motorized 

travel. This will be done in this RMP

Please note that the goal for the Pryor Mtn TMA is to protect wilderness values, 

cultural assets, visual characteristics, sensitive plants, fragile and erosive soils, 

wild horses and wild horse habitat.

DRMTDK-BL13-0381-1

NEPA

BLM must recognize, therefore, that not all uses need to be authorized 

everywhere in the analysis area in order to provide for multiple uses. On the 

contrary, with Montana's iconic prairie lands at stake, BLM needs to provide 

N

Thank you for your comment.

(non substantive)
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more balance in the RMP. More land needs to be set aside for sage-grouse and 

wildlife habitat and more lands need to be off-limits to OHV use and mineral 

development in order to provide for opportunities for quiet recreation and 

backcountry hunting opportunities.

DRMTDK-BL13-0381-

10

lands with 

wilderness 

characteristi

cs, NEPA

We also recommend that all lands with wilderness characteristics be included in 

a Master Leasing Plan (MLP) so that more care can be given to how these areas 

are managed for uses and values other than oil and gas (oil and gas should not 

dominate over other important resource values, including wilderness character 

and wildlife habitat).Including these areas in a MLP will provide an in-depth 

NEPA analysis on detailed closures, protective stipulations, and site-specific 

impacts that would come with any leasing in this sensitive area. While the 

proposed RMP revision underway is expected to provide broad guidance for 

leasing availability and general stipulations for wildlife habitat, it will not provide 

the crucial "look before you leap" in depth analysis of the specific resource 

values in an area. It is important that lease stipulations ensure necessary 

protection of public lands already leased and that non-waivable no surface 

occupancy stipulations be attached to leases that could threaten important 

wildlife habitat or use areas, water resources, recreation areas, historic sites 

etc., particularly if site-specific impacts are unknown or poorly known.

n

Thank you for your comment. Please see Chapter 1, section 1.4.1.3.1 – Issues 

considered but not further analyzed.

DRMTDK-BL13-0381-

11

lands with 

wilderness 

characteristi

cs

Regarding whether the Bear Creek area provides outstanding opportunities for 

primitive recreation, the inventory form says "yes." There "are outstanding 

opportunities for primitive recreation due to the presence of prehistoric carving 

on the cliffs of Petroglyph Canyon in the eastern portion of the unit. Although not 

well known or advertised, this region does have primitive recreation currently 

occurring on it and users appear to come from local, regional, and possibly 

national regions. The BLM has not, but may in the future, be required to actively 

manage this activity if use levels continue to increase. There are no permitted 

commercial outfitters currently using that area but there may be unauthorized 

guide services operating." The final summary notes that "a portion of the unit 

does offer outstanding opportunity for primitive recreation, but not the entire unit. 

There is not an outstanding level of solitude present." Again, however, the 

direction provided in BLM Manual 6310 is to not disqualify an area based on a 

finding that outstanding opportunities exist in only a portion of the area.

n

The BLM staff has reviewed the field work and documentation which was done 

previously for this unit, both by them and the documentation submitted by you. 

In light of this new data and the review, the team has determined that there are 

areas which possess outstanding levels of primitive recreation. The area was 

initially disqualified from further consideration, however, based on comments 

and supporting documentation, a review by BLM staff has determined that a 

portion of the unit (approximately 5,658 acres in size) does possess wilderness 

characteristics. Please see Appendix K and the lands with wilderness 

characteristics sections in chapters 1, 2, 3, and 4 for further discussions. 

DRMTDK-BL13-0381-

12

lands with 

wilderness 

characteristi

cs

size and naturalness were found to exist in the Dry Creek Unit, in addition to a 

very low incidence of human visitation, this unit should be acknowledged as 

possessing wilderness characteristics.

n

The BLM staff has reviewed the field work and documentation which was done 

previously for this unit, both by them and the documentation submitted by you. 

In light of this new data and the review, the team has determined that there are 

areas which possess outstanding levels of primitive recreation. The area was 

initially disqualified from further consideration, however, based on comments 

and supporting documentation, a review by BLM staff has determined that a 

portion of the unit (approximately 5,658 acres in size) does possess wilderness 

characteristics. Please see Appendix K and the lands with wilderness 
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Proposed Resource Management Plan and Final Environmental Impact Statement

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characteristics sections in chapters 1, 2, 3, and 4 for further

DRMTDK-BL13-0381-

13

lands with 

wilderness 

characteristi

cs

BLM should not drop the Bad Canyon Unit (2,036 acres) or the Weatherman 

Draw Unit (11,603 acres) from managing for wilderness characteristics in the 

preferred alternative. The Bad Canyon Unit, in addition to meeting the minimum 

size and possessing wilderness characteristics should be managed for 

wilderness values because it includes significant ecological and recreational 

values. The Unit is dissected by Bad Canyon Creek which is part of a Riparian 

Priority Recovery Area (an ecological value). The Bad Canyon Unit also provides 

outstanding opportunities for solitude

n

Thank you for your comments. The management actions for the areas you have 

identified have many appropriate measures to protect the resources without the 

formal designation. Please see the maps 11, 23, 57, 71, and map 156. Also 

note that there is no motorized access to the unit. 

Please see the end of Table 2.6.1 for Lands with Wilderness Characteristics 

management prescriptions and then refer to other sections in the table for the 

specific areas and their management prescriptions – many have the same 

regardless of designation 

DRMTDK-BL13-0381-

14

ACEC

To protect and give priority to existing and new ACECs, BLM should do 

everything within its authority to revise conditions of approval for existing leases, 

as necessary. We also recommend that the Steamboat Butte area be 

designated an ACEC. The area is not currently listed as an ACEC and is not 

being recommended for designation in the draft RMP. This is a mistake. The 

area hold significant paleontological and cultural resources and is listed under 

several hiking sites so it does receive some non-motorized recreational use.

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS

See appendix E for an evaluation of Steamboat Butte. 

DRMTDK-BL13-0381-

15

lands with 

wilderness 

characteristi

cs

In the DEIS, BLM includes very little information on how the proposed action 

may impact the four WSAs in the analysis area. There is simply not enough 

information in the DEIS to properly assess how and whether the proposed action 

-“ which includes designating areas for oil and gas development, OHV use on 

ways (as well as increased levels of OHV use on such ways), logging, rights-ofway and other uses -“ near, adjacent, and/or within WSAs will comply with 

FLPMA's non-impairment mandate for the WSAs in the analysis area.

n

BLM management actions within WSAs are governed by the BLM Manual 

6330- Management of Wilderness Study Area. All projects require specific 

NEPA analysis of an EA level, except those involving emergencies actions. 

In regards to your specific concerns, the Travel Management decisions in the 

RMP do not have any motorized routes designated as “open” within BIFO 

WSAs. Please see table 2.63, Page 2-168

Except as described in section 1.6.D.4.4 (access) of BLM Manual 6330 (page 

1-20) no new Rights-Of-Way will be approved for uses which do not satisfy the 

Non-impairment standard. This is also found in Table 2-6.3 on page 2-168 of 

the RMP 

In regards to your concern of oil and gas leasing within WSAs, the BLM Manual 

6330, page 1-22,, does not allow for any new oil and gas leasing. This is also 

found in Table 2-6.3 on page 2-168 of the RMP

In regards to logging, commercial forest product removal is generally not 

allowed (see pages 1-35 of Manual 6330), however vegetation may be 

removed only as an exception from the non-impairment standard for such 

reasons as public safety, emergencies, and insect and disease control. Please 

see page 1-33 of Manual 6330 for vegetation management prescriptions. This 

is also found in Table 2-6.3 on page 2-168 of the RMP 

Management of the WSAs is governed by BLM Manual 6300. By policy, no 

WSAs can be designated for oil and gas development (see RMP maps 160 and 
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161, and Manual 6330, page 1-22 for comparison with maps 54 to maps 57), 

OHV use must be restricted to designated routes or closed (RMP Maps 143 to 

146 and BLM Manual 6300, pages 1-27 to 1-29 for comparison) etc. In chapter 

2, tables 2.5, 2.61 and 2.63 there are discussions of actions which affect WSAs. 

All actions in WSAs are in accordance with existing Rules, regulations, and 

policies. 

DRMTDK-BL13-0381-

16

WSR, 

Travel mngt 

more information is required in the DEIS in order to submit meaningful public 

comments. Specifically, more information is required on: (1) the existing system 

of routes (roads and trails) in the analysis area including the location (as 

depicted on a map) and total mileage of routes; (2) BLM's inventory for eligible 

wild and scenic rivers; and (3) BLM's Section 106 of the National Historic 

Preservation Act (NHPA) inventory for cultural and historic properties.

n

thank you for your comment. More information on WSR can be found in 

appendix kl. Results of cultural inventories [proprietary information and cannot 

be included in public documents. 

DRMTDK-BL13-0381-

17

NEPA

it is important that the NEPA process and draft RMP carefully consider and 

incorporate the best available science on climate change and impacts to native 

wildlife species, especially sage grouse. In addition, BLM's inventory for eligible 

wild and scenic rivers must (but currently does not) satisfy NEPA's "best 

science" standard.

N

Thank your for your comment. 

Please see Appendix R for the WSR evaluation and analysis. 

DRMTDK-BL13-0381-

18

NEPA

This proposed action may have significant, direct impacts on the area's 

resources, including but not limited to ACECs, WSAs, lands with wilderness 

characteristics, cultural and historic properties, surface water resources (rivers, 

streams, creeks, lakes, ponds, wetlands), groundwater resources, soils, native 

vegetative communities, fish and aquatic species, native wildlife, big game 

species (pronghorn, elk, deer (mule and white-tailed), big horn sheep), game 

birds (including greater sage grouse), and special status species including, but 

not limited to listed and candidate species for protection under the federal 

Endangered Species Act ("ESA") and species of concern (both federal and 

state). BLM, therefore, must take a hard look at the direct impacts of the revised 

RMP on these important resources.

N

Thank you for your comment. The requisite level of information necessary to 

make a reasoned choice among the alternatives in an EIS is based on the 

scope and nature of the proposed decisions. As the EIS analyzes land use 

planning-level decisions, which by their nature are broad in scope, the requisite 

level of data and information is more generalized in order to apply to a wideranging landscape perspective. Although the BLM realizes that more data, and 

more site specific data, could always be gathered, the baseline data utilized in 

the EIS provide the necessary basis to make informed land use plan-level 

decisions.

The BLM considered the availability of data from all sources, adequacy of 

existing data, data gaps, and the type of data necessary to support informed 

management decisions at the land-use plan level. The data needed to support 

broad-scale analysis of the BLM Billings planning area are substantially 

different than the data needed to support site-specific analysis of projects. The 

RMP/EIS data and information is presented in map and table form and is 

sufficient to support the broad scale analyses required for land use planning.

Additionally, the BLM used the most recent and best information available that 

was relevant to a land-use planning-level analysis including the Baseline 

Environmental Report ([BER]; Manier et al. 2013). The BER assisted the BLM 

in summarizing the effect of their planning efforts at a range-wide scale, 

particularly in the affected environment and cumulative impacts sections. The 

BER looked at each of the threats to greater sage-grouse identified in the Fish 
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and Wildlife Service’s “warranted but precluded” finding for the species. For 

these threats, the report summarized the current scientific understanding, as of 

the BER’s publication date (June 2013), of various impacts to greater sagegrouse populations and habitats. The report also quantitatively measured the 

location, magnitude, and extent of each threat. These data were used in the 

planning process to describe threats at other levels, such as the sub-regional 

boundary and WAFWA Management Zone scale, to facilitate comparison 

between sub-regions. The BER provided data and information to show how 

management under different alternatives may meet specific plans, goals, and 

objectives.

The BLM consulted with, collected, and incorporated data from other agencies 

and sources, including but not limited to the U.S. Fish and Wildlife Service, and 

the Montana Fish, Wildlife and Parks. Additional information provided by state 

and local governments regarding socioeconomics also support the analysis in 

Chapter 4. 

As a result of these actions, the BLM gathered the necessary data essential to 

make a reasoned choice among the alternatives analyzed in detail in the Draft 

RMP/EIS, and provided an adequate analysis that led to disclosure of the 

potential environmental consequences of the alternatives (see Chapter 4, 

Environmental Consequences and Cumulative Effects). As a result, the BLM 

has taken a “hard look,” as required by the NEPA (see 40 CFR 1502.16), at the 

environmental consequences of the alternatives in the Draft RMP/EIS to enable 

the decision maker to make an informed decision.

As noted in more detail in responses to issue statements identified elsewhere in 

the report, the BLM has complied with the myriad applicable laws, policies, and 

guidance in developing the RMP/EIS. Section 2.2, Developing the Range of 

Alternatives, of the RMP/EIS, states that all alternatives would comply with 

state and federal laws, regulations, policies, and standards, and implement 

actions originating from laws, regulations, and policies. Additionally, in Section 

1.4.2, Planning Criteria, of the Draft RMP/EIS, the BLM has a criterion stating 

that all alternatives would comply with existing laws, regulations, and policies. 

The BLM has reviewed all actions in the Proposed RMP/Final EIS and found 

them to be consistent and within the bounds of all required laws, regulations, 

and policies. Further details regarding BLM compliance with state, county, and 

local plans and policies can be found in Section 1.5, Consistency with Other 

State, County, or Local Plans, of this report.

DRMTDK-BLNEPA The drastic and alarming decline in the natural habitat and numbers of greater 

sage-grouse (along with other game species such as pronghorn, sharp-tailed N

Thank you for your comment. 
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13-0381-

19

grouse, mule deer and non-game species like plover, Sprague's pipit, badger, 

jack rabbit, prairie dogs, and ferrets), in particular, requires special attention. 

BLM must take a hard look at how the proposed action directly (and, as 

discussed below, indirectly and cumulatively) impacts these important natural 

resources. Oil and gas development and ever increasing motorized access and 

use of public lands has resulted in the overall loss and degradation that is putting 

sage grouse and other species in peril. The impacts, therefore, must be carefully 

analyzed by BLM.

Please see Chapter 4 for impact analysis. 

DRMTDK-BL13-0381-2

Wildlife 

In greater sage-grouse priority protection areas, we recommend the following 

protective measures: close all areas to oil and gas drilling and exploration (or at 

the very least include NSO stipulations on all areas); allow all existing leases to 

expire (no renewal); take steps to minimize all adverse impacts to the resource; 

exclude areas from ROWs and consider opportunities to remove, bury, or modify 

powerlines; reclaim and restore any previous development in the areas; 

evaluate existing range improvements and modify, as necessary, to conserve, 

enhance, and restore habitat; withdraw area from locatable mineral entry; 

mineral material sales would require a plan to maintain habitat; and no new road 

construction (only maintenance of existing roads)

n

Thank you for the comment. Your protective measure suggestions will be 

considered when alternatives are selected in the Final RMP/ EIS.

DRMTDK-BL13-0381-

20

NEPA

Here, the DEIS fails to properly address indirect impacts of offering widespread 

oil and gas development, OHV use on "existing" roads and trails and on 

designated routes in 11 TMAs, and authorizing livestock grazing on 

387,057acres on the various resources of the analysis area, including but not 

limited to ACECs, WSAs, lands with wilderness characteristics, cultural and

historic properties, water resources (both surface and groundwater), fish and 

aquatic species, and native wildlife species (including big game, sage grouse, 

and special status species).

N

Thank you for your comment. Chapter 4 of the RMP/EIS provides a detailed 

description of the environmental and socio-economic consequences of 

implementing the alternatives presented in Chapter 2. 

DRMTDK-BL13-0381-

21

NEPA

In this case, BLM neglected to properly consider and analyze the cumulative 

effects of the proposed action. For example, in addition to the proposed action, 

there are a number of state, private, and other federal actions as well as natural 

occurrences or events taking place (or proposed to take place) in the analysis 

area including, but not limited to mining, oil and gas development, livestock 

grazing, irrigation, utility corridors, coal mining, private land development, 

logging and thinning (and associated developments), prescribed burning, 

recreation, energy development, travel planning, OHV use, climate change, and 

water developments. By themselves, these activities may have "individually 

minor" effects. A small area of wildlife habitat may be adversely affected by oil 

and gas activities or fragmented by existing and/or new designated routes. 

Lands with wilderness characteristics may be harmed by the sounds of an oil 

and gas rig or pre-existing mining operation, scarred by a new system route, or 

dissected by pasture and allotment fences. Individually, each of these incidents -

“ though serious -“ may not rise to the level of posing a significant risk to the 

N Thank you for your comment. 
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area's wilderness character or wildlife habitat. Collectively, however, the impacts 

of all of these and other activities -“ whether conducted by private individuals, 

state agencies, or other federal agencies -“ may be significant and must be 

analyzed.

DRMTDK-BL13-0381-

22

NEPA

No alternatives explore various ways to provide protections and mitigation for 

wildlife during the leasing or permitting process, i.e., incentives to protect large 

blocks of undeveloped land for wildlife habitat and wilderness values, clustering 

development, using timing restrictions and limitations (either as a lease 

stipulation or at the time of permitted), and incorporating detailed reclamation

plans. Nor does the DEIS explore alternatives that to seek to revise conditions of 

approval for applications for permits to drill (APDs) based on updated scientific 

information. The same is true with respect to livestock grazing (all alternatives 

make 434,154 acres available for grazing and permit grazing on 386,000 acres), 

special designations for sage grouse, and travel planning.

N

Thank your for your comment. 

Please see Chapter 2 for a discussion on alternative development. 

DRMTDK-BL13-0381-

23

NEPA

the BLM failed to: (1) explore an alternative that accommodates the short, mid, 

and long-terms needs of greater sage-grouse and other periled species; and (2) 

explore a real "no action" alternative as required by NEPA. BLM's purported "no 

action" alternative actually authorizes a host of activities in the analysis area, 

including oil and gas, OHV use, and livestock grazing.

N

Thank your for your comment. 

1) Please see Alternative B and appendices AA and AB to see how the BLM 

has incorporated guidance from the Sage-Grouse National Technical Team into 

this document. 

2) For the purposes of land use planning actions (ex. RMP/EIS): The No Action 

Alternative is to continue to implement the management direction in the land 

use plan (i.e., the land use plan as written). Any other management approach 

should be treated as an action alternative. (from: BLM Manual H-1790-1 page 

52) 

DRMTDK-BL13-0381-

24

cultural

the DEIS explains that the environmental analysis of impacts to cultural and 

historic properties in the planning area is primarily based on a Class I inventory 

(approximately 4.5% of the planning area, however, has been subjected to a 

Class III inventory).Based on information provided in the DEIS it appears that 

BLM: (1) does not consider the RMP to be an undertaking triggering the need to 

conduct Class II and Class III inventories now; (2) only commits to doing 

additional inventories if new surface disturbance occurs; and (3) has not 

undertaken a Class II or Class III inventory before authorizing various, sitespecific activities within the analysis area. BLM's approach is inconsistent with 

the NHPA, the implementing regulations, and BLM's own guidance.

n

Thank you for your comment. On-the-ground (Class II and Class III) cultural 

inventories are done at the implementation level. Please see text in Chapter 1 

(1.4.3) for a definition of land use plan decisions and implementation level 

decisions. 

The NHPA requires federal agencies to consider effects of federal undertakings 

on historic properties prior to making a decision or taking an action. Federal 

agencies meet this requirement by completing the Section 106 consultation 

process set forth in the regulations, including consulting with certain specified 

parties, such as the state historic preservation officer and Native American 

tribes, if relevant. Under Section 106, the process concludes with an agency 

finding of "no historic properties affected," "no adverse effect," or "adverse 

effects." 36 CFR 800.6.

NEPA, expanded the environmental review process to require federal agencies 
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to consider effects of proposed federal actions on the environment more 

generally. Federal agencies meet the NEPA requirement by preparing an 

environmental review document, which consists of a categorical exclusion (CE),

an environmental assessment (EA) or an environmental impact statement 

(EIS), depending on the level of potential impacts.

Neither statute mandates a particular outcome, but rather under both statutes, 

the impacts must be considered and the required processes must be followed.

DRMTDK-BL13-0381-

25

NEPA

not enough information is provided in the DEIS to properly assess NHPA 

compliance. Second, the proposed action (or at least certain aspects of it) qualify 

as an undertaking triggering the need -“now -“ to undertake a reasonable and 

good faith effort to identify cultural and historic properties. For example, the 

proposed action includes designating routes for motorized use in 11 TMAs. This 

is clearly an undertaking that will result in increased surface disturbance. Third, 

BLM should keep in mind that authorizing new surface disturbing activities is not 

a pre-requisite to qualify as an undertaking. According to BLM's own guidance, 

where there is a reasonable expectation that a proposed designation will shift, 

concentrate or expand travel into areas where historic properties are likely to be 

adversely affected a Class III inventory is required prior to designation. BLM's 

decision to designate 11 TMAs, therefore, triggers the need for a Class III 

inventory.

N

Thank you for your comment. On-the-ground (Class II and Class III) cultural 

inventories are done at the implementation level. Please see text in Chapter 1 

(1.4.3) for a definition of land use plan decisions and implementation level 

decisions. 

The NHPA requires federal agencies to consider effects of federal undertakings 

on historic properties prior to making a decision or taking an action. Federal 

agencies meet this requirement by completing the Section 106 consultation 

process set forth in the regulations, including consulting with certain specified 

parties, such as the state historic preservation officer and Native American 

tribes, if relevant. Under Section 106, the process concludes with an agency 

finding of "no historic properties affected," "no adverse effect," or "adverse 

effects." 36 CFR 800.6.

NEPA, expanded the environmental review process to require federal agencies 

to consider effects of proposed federal actions on the environment more 

generally. Federal agencies meet the NEPA requirement by preparing an 

environmental review document, which consists of a categorical exclusion (CE), 

an environmental assessment (EA) or an environmental impact statement 

(EIS), depending on the level of potential impacts.

Neither statute mandates a particular outcome, but rather under both statutes, 

the impacts must be considered and the required processes must be followed.

Please see Appendix ___ for the response from SHPO regarding cultural 

resources and travel management. Cultural resources were addressed as part 

of each route evaluation. See individual route reports. 

DRMTDK-BL13-0381-

26

Travel mngt

First, BLM never analyzes the direct, indirect, and cumulative impacts of 

designating system of routes for motorized use in the 11 TMAs and limiting 

motorize use to "existing" roads and trails outside the 11 TMAs on the various 

resources in the analysis area, including but not limited to lands with wilderness 

characteristics, ACECs, WSAs, native wildlife (including but not limited to, big 

game habitat and sage grouse habitat), soils, cultural and historic properties, 

and water resources. Important security areas for big game species, for 

instance, will continue to be carved up under BLM's hands off approach. 

n

The Billings Field Office has initiated a new effort in FY 2014 to inventory all 

transportation routes outside of the TMAs. All of these routes will be designated 

as “existing” and these will serve as the baseline for the transportation system, 

both motorized and non-motorized.

In lands which have been inventoried for their Wilderness characteristics, all the 

areas are managed as “limited” and all the areas were within TMAs which will 

have designated travel systems for non- motorized and motorized travel. Also 

note that all routes will be termed “primitive roads” if motorized use is allowed 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-224 Chapter 5: Consultation and Coordination

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Second, no effort is made to inventory, document, and map the "existing" system 

of routes outside the 11 TMAs. As such, it is impossible for BLM to analyze the 

impacts of such routes (and for the public to comment on the impacts of such 

routes) in the absence of a comprehensive inventory documenting and mapping 

all existing routes in the analysis area. The baseline condition will continue to 

change and likely get worse before a comprehensive travel plan for the entire 

planning area is developed (OHV use is on the rise).Third, as per Tri-State, no 

new user-created routes were to be created in the analysis area. Motorized use 

was to be restricted to existing routes that existed in 2003 (when the ROD was 

signed), subject to a few exceptions. BLM, however, has taken no steps to 

document the existing system of routes that existed in 2003. Nor is BLM 

attempting to do so now. What is preventing members of the public from creating 

new "existing" routes in the analysis area prior to adoption of the RMP and any 

future travel plan? And, how will BLM even know such routes are "new" given 

that lack of a comprehensive inventory? BLM concedes that the number of 

"existing" routes may change prior to completing a travel plan for the region. This 

is a violation of NEPA, Tri-State, E.O. 11644, and 43 C.F.R. § 8342.Fourth, in 

creating the 11 TMAs, there is no evidence in the DEIS or draft RMP that BLM 

considered and applied the minimization criteria (outlined above). This is a 

violation of E.O. 11644 and BLM's implementing regulations. Fifth, BLM should 

designate a system of routes (roads and trail) for the entire planning area (not 

just 11 TMAs) and not leave it up to whatever may be perceived as an "existing" 

route. As mentioned above, these routes should be depicted on a map and 

undergo a NEPA and minimization criteria analysis. BLM should also determine 

where lands fall on the Recreational Opportunities Spectrum (ROS). Managing 

an area as semi-primitive or even semi-primitive motorized, might help when lay 

the ground work for future travel planning. Sixth, until a travel plan is developed 

for areas outside the 11 TMAs, BLM should limit motorized travel to designated 

routes in areas where a wilderness inventory has been conducted. Through the 

wilderness inventory process, BLM has already identified existing routes and no 

new vehicle routes should be created before the travel planning process begins, 

which probably will not be completed for many years.

and as “trails” if not. 

DRMTDK-BL13-0381-

27

Travel mngt 

If BLM is going to defer travel planning outside the 11TMAs until after a ROD 

approving the new RMP is signed, we recommend the Agency initiate the 

planning and NEPA process for a travel plan as soon as practicable to avoid the 

creation of additional "existing" routes and further harm and impacts to the 

region's resources.

n

Based in part on public concerns similar to your comments, but also from 

discussions among the agency staff, and for the same reasons you have 

brought up, 

The BiFO has initiated a new travel planning process to establish the route 

baseline for lands outside the TMAs in the BIFO. The work is planned to be 

done in FY 2014. 

DRMTDK-BL13-0381-

Travel mngt 

BLM must also come up with an action plan and planning schedule to indicate 

areas that will have travel planning completed concurrently with the RMP 

process and which areas will be deferred. BLM Handbook 8342(IV) (B).

n

Thank you for your comments. BLM will develop a schedule for TMA planning 

as is required in the BLM 1626 Manual (Travel and Transportation). 
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28

DRMTDK-BL13-0381-

29

Travel mngt 

BLM must immediately close any areas where the agency finds that off-road 

vehicles are or will cause considerable adverse effects upon natural or cultural 

resources. 43 C.F.R. § 8341.2. BLM has policy guidance describing how RMPs 

and travel plans should address temporary closures including defining 

thresholds for when OHV related closures will take place. BLM should issue 

temporary closures for any area where OHVs are currently harming or may harm 

natural or cultural resources in the interim period before BLM can designate the 

appropriate travel network.

n

The BLM follows 43 CFR 8240, BLM Handbook 1626, Technical Reference 

9113-1 Planning and Conducting Route Inventories, as well as several 

Executive Orders (especially 11664) and Acts of Congress, including the 

Wilderness Act and FLPMA in designing and managing its Travel and 

Transportation system management. 

DRMTDK-BL13-0381-3

NEPA

In the DEIS, BLM mentions that many areas will not be given over-lapping 

designations. Greater sage-grouse priority protection areas, for instance, would 

not also be designated ACECs. And, BLM is recommending that an area within 

existing WSAs be removed from the East Pryor ACEC due to overlapping or preexisting protections.

N

Thank you for your comment. 

ACECs are proposed where special management attention is required 

to protect the important and relevant values in relationship to the BLM preferred 

alternative in the RMP. Should other management be proposed for these areas 

through the RMP process that protects the relevant and important values and 

ACEC designation is not necessary. 

As WSAs contain the most restrictive management, there is no need for an 

ACEC to overlap the WSA. The relevant and important values of the East 

Pryor ACEC are addressed through the management of the WSAs. 

DRMTDK-BL13-0381-

30

WSR

Under the WSRA, Congress explicitly limited a suitability determination for 

eligible rivers to eight items. These items include: (1) a description of the area 

(with maps); (2) the eligibility characteristics (free-flowing and ORVs); (3) status 

of landownership; (4) reasonably foreseeable future uses that would be 

enhanced, foreclosed, or curtailed if included; (5) the Federal agency 

administering the area; (6) the extent to which costs are shared by the state; (7) 

the costs to the U.S.; and (8) the degree to which the state may participate in 

protection and administration of the river. See 16 U.S.C. § 1275 (a); § 1276 (c).It 

is unclear if BLM appropriately applied these eight items. More information is 

needed. Notably, in other contexts, BLM has illegally transformed the WSRA's 

suitability factors into a subjective and political determination that offers cover for 

all decisions to reject rivers as unsuitable. In so doing, BLM is illegally standing 

in Congress' shoes, rejecting rivers as unsuitable based on purely political 

grounds.

Y

Thank you for your comment.

The BIFO did do a Suitability Study as part of this planning effort. It appears 

that the document was inadvertently left out of the document. It has been 

inserted into Appendix R, after the Eligibility Study Report.

DRMTDK-BL13-0381-

31

WSR

Before making a final decision on whether or not a river is "suitable" for inclusion 

in the NWSRS in the Billings District, BLM must analyze that decision in a NEPA 

document. See 47 Fed. Reg. at 39456. The document must include an 

assessment of the impacts of the decision (direct, indirect, and cumulative), an 

alternatives analysis, and be submitted for public review and comment. Id. Each 

"river study report will be a concise presentation of the information required in 

sections 4 (a) and 5 (c) of the Act as augmented by the Council on 

Y

Thank you for your comment.

The BIFO did do a Suitability Study as part of this planning effort. It appears 

that the document was inadvertently left out of the document. It has been 

inserted into Appendix R, after the Eligibility Study Report.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

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Environmental Quality regulations implementing the procedural provisions of the 

[NEPA]." 47 Fed. Reg. 39456. The Interagency Wild and Scenic River Council's 

technical papers and agency policy documents (Forest Service Handbook and 

BLM Manual) have followed suit by recognizing NEPA's applicability to the study 

report process. At present, this detailed information is lacking in the DEIS. BLM 

has not assessed the impacts of and alternatives to its suitable determination.

DRMTDK-BL13-0381-

32

NEPA

In addition to BLM's suitability determination, more information on why certain 

rivers or segments thereof were deemed ineligible is also required. Indeed, 

missing from the DEIS is the actual inventory documenting the standards and 

methods used and how the Agency reached its determinations for other rivers or 

segments thereof in the planning area. The public does not know why specific 

rivers and streams (or segments thereof) were deemed not to possess 

outstanding remarkable values. In order to submit meaningful public comment 

on the DEIS, the BLM must provide the actually inventory of eligible rivers and 

explain its methodology for identifying eligible and non-eligible rivers. For 

example, BLM suggests that to be deemed an outstandingly remarkable value it 

must be "exemplary," "significant," or be "nationally or regionally" important. BLM 

cites no authority to support such a high standard and we are not aware of any 

in the Wild and Scenic Rivers Act (WSRA) or the 1982 Interagency Guidelines.

N

Thank you for your comment. Please see Appendix R for the WSR evaluations, 

as well as the eligibility and suitability reports. The BIFO did do a Suitability 

Study as part of this planning effort. It appears that the document was 

inadvertently left out of the document. It has been inserted into Appendix R, 

after the Eligibility Study Report.

DRMTDK-BL13-0381-

33

NEPA

BLM, therefore, needs to go back -“under the appropriate standard for eligibility -

“and reevaluate all rivers within the analysis area. Particular attention should be 

placed on rivers that have both ecological, fish and wildlife, and historic/cultural 

values -“in particular those areas inhabited and/or used by Native Americans 

and the Lewis & Clark expedition.

N

Thank you for your comment. Please see Appendix R for the WSR evaluations, 

as well as the eligibility and suitability reports. The BIFO did do a Suitability 

Study as part of this planning effort. It appears that the document was 

inadvertently left out of the document. It has been inserted into Appendix R, 

after the Eligibility Study Report. 

DRMTDK-BL13-0381-4

lands with 

wilderness 

characteristi

cs

BLM finalized an original inventory of lands with wilderness characteristics in the 

1980s (the Montana Wilderness Inventory) and has since updated that inventory 

with new information. Pursuant to BLM's inventory for the DEIS, six tracts of land 

in the Pryors Unit, two tracts of land in the Burnt Timber Unit, one tract in the 

Weatherman Draw Unit, one tract in the Meeteetse Unit, and one tract in the Bad 

Canyon Unit possess wilderness characteristics. The total acreage of land (all 

eleven tracts) amounts to 27,292 acres.

n

Thank you for your comments and review of the lands with wilderness 

characteristics inventory process as well as the RMP in whole. 

Please see the end of Table 2.6.1 for Lands with Wilderness Characteristics, 

management prescriptions, and then refer to other sections in the table for the 

specific areas not found to possess wilderness characteristics and their 

management prescriptions – many have the same regardless of designation

DRMTDK-BL13-0381-5

lands with 

wilderness 

characteristi

cs

details on BLM's inventory being included in the DEIS (Appendix K). BLM's 

guidance explains the "Affected Environment" section of the NEPA document 

used to support the planning decision must "describe the inventory process, 

summarize any information received from the public, and incorporate inventory 

information by reference. The NEPA document should also include a brief 

description of each land with wilderness characteristics, including a map 

delineating the boundaries of each such area and the acreage." BLM Manual 

6320. The "Environmental Consequences" section of the NEPA document 

should "describe the direct, indirect, and cumulative effects of (1) various 

alternatives on lands with wilderness characteristics and (2) managing to protect 

n

Thank you for your comments. 

Suggested information to be included in the RMP has been included in the 

document. See Chapter 3 and Appendix K.
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lands with wilderness characteristics on other affected resources." Id.

DRMTDK-BL13-0381-6

lands with 

wilderness 

characteristi

cs

existence of two-tracks on the landscape -“ unlike roads -“ should not disqualify 

an area as land with wilderness characteristics or even count as a strike against 

managing such lands for wilderness characteristics. Nor should other human 

intrusions i.e. , fencing, stock ponds, that are minor and substantially 

unnoticeable be used to disqualify areas from being managed for wilderness 

character. The same is true with respect to mineral leases, ROWs, or other 

undeveloped interests. As stated in BLM Manual 6310, undeveloped ROWs and 

similar undeveloped possessory interests (e.g. mineral leases) are not treated as 

impacts to wilderness characteristics because these rights may never be 

developed.

n

This topic is discussed in Chapter 3 under Land with Wilderness 

Characteristics. The inventory update was completed following guidance 

contained in IM-2011-154 and BLM Manuals 6310 and 6320.

DRMTDK-BL13-0381-7

lands with 

wilderness 

characteristi

cs

BLM Manual 6310 sets forth guidance on how the BLM determines whether an 

inventory unit possesses outstanding opportunities for solitude and/or primitive 

and unconfined recreation, either of which is required to exist in order for an area 

to possess wilderness characteristics (among the other requirements). Two key 

provisions of the manual seek to minimize the tendency in which inventory units 

are discounted because outstanding opportunities may not exist on every acre, 

and also instances where units are compared relative to other areas nearby. 

BLM is instructed not to disqualify an area based on a finding that outstanding 

opportunities exist in only a portion of the area and is not to compare the lands in 

question with other parcels." Furthermore, BLM is to only consider the impacts of 

sights and sounds from outside the inventory area on the opportunity for solitude 

if these impacts are pervasive and omnipresent. "Notably, BLM's Manual 6310 

explains that "outstanding opportunities for solitude can be found in areas 

lacking vegetation or topographic screening. A small area could also provide 

opportunities for solitude if, due to topography or vegetation visitors can screen

themselves from one another."

N

Thank you for your concerns and comments. Based on these comments, the 

BLM staff has reviewed its findings in all the lands with wilderness 

characteristics units and has determined that a portion of the Bear Canyon Unit 

does meet the definition of possessing lands with wilderness characteristics

qualities. Accordingly, the RMP document has been revised to reflect this 

change. Please see the lands with wilderness characteristics text in chapter 2, 

3, and 4 for the discussion of this unit. BLM follows Manual 6301 in conducting 

its wilderness inventories and Manual 6302 when considering lands with 

wilderness characteristics during planning. These Manuals implement 

Secretarial Order 3310 and incorporate principles from BLM guidance (Organic 

Act directives) and legal rules developed as part of BLM’s original wilderness 

inventories. 

DRMTDK-BL13-0381-8

lands with 

wilderness 

characteristi

cs

BLM should also impose reasonable measures on existing and future leases 

(based on new findings and the need to manage the wilderness and wildlife 

values) and commit not to lease these areas once the existing leases expire.

n

Thank you for expressing your concerns and your comments have been 

included in the RMP administrative record. 

Please see the end of Table 2.6.1 for Lands with Wilderness Characteristics, 

management prescriptions, and then refer to other sections in the table for the 

specific areas not found to possess wilderness characteristics and their 

management prescriptions – many have the same regardless of designation

DRMTDK-BL13-0381-9

lands with 

wilderness 

characteristi

cs

Additional protective measures in lands with wilderness character (as well as 

sage grouse areas, ACECs, WSAs, and other sensitive areas) include providing 

lease-holders with incentives to protect large blocks of undeveloped land for 

wildlife habitat and wilderness values, clustering development, using timing 

restrictions and limitations (either as a lease stipulation or at the time of 

permitted), and incorporating a detailed reclamation plan. Also, if lands identified 

as having wilderness characteristics are developed for oil and gas, the plan 

should expressly state that they will be restored and managed for wilderness 

n

Thank you for your comment. Many of your suggestions are existing oil and 

gas stipulations (CSUs, TL, etc.) This topic is discussed in a range of 

alternatives in Chapter 2 under Wilderness Characteristics. The text has been 

clarified in the Proposed RMP/Final EIS in response to this comment.

Please see the end of Table 2.6.1 for Lands with Wilderness Characteristics, 

management prescriptions, and then refer to other sections in the table for the 

specific areas/units not found to possess wilderness characteristics and their 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-228 Chapter 5: Consultation and Coordination

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values upon completion of the oil and gas drilling. management prescriptions – many have the same regardless of designation

DRMTDK-BL13-0383-1WILD 

HORSES, 

PMWHR

Please work with the Forest Service to include the open meadows and Tony 

Island Spring in the mountaintop range. Please work with the National Park 

Service to reintroduce the Sorenson Extension into the horse range

N Thank you for your comment 

DRMTDK-BL13-0384-1

Travel mngt

GC 1001 (marked #1 on the attached map) is a 1/2 mile section of road that 

connects the east section of the Grove Creek County road, to a continuous 

section of Grove Creek County road slightly west, all a single piece of roadway 

travelling east/west off State Highway 72. This section is inaccurately shown in 

the detail, as having a length of 1.4 miles. The only thing different from the 

roadway east of this section, and the roadway west of this section, is that this 1/2 

mile portion is on BLM. This road is the main traveled roadway from Highway 72 

running westerly to a number of privately owned residences, and to the Grove 

Creek Ranch Headquarters. BLM should insure that this type of ROW access 

continues to be provided under any alternative. Next is a section of road 

approximately 5/8 mile long that is either described as the extreme west piece of 

the Grove Creek Road, or the extreme east end of GC 1047 Gold Creek. I have 

marked it as #2 on the attached map. Connecting to it on the east side is another 

5/8 mile piece I have shown as #3 on the attached map. These two legs of a wye 

are the main connectors from State Highway 72, to the Meeteetse Trail, and 

provide access to a number of private residences, (including mine), as well as to 

dozens of private property owners of 20 and 40 acre pieces of property 

accessed off Meeteetse Trail. Road #2 is a more graveled piece of road that 

receives the biggest percentage of east/west travel since it is not as susceptible 

to ruts and water puddles when wet. Road #3 tends to be more dirt sections and 

quickly develops waterholes and tire trail ruts when wet and is therefore more 

avoided, depending on the time of year. Without these connectors from Grove 

Creek Road to the Meeteetse Trail, traffic to the numerous residences in the 

area would have to connect to State Highway 72 via the Robertson Draw and 

Chance Roads. This would add approximately 5.2 miles to east west traffic in the 

event of an emergency. Seven to ten minutes of additional response time can be 

critical in the event of a fire or medical emergency.

n

Thank you for your concerns and comments. In regards to the vehicle routes 

which you have identified, BLM staff have reviewed the route designations and 

determined that all (marked “#1, #2, and #3 on your submittal map) are 

designated as “open” in the RMP and are not closed. 

DRMTDK-BL13-0384-2

ACEC

Topic: Grove Creek ACEC Comments This is a large area totaling approximately 

20 to 22 sections (12,800 to 14,080 total acres depending on Alternative), that is 

checker boarded with private land, State land, and BLM land. There are 

numerous privately owned homes in this area, with dozens more individual 

property owners of property that has been surveyed, plated, and sub divided into 

20 acre and 40 acre parcels since the early 1970's. These factors do not lend 

this area to an ACEC designation. There is too much wild land urban interface. If 

there are in fact legitimate areas on the BLM owned portions that meet both the 

Relevance and Importance tests, then only those areas on the westernmost 

section of the Gold Creek Complex and the Ruby Creek Complex, in 160 acre 

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS

The proposed Grove Creek ACEC varies in size by alternative from 8,251 acres 

(Alts B and D) to 9,445 acres (Alt C). The BLM can only designate BLM 

managed public land as an ACEC and the relevant and important values of the 

ACEC go beyond the physical archaeological sites on the ground, it is a 
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segments only, should be considered for ACEC designation, and not the entire 

22 section area.

possible traditional cultural property to the Crow tribe. 

Please see Appendix E for the resource evaluation on this ACEC. Also please 

refer to FLPMA Sections 103, 201, and 202 for the direction which it provides 

regarding the high priority BLM is to give in the designation and management of 

ACECs.

DRMTDK-BL13-0384-3

Fire 

Ecology 

and 

Manageme

nt

The fire management and suppression policy as shown in the proposed Grove 

Creek ACEC is in conflict with the intent of sage grouse habitat protection. 

Immediate suppression should be the policy in all fires involving sage grouse 

habitat, to not only protect the sage grouse habitat itself, but private property and 

human life that reside in the area as well, regardless of the origin of the fire. 

None the less, under any proposed alternative BLM should specify and clarify 

the criteria considered before a decision is made to manage fire in this area.

N

Thank you for expressing your concerns. 

Please see table 2-6.3 Grove Creek 

Please see Appendix E for the resource evaluation on this ACEC. Also please 

refer to FLPMA Sections 103, 201, and 202 for the direction which it provides 

regarding the high priority BLM is to give in the designation and management of 

ACECs. In response 

to your comment, the text in Alternative D for the Grove Creek ACEC of the 

Proposed RMP and Final EIS has been revised to state: Wildfire management 

(natural ignitions) for resource benefit. Full range of fire management activities 

would be used in ACEC in response to human-ignited fires. Use of heavy 

equipment and retardant would be avoided unless approved by authorized 

officer. 

DRMTDK-BL13-0386-1

Livestock 

Grazing, 

vegrangelands

the DRMP addresses conservation concerns to a degree, the document falls 

short of providing the depth of analysis and consideration of grazing alternatives 

warranted by a land use plan for all BLM-managed lands in south-central 

Montana. In spite of the evidence of widespread loss of plant productivity and 

ground cover, accelerated erosion and BLM's own documentation of rapid 

declines in species such as sage-grouse, BLM routinely chooses not to address 

livestock impacts in any scientific or sustainable fashion. In regards to livestock 

grazing, Western Watersheds Project urges the BLM to add the following to the 

Final EIS and RMP:(1) specific measurable terms and conditions for livestock 

grazing in riparian areas, uplands, and wildlife and fisheries habitat, including:(I) 

a minimum of 7" stubble height remaining on hydric soils riparian greenlines 

after livestock grazing(ii) a 10% maximum annual bank or wetland alteration 

from all sources for streams and wetland hydric and mesic soil areas of upland 

seeps, springs, wet meadows and aspen clones(iii) a maximum annual woody 

browse utilization by all browsing ungulates of 15% on cottonwood, aspen, 

woody shrub, and willows (iv) a maximum annual grazing utilization of perennial 

grass species on upland landscapes by all grazer of 35%(v) a minimum 9" 

residual perennial native grass cover for ground-nesting birds like sage-grouse 

and sharp-tailed grouse(2) additional needed alternatives(3) inclusion of 

directions for the permanent retirement of voluntarily waived grazing permits in 

n

Thank you for your comment. The specific measurable term and conditions you 

outline in comment bullet 1 are not within the scope of an RMP level analysis, 

and blanket terms and condition which would be applied through an RMP are 

not always warranted. This is supported by the data presented on page 2-13 

and in Appendix S, in which 83.5% of the allotments (approximately 309,700 

acres) are meeting all standards for rangeland health, an additional 9.1% 

allotments (approximately 41,000 acres) are making significant progress toward 

meeting standards, and eleven allotments (3,835 acres) are not meeting 

standard for rangeland health. 

The use of management tools such as the guidelines outlined in appendix I, as 

well as and if appropriate measurable use limits are analyzed, and implemented 

through site specific NEPA analysis during permit/lease issuance.

Comment Bullet 2: An adequate range of alternatives was analyzed. (See 

section 2.2.) Each alternative provides a different emphasis for managing public 

lands and resources within the planning area, and each alternative represents a 

complete and reasonable RMP that (1) meets the purpose and need described 

in Chapter 1; (2) responds to environmental, operational, and economic 

concerns raised by the public, agencies, businesses, and other special interest 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

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all alternatives and the selected alternative of the Final EIS groups during the scoping process; and (3) addresses potential environmental 

issues identified during review of the proposed management actions.

Comment Bullet 3: The permanent retirement of all voluntarily waived grazing 

permits is not warranted. As previously stated 83.5% of the allotments 

(approximately 309,700 acres) are meeting all standards for rangeland health 

and an additional 9.1% allotments (approximately 41,000 acres) are making 

significant progress toward meeting standards. The rangelands of the Great 

Plains have a long evolutionary history of grazing and grazing is accepted by 

grassland ecologists as a keystone process of the grassland ecosystem 

(Fuhlendorf and Engle 2001, Milchunas et al. 1988, Knapp et al. 1999). On a 

site specific basis, by policy, the BLM would examine and document whether 

continued livestock use of all or a part of the forage allocation proposed for 

relinquishment meets rangeland health standards, and if that continued use 

would be compatible with achieving land use plan management goals and 

objectives. 

DRMTDK-BL13-0386-

10

Livestock 

Grazing

Any analysis of grazing is incomplete without a discussion of the effect the 

practice has had on predators. The most vehement opposition to wolves, bears, 

and other predators comes from the livestock industry, and is one of the main 

reasons some of the species are now listed. Predators perform important topdown ecological functions, yet they are consistently eradicated and heavily 

managed in order to protect livestock on public land, costing taxpayers millions 

of dollars. The DEIS fails to include an analysis of the impacts from livestock 

grazing on predators in the planning area, and such a discussion must be 

included in the FEIS

n

Impacts to predators as the result of livestock grazing are not within the scope 

of the RMP. Montana Department of Fish, Wildlife, and Parks manage the 

wildlife species, including harvest laws and regulations. This includes: Game 

species, such as black bear, wolf, and mountain lion, furbearers such as 

bobcat, and non-game species such as fox and coyote. Additionally, the US 

Fish and Wildlife Service manage threatened and endangered species such as 

the lynx and grizzly bear. In areas where these species occur, Standard 5 

(Habitat) found in appendix I states “The environment contains all of the 

necessary components to support viable populations of a sensitive/threatened 

and endangered species in a given area relative to site potential.” Therefore if 

livestock grazing is impacting habitat or specific populations in a given area, 

site specific terms and conditions would be analyzed through the NEPA 

process, and applied as deemed necessary.

Additionally, BLM has a Memorandum of Understanding (MOU) with USDA 

Wildlife Services for predator control on public land. MOU mandates the 

preparation of NEPA analysis, and an annual predator control plan and report.

DRMTDK-BL13-0386-

11

Wildlife 

The Final EIS should discuss in detail the vast array of livestock diseases that 

can significantly harm if not kill native wildlife. Bighorn sheep in particular are 

extremely susceptible to livestock diseases carried by domestic sheep and 

goats, which are often asymptomatic to these same diseases." Pasteurella 

pneumonia and lung worm in particular are spread by domestic sheep. Yet, the 

RMP proposed to continue domestic sheep grazing in known bighorn sheep 

ranges without disclosing the expected impacts

n

Thank you for the comment. The disease transmission risk has been 

recognized in several locations in the DRMP. 

Refer to Sections 2-6.1, page 2-72 and 73, and 2-6.2, page 2-120, where 

Alternative D states, “Domestic sheep/goat permits – No new grazing permits 

authorizing sheep or goat allotments would be allowed in bighorn sheep range 

(Map 17).

Sheep and goat allotments in areas with risk of contact with bighorn sheep and 

domestic sheep and/or goats in the planning area would be reviewed and 
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managed, or reclassified if necessary, to achieve effective separation (both 

temporal and/ or spatial) between domestic sheep and/ or goats and bighorn 

sheep. 

Domestic sheep and goats used for weed control would only be authorized 

where mechanisms are in place to achieve effective separation from wild 

sheep.

(Table 2-6.1, page 2-63)

Management actions that preclude grazing in certain areas of the planning area 

are in place because livestock grazing has been deemed inconsistent with 

other activities, uses, or needs (i.e. wild sheep range, concentrated recreation 

areas, etc.). (Table 2-6.2, page 2-116)

DRMTDK-BL13-0386-

12

Livestock 

Grazing, 

vegrangelands

Given these findings, the BLM should analyze the impacts of long-term active 

management and its impacts on sagebrush communities and obligates 

compared to the impacts of removing livestock and allowing these communities 

to recover naturally. Additionally, since the continued "management" of 

sagebrush has led to many of the situations scientists now agree are threatening 

these ecosystems, the removal of livestock from sagebrush communities should 

be a seriously considered alternative in the RMP

n

Please refer to section 2.4, “Alternatives Considered but Not Analyzed in 

Detail”. This topic was discussed in detail in Section 2.4.1 “Eliminate Livestock 

from BLM Public Lands”, on page 2-12 through 2-15.

Livestock grazing has occurred on public lands within the field office since 

settlement, representing “long-term.” In the face of “long term” grazing, 343 

allotments of the 370 total allotments are meeting standards for rangeland 

health, or are making significant progress towards meeting standards, 

representing 350,811 acres (table 3-16 Pg. 3-50) or nearly 81% of the acres 

within the field office.

Standards for Rangeland Health (appendix I) outline the ecological processes 

which must be intact and functioning, including production, diversity, and 

residual cover. The standards are to be used in conjunction with Ecological 

Site Descriptions (Pg. 3-48) which recommend management actions (including 

livestock grazing) for specific communities on a site specific basis.

DRMTDK-BL13-0386-

13

Wildlife

The 2012 Montana Fish, Wildlife, and Parks ("MTFWP") counts for the eastern 

Montana Sagegrouse Management Zone are only 64.9% of the long term 

average.68 Across Montana, sagegrouse numbers have declined by more than 

half since 1980.69 Furthermore, hunter harvest estimates have declined even 

further, dropping from 40,000 birds in 1984 to less than 5,000 in 2011.70 This 

represents an 87.5% decline in hunter harvest across the State. Please review 

and share this important sage-grouse data in the final EIS. If you have more site 

specific information relevant to sage-grouse trends and habitat conditions within 

the Hi-Line RMA, please reveal it in the final EIS as well

n Thank you for your comment. This comment refers to the Hiline DRMP/EIS

DRMTDK-BL13-0386-

14

Livestock 

grazing, 

social/econ

The economic and social value of public lands livestock grazing receives 

disproportionate weight in the DEIS. The importance of public lands grazing to 

the economy of the region is grossly overestimated. The calculation of the social 

and economic values of the draft plan should demonstrate a clear understanding 

and consideration of the conflicts between continued grazing and other uses of 

N

Costs associated with administering the range program are included in the Field 

office’s annual salary and non-salary expenditures analyzed in Chapter 4. 

These expenditures are financed with congressionally appropriated funds.
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the public lands. The BLM must provide a more thorough analysis of the social 

and economic values of different livestock grazing levels. This analysis must 

consider the administrative costs of a grazing policy, economic benefits from 

recreation where grazing is reduced or eliminated, and the cost of negative 

environmental consequences of livestock grazing in the area

DRMTDK-BL13-0386-

15

Livestock 

grazing, 

social/econ

The administrative costs of public lands grazing are often underestimated, and 

not even considered in the DEIS. Considering only direct costs, BLM range 

management costs in 2011 totaled $77.3 million, while income from grazing fees 

was only $4.5 million, leaving a net deficit to the U.S. Treasury was $72.8 

million.79 This loss on federal grazing programs fails to consider indirect costs, 

such as administration of the range program. Estimates of those indirect costs 

rise well over $100 million.80 The economic calculation in the DEIS ignores 

potential administrative cost savings from reduced grazing. Decreased grazing 

would save the BLM costs associated with environmental analysis, litigation, 

grazing permit administration, predator control, weed spraying, and costly efforts 

to preserve species harmed by grazing

n

Costs associated with administering the range program are included in the Field 

office’s annual salary and non-salary expenditures analyzed in Chapter 4. 

These expenditures are financed with congressionally appropriated funds.

DRMTDK-BL13-0386-

16

Social/econ

Agricultural statistics often overestimate the value of public lands ranching to 

local economies. The number of permittees and full-time ranchers is often 

extremely inflated. In fact, "the elimination of all public lands livestock grazing 

would result in a loss of 18,300 jobs in agriculture and related industries across 

the entire West, or approximately 0.1 percent of the West's total employment."81 

For further information on the significance of federal public lands grazing to 

employment and economies in the West generally, see Thomas Power's article, 

Taking Stock of Public Lands Grazing: An Economic Analysis.82Â 82 Thomas 

Power, Taking Stock of Public Lands Grazing: An Economic Analysis, available 

at http://www.publiclandsranching.org/htmlres/wr_taking_stock.htm.

n

The livestock grazing analysis uses the best available information from BLM 

grazing permits and a peer-reviewed method of estimating employment and 

income associated with livestock grazing, as described on pg. 4-595 of the 

DEIS.

DRMTDK-BL13-0386-

17

Social/econ

Often, public lands recreation provides far more economic benefit to local 

communities than livestock grazing. Improved environmental conditions that 

would result from decreased grazing would likely create more jobs and economic 

development related to outdoor recreation such as hiking, camping, fishing, 

hunting, and the associated benefits to restaurants, hotels, convenience stores, 

and other in the area. A 2011 Department of Interior study stated that 

"[r]ecreation visits to Interior-managed lands in the contiguous United States, 

Hawaii, and Alaska in 2011 supported over 403,000 jobs and about $48.7 billion 

in economic contributions to the communities and regions surrounding Interiormanaged land."83 The DEIS ignores the economic significance of recreation, an 

economic benefit that would increase with improved land conditions from 

decreased grazing

n

The livestock grazing analysis uses the best available information from BLM 

grazing permits and a peer-reviewed method of estimating employment and 

income associated with livestock grazing, as described on pg. 4-595 of the 

DEIS.

DRMTDK-BL13-0386-

Livestock 

grazing

The DRMP fails to address the economic costs of environmental degradation. It 

fails to calculate the value lost from negative environmental impacts to water 

quality and quantity, aquatic species habitat, riparian and upland wildlife habitat 

N

Thank you for your comment. Please see Chapter 3, Table 3-17 for a summary 

of allotments/acreage meeting Standards of Rangeland Health. 
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18 quality and quantity, and native vegetation. Unsustainable grazing practices 

proposed in the DEIS could lead to species loss throughout the area. The DEIS 

also fails to address the potential for further exotic species and weed 

expansions, the costs associated with weeds and flammable invasive species, 

and the resulting potential for species loss. The viability of wildlife and rare plant 

populations and the cost to protect and preserve them in the face of chronic 

grazing degradation demands BLM's attention. If the BLM is to rise to its calling 

as land administrator for the public, the beauty and intrinsic value of the land, as 

described by Aldo Leopold, must also be addressed

DRMTDK-BL13-0386-

19

Livestock 

grazing

The DRMP fails to provide in-depth analysis of various alternatives, including a 

no grazing alternative, and two or more significantly reduced livestock use 

alternatives. The draft plan alternatives would permit grazing of an average of 

42,931 AUMs on 386,000-387,000 acres.88 The impact of oil and gas 

development on these species is analyzed in more detail, but livestock grazing 

impacts are not sufficiently analyzed. Western Watersheds Project urges the 

BLM to add specific measurable objectives for livestock grazing specific to 

riparian areas, uplands, and impacts on sensitive species habitat in order to 

comply with FLPMA, beginning with the five terms and conditions mentioned 

above

n

A no grazing alternative was considered but not analyzed in detail (section 

2.4.1 Pg. 2-12 and 2-15) for various reasons, including the data presented in 

the comment above. Additionally, reduced grazing was not considered due to 

the fact that across the board reductions are not warranted because only 11 

allotments (3,835 acres) are not meeting standards. A “No Grazing” alternative 

is considered, and analyzed in detail during site specific NEPA analysis prior to 

permit/lease issuance. The proposed alternatives and existing rangeland 

health standards and guidelines for the Billings FO provide the necessary tools 

to mitigate and address resource conflicts and competing uses within the 

planning area. The draft plan and EIS provides sufficient detail to foster 

informed decision making at the broad, programmatic level of this plan.

Rangeland Health Standards (Appendix I) specifically Standard 5 (habitat) 

ensures that livestock management will comply with FLPMA. Standard five 

states “The environment contains all the necessary components to support 

viable populations of a sensitive/threatened and endangered species in a given 

area relative to site potential.” Additionally, the incorporation of measurable 

objectives for livestock grazing is outside of the scope of an RMP level analysis, 

and should be conducted at the site specific NEPA analysis stage based on site 

potential, available resources, and seasonal use patterns. It is at the sitespecific level, when BLM is making a critical decision to act, that the agency is 

obligated fully to evaluate the impacts of a proposed action.

DRMTDK-BL13-0386-2

Livestock 

grazing

the reason for addressing livestock grazing in the RMP is to improve the range 

condition of the allotments within the project area and to maintain and improve 

wildlife habitat. This direction, based on laws and regulations, should be 

explicitly stated in the "Purpose and Need for the Plan" in the FEIS. 

Furthermore, the selection of any alternative in the DEIS that does not provide 

direction for meeting those goals violates the intent of the laws and regulations 

that govern public land management

n Thank you for your comment

DRMTDK-BL13-0386-

Livestock 

grazing

The BLM should consider a no grazing alternative. The DRMP states that 

"[Necause the BLM has considerable discretion through its grazing regulations 

to determine and adjust stocking levels, seasons-of-use, and grazing 

n

There is no documented need to entirely eliminate livestock grazing within the 

planning area. A no grazing alternative was considered but not analyzed in 

detail (in the DRMP: section 2.4.1 Pg. 2-12 and 2-15) based upon the 
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20 management activities, and to allocate forage to uses of the public lands in an 

RMP, the analysis of an alternative to entirely eliminate grazing is not 

needed."89 Considering the scientific evidence demonstrating that the 

elimination of grazing is the only way to protect and restore many areas, the 

BLM should provide analysis of that important option

proportion of public land and number of grazing allotments meeting standards, 

and making significant progress towards meeting standards. Additionally, 

reduced grazing was not considered due to the fact that across the board 

reductions are not warranted because only 11 allotments (3,835 acres) are not 

meeting standards. A “No Grazing” alternative is considered, and analyzed in 

detail during site specific NEPA analysis prior to permit/lease issuance. The 

proposed alternatives and existing rangeland health standards and guidelines 

for the Billings FO provide the necessary tools to mitigate and address resource 

conflicts and competing uses within the planning area. The draft plan and EIS 

provides sufficient detail to foster informed decision making at the broad, 

programmatic level of this plan. Please see Section 2.4.1 for rationale for 

Alternatives Considered but not Analyzed in Detail - Eliminate Livestock 

Grazing from BLM Public Lands.

DRMTDK-BL13-0386-

21

Livestock 

grazing

In addition to the no grazing alternative, the BLM should analyze an alternative 

that reduces permitted grazing by 50%. The current alternatives offer only 

minimal variation in number of acres and permitted AUMs, and only a reduction 

of 50% or more would offer sufficient change to address the environmental 

impacts of livestock grazing. The EIS and RMP must also address the fact that 

livestock sizes, and thus forage consumption, have increased dramatically since 

the AUM was defined. Failure to address this critical issue will lead to legal 

vulnerability under NEPA, APA and the False Claims Act

n

Thank you for the comment, As stated above across the board reductions are 

not warranted based on current land health standard statistics. Reductions are 

considered at the site specific level rather than at an RMP level to address site 

specific issues. 

For purposes of pragmatic and orderly range administration, the BLM's 

definition of an Animal Unit Month (AUM) for fee purposes at 43 CFR 4130.8-1 

(c) encompasses a variety of classes of animals

that vary in weight and can differ significantly from a 1,000-pound animal. The 

forage consumed by a steer or heifer weighing 600 pounds grazing for one 

month is counted as an AUM, as is the forage consumed by a 1000-pound cow 

with a calf. The BLM's definition of an AUM at 43 CFR 4100.0-5 does not 

identify the quantity of forage that constitutes an AUM nor does the regulation 

at 43 CFR

4130.8-1 providing for payment of grazing fees. 

The amount of permitted use is a mandatory term in grazing permits and 

leases. Permitted use will be modified when the authorized officer determines 

that such an adjustment is needed to manage, maintain, or improve rangeland 

productivity; to assist in restoring ecosystems to properly functioning

condition; or to otherwise meet land health standards or land use plan 

objectives. (See management actions common to all alternatives on page 2-

116.) The BLM manages grazing impacts at the allotment level using the data 

gathered

through monitoring, field observations, ecological site inventories, and land 

health assessments. Even though data for livestock weights or the amount of 

forage consumed per animal are not specifically gathered or identified, 

monitoring resource condition at the allotment level and, where necessary, 
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making changes in grazing management, would account for differences in 

livestock weights and forage consumption.

DRMTDK-BL13-0386-

22

Livestock 

grazing

As part of the Final EIS's explanation of the existing management situation, the 

Final EIS and RMP should provide an Allotment Management Summary 

detailing the conditions of each allotment within the planning area. This summary 

should include not only the number of AUMs permitted on each allotment, but 

also the actual use or "average use." Without data about actual use, the 

environmental assessment of livestock grazing impacts may be significantly 

distorted, especially on those allotments where less than the permitted AUMs 

are actually grazing on the land. Additionally, this section of the document 

should include the suspended nonuse AUMs, other forage allocations, specific 

resource concerns, and management objectives. The attached two page excerpt 

from the July 1999 Owyhee RMP and FEIS offers a great example of an 

Allotment Management Summary

n

A summary of the allotment information is available in appendix S. Of the 370 

allotments administered by the Billings Field Office 236 allotments (64%) are 

management category C or custodial management. On these allotments there 

is typically no suspended use and average or actual use is not collected on 

these allotments. There are 100 allotments (27%) categorized as M or maintain 

management. Occasionally these allotments have suspended AUMs, and only 

occasionally is the actual/average use tracked on these allotments. The 

remaining 34 allotment (9%) are category I or Improve allotments. On these 

allotments suspended AUMs are typically a result of past management actions, 

however documentation of this has been poor. Actual use is commonly tracked 

on these allotments. Due to the fact that only eleven allotments (3,835 acres) 

are failing rangeland health standards, and actual use data is collected on only 

a few allotments, the BLM did not include this data. While these data were not 

included in the DRMP, these data are reviewed and taken into consideration 

during the permitting process.

DRMTDK-BL13-0386-3

Livestock 

grazing

The correction of resource degradation caused by domestic livestock and the 

prevention of future degradation should be driving forces behind the RMP and 

should be reflected throughout the NEPA document and in any future agency 

decisions regarding domestic livestock grazing in the project area. Each 

alternative falls short of restoring degraded conditions and meeting the 

mandates described above. Specific livestock grazing levels that will be used to 

meet standards are lacking in all alternatives in the DEIS and must be included 

in the FEIS

n

The specific livestock levels used to meet standards are given in the 

alternatives-page 2-118. The degraded conditions suggested by the comment 

are not substantiated by data. Land health standards are being met, or 

significant progress is being made, on 97% of the acreage being administered 

for livestock grazing. (See table 3-16 on page 3-50.) Less than 2% of the acres 

are not meeting standards. As stated in the purpose of the RMP (pg. 1-4) “The 

purpose or goal of the land use plan is to provide a comprehensive framework 

for the BLM’s managers in accordance with FLPMA, and the principles of 

multiple use and sustained yield.” Based on the current statistics of land health 

within the field office (pg. 2-13) with only 11 allotments (3,835 acres) not 

meeting standards, specific levels of grazing throughout the field office are not 

needed. These standards are better applied through site specific NEPA 

analysis, and applied through grazing permit terms and conditions.

DRMTDK-BL13-0386-4

Livestock 

grazing

The DRMP fails to provide clear, quantitative terms and conditions to guarantee 

compliance with those guidelines. The DRMP explains that permit level range 

management will be consistent with the Standards for Rangeland Health and 

Guidelines for Livestock Grazing Management for Montana, North Dakota, and 

South Dakota,4 essentially leaving all decisions regarding the number of 

permitted on the landscape for the individual permitting process. While such 

guidelines articulate important goals, those goals will not be achieved without 

requiring that land managers meet quantitatively measurable terms and 

conditions. For example, Guideline #1 provides that "[g]razing will be managed 

in a manner that will maintain the proper balance between soils, water, and 

vegetation over time."5 In order to address effectively environmental impacts of 

n

By regulation, grazing use on public lands must meet, or make progress toward 

meeting, rangeland health standards. Permitted use, terms and conditions, and 

range improvements may all be modified when site specific conditions warrant 

such changes. Current rangeland health standard statistics (pg. 2-13) show that 

authorized grazing use within the Billings FO is achieving consistency with the 

Standards for Rangeland Health and Guidelines for Livestock Grazing 

Management for Montana, North Dakota, and South Dakota. Only 11 allotments 

(3,835 acres) are failing to meet standards for rangeland health, while 309 

allotments are meeting all standards and an additional 34 allotment are making 

significant progress toward meeting land health standards under the current 

1984 Land Use Plan. The record ( see table 3-16) shows that the BLM has 
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grazing, the DRMP must provide clear, quantitative terms and conditions to 

guarantee compliance with those guidelines

addressed the environmental impacts of grazing on the landscape. Where 

grazing impacts of grazing are causing degradation of public land, or conflicting 

with other multiple use objectives or goals, quantitatively measurable terms and 

conditions, as well as other terms and conditions are placed on the grazing 

authorization.

DRMTDK-BL13-0386-5

Livestock 

grazing

The Billings Field Office ("BiF0") has failed to take the required "hard look" at the 

impacts of domestic livestock grazing. The DEIS fails to scientifically and 

accurately determine those lands which are capable and suitable for livestock 

grazing. The BLM has further failed to accurately and quantitatively determine 

how much forage (i.e. forage capacity) is currently available. On top of this, the 

DRMP fails to properly allocate that forage to watershed and stream protection, 

wildlife habitat and food, then to livestock if available

n

The RMP identified lands (see pages 2-117 to 2-118 of the DRMP) available or 

not available for livestock grazing considering factors such as other uses for the 

land; terrain characteristics; soil, vegetation, and watershed characteristics; the 

presence of undesirable vegetation, including significant invasive weed 

infestations; and the presence of other resources that may require special 

management or protection including special status species, special recreation 

management areas (SRMAs), or ACECs. The forage capacity available for 

livestock grazing under the various alternatives is shown on page 2-118. The 

allocation of forage is proper because 97% of the acres being grazed are either 

meeting rangeland health standards or making significant progress toward 

meeting land health standards. (See appendix S.) Land health standard 

assessments consider the health of watersheds including riparian areas and 

uplands, as well as habitat for wildlife and plant populations.

The RMP took a “hard look” at the impacts of livestock grazing. The record 

shows that BLM adequately considered livestock grazing impacts in multiple 

sections of the RMP (See chapter 4.), including grazing impacts on greater 

sage-grouse habitat, riparian vegetation, and fish and wildlife, among others.

DRMTDK-BL13-0386-6

Livestock 

grazing

the DRMP fails to seriously consider the impacts of livestock grazing on the 

planning area, and instead promotes the idea of grazing as a method to improve 

land management. Citing the Grassland National Park Management Plan, the 

DRMP states, "[t]here is also agreement among many scientists and natural 

resource managers that some level of grazing disturbance is necessary to 

assure the ecological integrity of the mixed-grass prairie ecosystem." (Grassland 

National Park Management Plan 2001).13 The Canadian Grassland National 

Park document refers to historic bison grazing, when grazing animals moved 

across the landscape. These scientific conclusions do not apply to cattle, 

especially fenced cattle. Instead of relying on inapplicable historical 

characterizations of bison, the Final RMP and EIS should consider current peer 

reviewed science describing the environmental impacts of livestock grazing

n

Grazing is a well-accepted land management tool. On page 2-13 where the 

Grassland National Park Management Plan was cited, the context was to show 

that grazing disturbance is necessary to assure ecological integrity of the mixed 

grass prairie. This context does not elaborate as to the kind or class of 

livestock, but rather the act of grazing is needed. Further research (cited on pg. 

2-13) supports the claim that many of the Billings RMP planning area 

rangelands evolved with grazing and grazing is a keystone process for these 

systems. 

DRMTDK-BL13-0386-7

Livestock 

grazing

The HiLine DRMP, also released for comment this month, recognizes the 

potential for livestock to impact naturalness, stating: Livestock grazing has the 

potential to impact naturalness, the undeveloped character, and to create conflict 

with recreation users. Manipulation of vegetation, alteration of soils, and the 

presence of fecal matter would create unnatural conditions and would impact 

opportunities for solitude, particularly in areas where livestock congregate. 

n

Sections 4.2.14.5.3, 4.2.14.6.3, and 4.2.14.7.3 specifically discuss the impacts 

of livestock grazing and range improvements have on the naturalness of lands 

with wilderness characteristics. 

Appendix K discusses the lands with wilderness characteristics evaluation 

process for specific tracts. Livestock grazing and range improvements and their 
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Range facilities, such as fences, water troughs, and tanks have the potential to 

degrade wilderness characteristics by creating new developments, disturbing 

visual resources, and influencing wildlife migration, reproduction, and mortality 

(e.g., sage-grouse/fence collisions).20Livestock grazing in the BiFO planning 

area presents the same potential impacts [to naturalness as described in the 

HiLine DRMP], but the DRMP fails to acknowledge or address those impacts

effects on current conditions were evaluated as part of this process. 

Sections 4.3.5.4.13, 4.3.5.5.13, 4.3.5.6.13 and 4.3.5.7.14 specifically discuss 

impacts livestock grazing and range improvements have on recreational users.

DRMTDK-BL13-0386-8

Livestock 

grazing

The Billings DRMP acknowledges very few negative impacts of livestock 

grazing. In contrast, the HiLine DRMP acknowledges some of the many know 

negative environmental impacts of livestock grazing in riparian areas: 

Overgrazing can eliminate riparian vegetative cover, resulting in increased soil 

erosion and sedimentation. Increases in nonpoint source pollution, and loss of 

channel stability, can deteriorate water quality and diminish the ability of 

ecosystems to maintain healthy aquatic communities across localized and 

watershed scales.. . Strewn conditions and degraded water resources 

characterized by livestock overgrazing often include unstable and eroded banks, 

sedimentation, buried or embedded rock substrates, loss of riparian vegetative 

cover and associated organic matter inputs, increased width-to-depth ratio, 

reduced current in shallow water, nutrient enrichment, increased algae growth, 

reduced dissolved oxygen, higher temperatures, and reduced wildlife habitat 

structure.

n

In response to your comment, the text in section 4.2.6.3 (riparian and wetlands) 

of the Proposed RMP and Final EIS has been expanded to include the 

discussion of the negative impacts associated with livestock grazing in riparian 

areas.

DRMTDK-BL13-0386-9

Wildlife

Grazing also exerts great impact on animal populations, usually due to indirect 

effects on habitat structure and prey availability.36 Deleterious effects of grazing 

have been observed in all vertebrate classes. Response of native wildlife to 

grazing varies by habitat. Bock et al.37 reviewed the effect of grazing on 

Neotropical migratory land birds in three ecosystem types, and found an 

increasingly negative effect on abundances of bird species in grassland, riparian 

woodland, and Intermountain shrubsteppe (almost equal numbers of species 

with positive and negative responses to grazing in grassland; six times as many 

with negative as positive responses in shrubsteppe), but impacts to these 

species are lacking in the DEIS

n

Under Alternatives B & D Management Categories would be changed to “I” 

within sage steppe habitats in PHMA for sage grouse. These “I “category 

allotments would have a higher priority management level. Other sagebrush 

obligate species would also benefit from higher priority management of the 

sage steppe habitat. Also, all grazing permit renewals would have site specific 

NEPA analysis addressing migratory birds and other wildlife.

If livestock grazing is identified as a causal factor, and if standards for healthy 

rangelands are not met, changes in grazing management have to be 

implemented within 1 year.

DRMTDK-BL13-0390-1

Wildlife

ABC is in the process of finalizing Conservation Plan for the Long-billed Curlew 

that includes Best Management Practices drawn from studies throughout the 

species' range, many of them compiled by Cannings (1999), Dechant et al 

(1999), Fellows and Jones (2009). We urge you to consider incorporating the 

following BMPs into Appendix B, Wildlife Habitat and Special Status Species, 

pages B-24 through B- 26. We realize further that "BMPs would be implemented 

at the discretion of the Billings Field Office on a project-specific basis, depending 

on the specific characteristics of the project area and the types of disturbance 

being proposed", which is wording common to all Alternatives, page 2-8. Section 

IV -“ Best Management Practices (from: Conservation Strategies for the Longbilled Curlew: Focal Areas, Desired Habitat Conditions and Best Management 

n

Thank you for the comment. Long-billed curlews are considered Special Status 

Species through BLM I.M. MT-2009-039. BMPs would be considered in the 

project-specific NEPA analyses. A reference to the “Conservation Strategies 

for the Long-billed Curlew”, American Bird Conservancy, Sept. 2013, will be 

included in the BMP Appendix, Section B.4 , “Wildlife” and references.
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Practices (FINAL WORKING DRAFT). American Bird Conservancy, The Plains, 

VA, and Kalispell, MT.) The following set of recommended management actions 

and guidelines should be implemented wherever practicable within the breeding 

range of the Long-billed Curlew in North America. They are adapted primarily 

from Dechant et al (1999) and Cannings (1999). In every case, these guidelines 

will be most effective if implemented on landscapes already known to be 

inhabited by breeding curlews; ideally implementation should be accompanied 

by local surveys to verify important nesting or brood rearing areas. The timing of 

breeding, appropriate stocking rates, seed mixes and opportunities will vary 

regionally, as well as by site. We present these as overall guidance to land 

managers across the range of the species, but urge local partner cooperation 

and consultation during their implementation. This will help ensure that local 

expertise and other site management objectives are taken into account. Manage 

Grazing Appropriately ? Remove tall, dense residual vegetation before the prelaying period (graze in fall/winter). ? Adjust timing and intensity of grazing to 

leave grass cover 10-30 cm tall by 15 April. ? Retain 5% of grasses and forbs in 

taller condition (30-40 cm) for broods. ? Avoid grazing during the incubation and

nestling period (15 April -“ 15 July), to avoid potential for trampling. ? Do not 

drag hayfields to break up cowpies. We recommend using existing or future 

information regarding the known distribution of Long-billed Curlews to implement 

these grazing BMPs on those acres where grazing is allowed, under the 

selected alternative. Halt Habitat Conversion ? Prevent conversion of grassland 

or shrubsteppe, particularly within 1⁄4 mile of wetlands. ? Maintain or manage for 

grassland block sizes of >120 acres. ? Manage the forest fringe to 

minimize/reverse forest encroachment using slashing or other suitable method. 

We recommend using existing or future information regarding the known 

distribution of Long-billed Curlews to implement these BMPs under any selected 

alternative, particularly on any ac available for oil and gas leasing, or 

Renewables ROW designations. Known Long-billed Curlew breeding areas 

should be excluded from sites considered for wind energy developments. 

Emphasize Native Grasses and Forbs ? Burn areas only where and when fire 

intensity will reduce shrub coverage and increase habitat openness without 

reducing the diversity of native grass and forbs. ? Avoid seeding with nonnatives (e.g. crested wheatgrass). ? Use locally-appropriate native 

bunchgrass/forb seed mixes for restoration and revegetation efforts. ? Where 

necessary, manage taller non-native grass cover with grazing, mowing or fire to 

maintain low profile vegetation prior to the nesting season. We recommend 

using existing or future information regarding the known distribution of Longbilled Curlews to implement these BMPs under any selected alternative. Avoid 

Disturbance During Sensitive Periods ? Protect breeding habitat of curlews from 

detrimental human activities, such as vehicular use, researcher disturbance, and 
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shooting. ? Do not construct roads in occupied curlew habitat unless there is no 

other practicable option. Limit road use during the breeding season (March 15-

July 15). We recommend using existing or future information regarding the 

known distribution of Long-billed Curlews to implement these BMPs under any 

selected alternative, particularly on acres available for oil and gas leasing, or 

with Renewables ROW designations. Designation of areas open or closed to 

OHV use should consider Long-billed Curlew breeding habitat and timing. Adjust 

Certain Agricultural Practices ? Reduce pesticide use on grasslands, especially 

near water, to maintain both terrestrial and aquatic invertebrates as a food 

sources. ? Avoid widespread pesticide applications aimed at controlling 

grasshoppers. ? Reduce herbicide use to maintain nesting, loafing, and broodrearing cover. ? Whenever possible and practicable, favor flood-irrigation of hay 

meadows over sprinkler systems. References Cited: Brown, S., C. Hickey, B. 

Harrington, and R. Gill, eds. 2001. The U.S. Shorebird Conservation Plan, 2nd 

ed. Manomet Center for Conservation Sciences, Manomet, MA. Cannings, R.J. 

1999. Status of the Long-billed Curlew in British Columbia. Wildlife Working 

Report No. WR-96, British Columbia Ministry of Environment, Lands and Parks, 

Victoria. 14p. Dechant, J. A., M. L. Sondreal, D. H. Johnson, L. D. Igl, C. M. 

Goldade, P. A. Rabie, and B. R. Euliss. 1999 (revised 2002). Effects of 

management practices on grassland birds: Long-billed Curlew. Northern Prairie 

Wildlife Research Center, Jamestown, ND. 19 pages. Fellows, S.D., and S. L. 

Jones. 2009. Status assessment and conservation action plan for the Long-billed 

Curlew (Numenius americanus). U.S. Dept. of Interior, Fish and Wildlife Service, 

Biol. Tech. Publ, FWS/BTP-R6012-2009, Washington, D.C. 98p.

DRMTDK-BL13-0392-1

Wildlife 

2-69Wildlife Habitat Unoccupied raptor nests would be protected from removal 

or destruction for 7 years. MJRWS may affect a raptor nest. How will BLM know 

whether a raptor nest has been unoccupied for 7 years? It seems that any nest 

will need to be observed for 7 years once discovered before a tree could be cut 

or a power pole replaced. What does the science say about the longevity of a 

nest that is not maintained and what is the scientific basis for the 7-year 

timeframe?

n

Inventories and signs of nest activity would be conducted. Seven years was 

selected based on the period a known preferred prey species fluctuates from 

population highs to lows ( C. White BYU 1998 personal communication in 

Romin and Muck 2002). 

-from MSO consistency guidance

DRMTDK-BL13-0392-2

Wildlife 

2-72Big Game Winter Range Alternatives B and D - Over the snow vehicles 

would be prohibited in big game crucial winter range. MJRWS may require 

maintenance in the winter when access would include over snow vehicles. There 

is no justification for eliminating all over the snow use.

n

BLM-authorized Administrative access would be maintained. Refer to Appendix 

O, page O-2, 5th bullet down. 

DRMTDK-BL13-0395-1

Air

2) In the Executive Summary, ES 1.6.1.12.1 Mineral Resources: It is stated in 

the last paragraph that, "The BLM anticipates only limited development for 

locatable minerals, fluid minerals, coal and mineral materials during the life of 

the plan and, therefore, effects to the development of these resources from the 

alternatives are expected to be minimal." Minimal impact is a fairly bold 

prediction when watching the oil development work done in the area during the 

n

Thank you for your comment. GHG emission emissions from BLM-authorized 

activities are included in Chapter 4, Climate Change, alternative-specific 

emission inventories and Appendix Y.
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past two years and the future work scheduled that will be using applications of 

new technology. Although certainly we are not as large an area, that could have 

been said about the Bakken a few years ago. We are not sure that is an 

accurate assumption.

DRMTDK-BL13-0395-2

NEPA

3) Page 1-21, Section 1.5.1 County Plans, the Executive Summary does not 

include the Musselshell County Growth Policy adopted in 2003 and revised in 

2011. It also does not acknowledge the six county Comprehensive Economic 

Development Strategy (CEDS), which includes three of the counties in the RMP 

planning area. This plan was written in 2007, revised in 2012, signed by all six 

central Montana counties and over a dozen incorporated towns. It was officially 

accepted by US Economic Development Administration and signed off on by the 

Governor of Montana. Both plans speak to area development preferences and 

projects.

N

Thank your for your comment.

Please see Chapter 4 for the environmental consequences and Section 1.5 and 

Chapter 5 for discussions of inconsistencies between the Proposed RMP and 

county or local plans.

DRMTDK-BL13-0395-3

Water

4) Where did the information about 100 year floodplains come from? Map 8 in 

Volume IV shows a general map of the northern portion of the Billings District 

indicating flood mapped areas. Map 8 does not match our FEMA floodplain 

maps for the area. In fact much of the area may not have been officially mapped 

for floodplain. The 100 year floodplain is also referred to in table 2-5 of Volume I. 

Map No. 8 even indicates a range of frequency of flood events? Because of the 

small scale of the map, it is relatively hard to read and interpret. How are the 

terms Frequent, Occasional and Rare defined? What are those determinations 

based on? Do those interpretations have any bearing on the boundary levels of 

Sage Grouse Habitat?

n

Map 8 in Volume 4 was created by a BLM hydrologist using soil types and 

geomorphic character through GIS applications/analysis. It does not represent 

100 year floodplains per FEMA. It is more comprehensive. 

DRMTDK-BL13-0395-4

Edits

5) Table 2-6.1 and multiple other places in the RMP there is reference to 

"desirable nonnative plant and animal species. We believe there should be a 

definition of this reference, perhaps listing what those possible species would be. 

This should not be subject to interpretation in potential, future legal proceedings.

n

Thank you for your comment. A definition for desirable nonnative has been 

included in the glossary.

DRMTDK-BL13-0395-5

Coal

Table 2-8, Summary of Comparison Impacts: Alternative D on page 196 speaks 

of the impacts of a few jobs and limited federal revenue due to the mining of 2.8 

million tons of coal annually will likely continue. It seems that all revenues and 

jobs associated with area coal mining, because it likely occurs in addition to and 

partially because of the federal presence, should be included in this impacts 

analysis of this section, i.e. Signal Peak. It is significantly more that 2.8 million 

tons of coal annually and a "few jobs".

N

Thank you for your comment. The 2.8 million ton value is the estimated 

average federal coal that will be mined by Signal Peak Energy at the Bull 

Mountains Mine No. 1.

DRMTDK-BL13-0396-1

Air

1. In the Executive Summary, Air Quality Related Values should be briefly 

discussed along with air quality. 2. In Chapter 1 under the Consultation section, 

it should be mentioned that there was a technical workgroup formed to address 

air quality issues as discussed in the Memorandum of Understanding between 

USDA, USDI and USEPA regarding the Air Quality Analyses and Mitigation for 

Federal Oil and Gas Decisions through the NEPA Process (June 23, 2011) 3. 

Chapter 3 Affected Environment, Particulate Matter, (3.2.1.8) -- Add: Fine 

Y

1. See the "Executive Summary" section reference to “air resources,” which 

include AQRVs. 

2. See Section 1.6.2. 

 3. See Section 3.2.1.8. 

 4. As agreed by the AQTW, VISCREEN modeling was not performed for 

the planning area. 

5. As agreed by the AQTW, AQRV analysis for the planning area is 
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particulate also contributes to reduced visibility in nationally important areas 

such as national pars "and wilderness areas." 4. VISCREEN is addressed in the 

Appendix, but is not described in Chapter 4. The "Far-field AQRV Impacts" 

section be renamed to "AQRV Impacts" and should include the commitment to 

perform near-field analysis. 5. In the discussion of all the Chapter 4 alternatives, 

it states that future PGM modeling will be used. The statements should 

reference both limited AQRV analysis that will occur now and the PGM modeling 

analysis that will occur in the future to evaluate potential air impacts. 6. The FWS 

does not necessarily support the statement "Potential total nitrogen and sulfur 

deposition would likely remain below the levels of concern (3.0 kg/ha/yr and 5.0 

kg/ha/yr, respectively)". FWS needs to evaluate these level of concern numbers 

and potentially provide supportable deposition values. FLAG 2010 suggests that 

incremental emission increases from development should be evaluated using 

the DATs. 7. AQRV impacts are not assessed as a function of "new" versus 

"existing" air quality emission levels. Although referenced as a subjective 

analysis, FLAG guidance does not support such a determination. 8. 

Summary/averaging current visibility conditions at Class I areas is relevant to 

cumulative (regional haze rule) evaluation. Incremental analysis being 

conducted between draft and final EIS development will not consider this 

averaging. 9. The statements that the "Air Resource Management Plan and 

Adaptive Management Strategy" was "was prepared in collaboration" under the 

oil and gas MOU may not accurately reflect our understanding of what was 

discussed in the air quality technical workgroup. FWS was not fully aware of the 

intent to utilize an Adaptive Management Strategy and its associated methods in 

the future. The FWS Branch of Air Quality would like to request a meeting or 

conference call with BLM on a staff and management level to discuss this 

strategy and its associated agreements. 10. In the Glossary add the term "Air 

Quality Related Value", "Class I Areas," "Class II Areas" and "Sensitive Class II 

Areas." 11. In the Bibliography add the BLM. EPA, FS, FWS, and NPS Oil and 

Gas Air Quality MOU dated June 23, 2011.

deferred until PGM can be performed with appropriate data. 6. Until 

the FWS can provide data with specific levels of concern (LOC), the default 

LOC values in FLAG will be used. Future photochemical grid modeling will 

evaluate incremental and cumulative deposition impacts. 

7. Cumulative impacts including new and existing emissions will be modeled 

using photochemical grid modeling to assess air quality and AQRV impacts, as 

described in Appendix B, Section 5.1. 8. As agreed by the AQTW, 

AQRV analysis for the planning area is deferred until PGM can be performed 

with appropriate data. No AQRV modeling was performed between the draft 

and final EIS. 9. The language in Section 1.1 of Appendix T has been 

revised. 10. These terms are included the Glossary. 

11. The References section includes the June 23, 2011 MOU.

DRMTDK-BL13-0398-1

Locatable 

Minerals

Executive Summary. Section 1.6.1.12.1. and for all subsequent occurrences of 

these statements and conclusions in the RMP/EIS. We respectfully request that 

revisions to two paragraphs in this section be incorporated into the final 

RMP/EIS: Suggested revisions (in italics) for completeness and clarification: 

"With the exception of bentonite and chemical grade limestone, the development 

potential for other locatable minerals in the planning area is low. Large areas of 

commercially viable chemical grade limestone deposits in the planning area are 

located just northeast of Warren in southern Carbon County, occurring in the 

exposed upper Madison Limestone strata of the southwest flank of Big Pryor 

Mountain. Current and future bentonite and chemical grade limestone surface 

mining operations would not be affected under any of the alternatives because 

n

Thank you for your comment. Text in Chapter 1 has been edited to address 

your concerns. 
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the mining claims are valid, existing rights and the areas recommended for 

withdrawal do not coincide with areas having development potential." "The BLM 

anticipates only limited development for locatable minerals (except for moderate 

development for bentonite and chemical grade limestone), fluid minerals, coal, 

and mineral materials during the life of the plan and, therefore, effects to the 

development of these resources from the alternatives are expected to be 

minimal to moderate." Rationale: Based on the 50-plus year history of highcalcium limestone production from the Warren (Bighorn) Quarry now operated 

by Montana Limestone Company (MLC) in Carbon County, we believe this 

section and the conclusion statement should be amended to point out the 

significant viable locatable chemical grade limestone deposits in the 

southwestern Warren- Pryor Mountains area.

DRMTDK-BL13-0398-2

Locatable 

Minerals

4. RMP/EIS Chapter 3 - Affected Environment, Section 3.17.4.5 "Locatable 

Materials" We respectfully request that the following revisions be made to this 

section. Suggested revisions (in italics) for completeness and clarification: 

"There are currently two approved 3809 mine plans for bentonite. Development 

potential for additional bentonite, gypsum, uranium, and limestone exist in the 

decision area. Locatable minerals related mining activity consists of two active 

bentonite mines and one active chemical grade limestone quarry, located in 

Carbon County. Two mining companies have both patented and unpatented 

claims for bentonite located on the west and southwest flanks of the Pryor 

Mountains in southern Carbon County. One mining company has patented and 

unpatented claims for chemical grade limestone on the southwest flanks of the 

Pryor Mountains near Warren in Carbon County."

n

Thank you for your comment. Text in Chapter 3 has been edited to address 

your concerns. 

DRMTDK-BL13-0398-3

Social/econ

Section 3.32.2.1 Demographic and Economic Characteristics and Trends On 

Table 3-71, please include chemical limestone production under the "Major 

Population Center(s) and BLM Land/Mineral Uses" Column for Carbon County.

n

Thank you for your comment. MLC’s operations dobenefit Carobn County’s 

economy. However the table you reference has to do the amount of BLM 

federal minerals contributing to Carbon county’s economy. 

DRMTDK-BL13-0398-4

Locatable 

Minerals

Section 3.32.2.2.2 Mineral Development and Production "Federal mineral 

activities include oil and gas leasing and production, mineral materials (sand and 

gravel and decorative stone), and some unpatented bentonite claims. There may 

also be a federal coal lease sale in 2011. Mining of private minerals includes 

these same minerals as well as coal, sand and gravel, chemical limestone, and 

platinum group minerals."

n Thank you for your comment. The text in chapter 3 has been updated. 

DRMTDK-BL13-0403-1

NEPA

No Surface Occupancy (NSO). There is no public process spelled out that would 

allow the public to comment when exceptions are made to NSO stipulations. 

This needs to be corrected. If exceptions are made (waivers, exemptions and 

modifications) to NSO, the BLM needs to notify interested parties and allow for 

public comment, including an analysis under the National Environmental Policy 

Act. At a minimum, this public comment process and NEPA compliance should 

apply to the NSO provisions in sensitive areas for wildlife, including the Greater 

Sage-Grouse Protection Priority Area (PPA), Areas of Critical Environmental 

n

Thank you for your comment. The public has the opportunity to provide 

comments on NEPA documents as part of the regular NEPA process. . The 

subject of this comment is beyond the scope of the Billings/Pompeys Pillar 

National Monument RMP/EIS and does not require further agency response.
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Concern (ACECs) and critical habitat for other BLM Sensitive Species.

DRMTDK-BL13-0403-

10

Riparian,

Vegetation 

Invasive 

Species 

and 

Noxious 

Weeds

We ask that the BLM adopt Alternative B for its use of herbicides near wetlands 

and riparian areas. A 25 foot buffer (found in the other Alternatives), is not 

adequate; a 50 foot buffer is more appropriate.

n

Thank you for your comment. A 25 foot buffer has been determined safe for 

water quality conservation. Application conditions must be followed to ensure 

chemicals have adequate time to dry and attenuate, for example, a treatment 

may be delayed if the weather is rainy which could allow for chemical to be 

washed into the waterbody before drying/attenuation. 

Alternative B, found on page 2-64 analyzes land base (ATV, Truck mount 

spray equipment) application methods that would not be allowed within 1⁄4 mile 

(1320 feet) of fish-bearing water bodies during periods when fish are in life 

stages most sensitive to the herbicide(s) used. Alternative D (the preferred 

alternative) adheres to BLM policy and all BLM approved pesticide label 

specifications and restrictions, also part of bureau policy for the application of 

any herbicide. Additionally, Pesticide Use Proposals (PUPs) are prepared on a 

site specific basis at the project implementation level which is beyond the scope 

of this document.

DRMTDK-BL13-0403-

11

ACEC, 

NEPA

We also believe that ACEC status is appropriate for the proposed Carbon 

County PPA for the following reasons:??BLM Manual 1613, item .5 (Relationship 

of ACEC's to Other Designations), states that the "ACEC designation is the 

principal BLM designation for public lands "where special management is 

required to protect important natural, cultural, and scenic resources and to 

identify natural hazards."" BLM special management areas are supposed to be 

designated as ACECs. There is no official recognition of PPAs-”only 

ACECs.??BLM Manual 1613, item 53 C (Other BLM Designations and 

Management Areas/Special Management Areas Avoided), specifically states 

that the use of the terms "special area" or "special management area" are to be 

avoided. These terms are relative and have little useful meaning. This is required 

to avoid ambiguities and to provide an appropriate context to BLM designation of 

areas requiring special management attention, consistent with designation 

authority under the FLPMA and the planning regulations (43 CPR 1610.7)." Note 

that although PPAs do not specifically use the term "special area" or "special 

management area," the concept behind PPAs is exactly what Manual 1613 was 

trying to avoid: ambiguities.??BLM Manual 1613, item 64 (Conformance 

Determinations and NEPA Compliance), specifically states that - ̃[a]ll actions to 

be conducted or authorized by a BLM official must be in conformance with the 

provisions of the RMP as defined in 43 CPR l601.0-5(b). Whenever an ACEC 

may be affected by the implementation of an authorized or permitted activity, the 

decision instrument authorizing the specific action must include a description of 

the special management measures to be applied. An environmental analysis for 

a proposed action which might affect an ACEC must identify impacts, if any, on 

the ACEC and must incorporate by reference the pertinent portions of the EIS 

prepared for the RMP." Because of this provision, we believe ACEC status for 

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS. 

ACECs are proposed where special management attention is required 

to protect the important and relevant values in relationship to existing or 

proposed management in the BLM preferred alternative in the RMP. Should 

proposed management be present that protects the relevant and important 

values then ACEC designation is not necessary.

All PHMAs were considered and analyzed as an ACEC under Alternative B. 

See Appendix E for relevance and importance evaluation. 

Beyond the scope of this document. Much of this will occur at the 

implementation level. 
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the proposed Carbon County PPA will provide far greater protection for this area 

than a PPA designation, because specific permitted activates would be subject 

to an environmental analysis under NEPA, which should include public 

comment. This provision will prevent an excessive number of waivers, 

exemptions and modifications to NSO stipulations.

DRMTDK-BL13-0403-

12

Wildlife 

At a minimum, the BLM needs to use the Montana Fish, Wildlife & Parks (FWP) 

2010 sage-grouse - ̃core areas' as a basis for sage-grouse NSO management 

designations. These areas need to be NSO to the maximum extent practical.

n

Thank you for your comment. BLM did use FWP Core Area mapping for PHMA 

mapping. Refer to Map 168. Also, be aware that BLM can only consider public 

lands in the designated areas. In addition, BLM also designated Restoration 

Areas and GHMAs beyond the Core Areas. Your NSO protective measure 

suggestion will be considered when alternatives are selected in the Final RMP/ 

EIS.

DRMTDK-BL13-0403-

13

Wildlife 

In addition to the FWP core areas, we recommend specifically including the 

portions of Audubon's IBAs that are outside the core areas designated by FWP 

(see Figure 2 above). Because FWP and Audubon used the same data to 

establish critical areas, we suggest erring on the side of caution with a declining 

species and use both boundaries

n

Thank you for the comment. BLM can only manage habitat on public lands. 

Core area acreage outside of the PHMA designations were excluded either 

because of land ownership or previous habitat disturbance.

DRMTDK-BL13-0403-

14

Wildlife 

As we learn more about sage-grouse, we are finding out that Montana birds 

migrate seasonally. Any identified winter range should be protected with timing 

restrictions AND buffers (preferably a 4 mile buffer).

n

Table 2-6.1, , Alternative B, includes the following: “Surface use for oil and gas 

exploration (including geophysical operations) would be prohibited from 

December 1 to March 1 within greater sage-grouse winter range or within 4 

miles of a sage-grouse lek (TL). The following special operating constraints 

apply in greater sage-grouse winter range: surface occupancy and surface 

disturbance density and / or mitigation plan (CSU) within greater sage-grouse 

winter range. Your comment will be considered in the Final RMP Decision. 

DRMTDK-BL13-0403-

15

NEPA

We support the addition of a provision (common to all the Alternatives, including 

the Preferred Alternative) from the HiLine DRMP/DEIS that stated, "[w]here 

leases or rights-of-way have some level of development (e.g., road, fence, well, 

etc.) that are no longer in use, the site would be reclaimed by removing the 

features and restoring the habitat. Upon project completion or right-of-way 

expiration, roads built and maintained for commercial use across BLM land 

would be reclaimed, unless based on site-specific analysis, the route provides 

specific benefits to the public and the continued public use does not contribute to 

resource conflicts."

N Thank you for your comment. 

DRMTDK-BL13-0403-

16

Livestock 

grazing

Because all BLM Alternatives maintain the current level of livestock grazing, this 

not an adequate range of alternatives. As an example, Table 4.6 (p. 4-9) shows 

no range of differences in "rangeland improvements" between the alternatives.

n

Please see section 2.4.1 of the DRMP for a detailed discussion as to why a no 

grazing alternative was considered but not analyzed in detail, as well as the 

rationale for the level of grazing analyzed in each alternative.

Additionally, Table 4.6 of the DRMP is a table of surface disturbance 

assumptions based on historic disturbance levels in relation to proposed 

management changes by alternative. Since no alternative specifically reduces 

or increases the expected level of range improvements, no change is 

documented.
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DRMTDK-BL13-0403-

17

Livestock 

grazing

The BLM should explicitly outline within the Final RMP/EIS the number of 

grazing allotments within PPAs, the number of those allotments that do not meet 

specified BLM rangeland standards, the number of allotments with degraded 

riparian or wetlands areas, and information on how these conditions will be 

improved.

n

These data are presented in appendix S, but not summarized. 105 Allotments 

are located or contain some public land within PHMA, four of these allotments 

are failing one or more standards, 85 of these allotments are meeting all 

standards, five allotments have not been assessed, and 11 allotments are 

making significant progress towards meeting standards. On the 15 allotments 

failing or making significant progress towards meeting standards the riparian 

standards was listed on two allotments. Changes are implemented on a site 

specific basis to address resource issues. Common practices to address 

riparian issues include a season of use change, reduced duration, or exclusion 

from livestock grazing.

DRMTDK-BL13-0403-

18

Livestock 

grazing

We support the addition of a provision (common to all the Alternatives, including 

the Preferred Alternative) from the HiLine DRMP/DEIS that placed a high priority 

on monitoring all grazing allotments within PPAs. We also support the 

commitment to reassessing allotments within PPAs that are either canceled or 

relinquished to determine if they should be closed to grazing altogether. In order 

to ensure that this provision is meaningful (and not just words on paper), the 

BLM should annually report how many allotments are canceled or relinquished 

within PPAs, and how many are then retired. This report could be placed on the 

website for the Billings/Pompeys Pillar planning area.

n

Thank you for your comment. In the table of alternatives (Table 2.6.2 - DRMP) 

Alternatives B and D propose to designate all allotments within PHMA as a 

management category I or improve grazing allotment. These allotments 

receive the most vegetation monitoring and compliance inspections. 

Additionally, under management common to all alternatives (Pg. 2-116) it is 

stated that if grazing preference on an allotment wholly located within PHMA is 

voluntarily relinquished, the BLM may consider the retirement of the allotment. 

When the BLM is considering whether or not to retire the allotment, sage 

grouse habitat requirements in relation to current livestock use levels would be 

evaluated.

DRMTDK-BL13-0403-

19

NEPA, 

We support the addition of a provision (common to all the Alternatives, including 

the Preferred Alternative) from the HiLine DRMP/DEIS that limits wells to 1 well 

per square Page 10 -“ Montana Audubon Comments on Billings/Pompeys Pillar 

BLM Resource Management Plan mile. In addition to this provision, we request 

that scientifically-based buffers be established, with other appropriate protective 

provisions

n

Thank you for your comment. The RFD for the B&PPNM plan revision is 4 

wells per year occurring on BLM managed federal mineral estate per year. 

There are no high potential oil and gas development areas occurring in the 

federal mineral estate. Full-scale would be four wells per year. 

DRMTDK-BL13-0403-

20

NEPA

Any time the BLM authorizes changes to the NSO or Controlled Surface Use 

(CSU) stipulations in areas less than 4 miles from a lek, the public should have a 

chance to comment on the proposal and a site-specific NEPA analysis should be 

conducted. In addition, the BLM should issue an annual summary of all NSO and 

CSU stipulations authorized that are within less than 4 miles of a lek.

N

Thank you for your comment. That is currently what the BLM is doing through 

this land use plan revision. 

DRMTDK-BL13-0403-

21

Wildlife 

In all sage-grouse areas where buffers are used, energy development should be 

prevented-”to the maximum extent possible-”within 4 miles of active leks. 

Colorado (Colorado Steering Committee 2008) and Wyoming (Governor's 

Executive Order 2008) have adopted a 4-mile buffer to protect sage-grouse 

breeding habitat. These buffers were based on regional radio-telemetry data that 

indicated 80% of nesting occurred within 4 miles of leks. Thus, 20% of the 

nesting population in these regions may be compromised.

n

Thank you for the comment. Your 4 mile protective measure suggestion will be 

considered when alternatives are selected in the Final RMP/ EIS.

DRMTDK-BL13-0403-

Wildlife

that produce substantial noise, such as compressor stations, should not be 

allowed near active sage-grouse leks. The BLM should develop a scientificallydefensible provision that has a buffer around industrial sources of noise. For n

Refer to Appendix AA (section F) refers to BMPs for noise from Fluid Mineral 

development.
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22 example, all pump stations should be located at least 2 miles from the nearest 

active lek, but preferably more than 4 miles (Naugle et al. 2011). In addition to a 

buffer, noise should be prohibited between 1 hour before sunset to 1 hour after 

sunrise between March 1 and May 15 near leks, unless the activity is specific to 

inventorying, monitoring, or viewing greater sage-grouse.

DRMTDK-BL13-0403-

23

Wildlife

Roads, Pipelines, Communication Towers, and Power (and Transmission) Lines: 

Development and its associated infrastructure fragment sage-grouse habitat. 

Habitat fragmentation is believed to be a primary cause of sage-grouse decline 

and in some areas has already led to population extirpation. Because of this 

threat: The BLM should NOT authorize new roads, pipelines, communication 

towers, power or transmission lines, and other permanent structures on sagegrouse winter occurrence points, winter concentration areas, and-”preferably-

”within 4 miles of active leks. At a MINIMUM, permanent structures should be 

located at least 2 miles from active leks (although, as stated above, a 4 mile 

distance is preferred). In addition, a scientifically defensible buffer should be 

established for winter occurrence points and winter concentration areas. Any 

time the BLM changes NSO stipulations or authorizes CSU for a project in areas 

less than 4 miles from active leks, the public should have a chance to comment 

on the proposal and a site-specific NEPA analysis should be conducted. We 

support the DRMP/DEIS provision that roads, pipelines, and other infrastructure 

should follow existing Rights-of-Way as much as possible. Clustering this 

infrastructure will fragment less habitat. The BLM should consider adopting 

stipulations that allow no more than a 3% surface disturbance cap per section in 

PPAs (Knick et al. 2013), with no more than 5% surface disturbance cap per 

section in general sage-grouse habitat. It should also be noted that these 

surface disturbance provision cap levels should be changed if new scientific 

information indicates that it is not adequate. In addition, compensation should be 

required with a 1:1 Habitat Compensation Ratio. Requiring compensatory 

mitigation will better ensure that CSU stipulations provide better protection for 

sage-grouse.

n

Thank you for the comment. According to Alternatives in Chapter 2, Table 2-

6.1 the options you presented are available for decision in the Final RMP. Your 

comments will be considered in the Final RMP.

A process is described in Appendix D.2.6. “Substantial modification or waiver 

is subsequent to lease issuance is subject to public review for at least a 30-day 

period.”

DRMTDK-BL13-0403-

24

Renewable 

Energy

Excluding commercial wind from the PPA would be consistent with the U.S. Fish 

and Wildlife Service (USFWS) recommendation to "... avoiding placing wind 

turbines within 5 miles [8 km] of known leks (USFWS, 2004)." In fact, this 

standard should be added in the Preferred Alternative for any identified lek on 

BLM land within the planning area. In addition, buffers around wintering areas for 

wind turbines in those areas outside of PPHs should be established.

n

The cited 2004 USFWS briefing paper was prepared in regard to studies 

conducted on the greater prairie chicken. Connelly et al. (2000) recommends a 

two mile buffer for sage-grouse. Rather than buffers, the preferred alternative 

designates sage grouse PHMAs and winter range as avoidance areas, 

regardless of the distance from an occupied lek. Designated avoidance areas 

are not managed as open, but would require substantial commitment on the 

part of the proponent and site-specific study before any renewable energy 

applications would be considered.

Given potential future advances in renewable energy technologies, coupled 

with ongoing research related to impacts of renewable energy development on 
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sage-grouse, total exclusion of renewable energy given the long-term nature of 

this plan is not warranted. 

DRMTDK-BL13-0403-

25

ACEC

The Pryor Foothills ACEC should be expanded, as proposed by the Montana 

Native Plant Society (MNPS), to include sections 30 and 31. This expansion is 

needed to help protect important and rare plant communities.

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS. Please refer to 

Appendix E. Areas Of Critical Environmental Concern in the Draft RMP/EIS for 

a discussion of ACEC Nominations for East Pryor ACEC (BLM nomination), 

Pryor Foothills Research Natural Area/ACEC (public nomination), and Sykes 

Ridge Rare Plant ACEC (nomination by Peter Lesica). 

Please see the 1998 ACEC Assessment and Proposed amendment to the 

Billings, Powder River and South Dakota RMPs here:

http://www.blm.gov/style/medialib/blm/mt/blm_programs/

planning/billings_rmp/amendments.Par.94086.File.dat/acecEA.pdf

pages 74-76 are the nominations evaluations for the Billings RMP and page 

103 shows the map of the nominated vs. recommended ACEC.

DRMTDK-BL13-0403-

26

ACEC, 

WSA

The land within the East Pryor ACEC should not be removed from Wilderness 

Study Areas (WSA) designation. WSA designation alone does not provide 

adequate protection of this area. WSAs and ACECs are established for very 

different reasons and managed with different objectives. As described above in 

our comments, Priority Protection Areas/Priority Areas versus ACEC Status, 

there is no reason to eliminate the overlapping designations. These compatible 

"overlapping designations" serve an important purpose of identifying and 

protecting multiple resource values.

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revision. Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS

ACECs are proposed where special management attention is required 

to protect the important and relevant values in relationship to management in 

the BLM preferred alternative in the RMP. Should existing management be 

present (like a WSA) that protects the relevant and important values then ACEC 

designation is not necessary. Language is included in the RMP that should 

congress (ever) make a decision on wilderness in the Pryors, and this area not 

be designated wilderness, then it would be managed as an ACEC.

As WSAs contain the most restrictive management, there is no need for an 

ACEC to overlap the WSA. The relevant and important values of the East 

Pryor ACEC are addressed through the management of the WSAs. 

Your comments have been recorded as per NEPA regulations and they have 

been considered by the Billings Field Office and Montana State Office and 

documented in the administrative record associated with the B&PPNM 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

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RMP/EIS. Thank you for your comments.

In regards to the overlapping designations of ACEC/Wild Horse Range/WSAs, 

the actual management prescriptions (No Oil and Gas development, etc.) are 

intended to be in place regardless of the land’s designation.

Please see table 2.63; Page 2-168 for WSA management prescriptions and 

page 2-147 for management prescriptions in the East Pryor ACEC, as well as 

page 2-171 for management prescriptions in the PMWHR.

DRMTDK-BL13-0403-

27

Travel mngt

The HiLine DRMP/DEIS restricted OHVs to two areas Page 12 -“ Montana 

Audubon Comments on Billings/Pompeys Pillar BLM Resource Management 

Plan totaling 124 acres. We support a similar limit in the Billings/Pompeys Pillar 

Final RMP/EIS as long as the location for these areas 1) do not contain wetlands 

or riparian areas, 2) do not contain quality grasslands or sagebrush habitats, 3) 

adequately protected wetlands, riparian areas, grasslands, and sagebrush 

habitats from intrusion by OHVs (through buffers, fencing, etc.), and 3) are not in 

an area sensitive to wildlife.

n

Thank you for your concern and comments. The RMP decision has only one 

designated area for cross-country OHV use, the South Hills OHV Area (1,371 

acres). Rationale for this decision is found in the RMP. For the reminder of the 

FO lands, travel is limited to either existing or designated routes. Consideration 

for route designation was given to resource protection by the Interdisciplinary 

Team. (see Appendix O and individual Route Inventory forms) 

DRMTDK-BL13-0403-

28

Renewable 

energy

development should be excluded from the Greater Sage-Grouse PPA, crucial 

sage-grouse wintering areas, ACECs, and large reservoir waterfowl complexes. 

Although the DRMP/EIS exclude wind development from specific acres, we are 

unclear if the BLM recommends an exclusion for the above-listed areas. This 

request for an exclusion is supported by the U.S. Fish and Wildlife Service 

(USFWS) recommendation of "... avoiding placing wind turbines within 5 miles [8 

km] of known leks (USFWS, 2004)." In addition we would support adding an 

exclusion provision in the Preferred Alternative for the above-referenced areas 

for commercial solar development.

n

Pages 2-135 through 2-137of the Draft RMP clearly outline the specific areas 

and resources that lie within the renewable energy exclusion (78,088 acres) 

and avoidance (331,088 acres) areas in the preferred alternative. These 

allocations apply to both wind and solar development. Greater Sage-Grouse 

PHMAs, Sage-Grouse Winter Range, and riparian areas and wetlands (which 

would cover large reservoir waterfowl complexes) lie within avoidance areas, 

where development could not occur unless special stipulations and 

conservation measures would adequately conserve the habitat of concern. 

Given potential future advances in renewable energy technologies, coupled 

with ongoing research related to impacts of renewable energy development on 

sage-grouse, total exclusion of renewable energy over the long-term is not 

warranted. Please note that avoidance areas are not managed as open, but 

would require substantial commitment on the part of the proponent and sitespecific study before applications would be considered.

DRMTDK-BL13-0403-

29

Wildlife 

Regarding black-tailed and whitetailed prairie dogs, there needs to be a 

scientifically-based buffer established that will ensure that prairie dogs expand 

their occupation of BLM land. These species have been declining in Montana. If 

surface disturbing activities are allowed within the scientifically-established 

buffer, then the public should have a chance to comment on the proposal and a 

site-specific NEPA analysis should be conducted.

n

Thank you for your comment. Prairie dog habitat is defined as, “the maximum 

extent of areas occupied by prairie dogs at any time during the last 10 years.”-

source MSO- consistency

DRMTDK-BL13-0403-3

Wildlife 

Montana has a total of 40 Important Bird Areas, four of which are located 

partially or wholly within the Billings/Pompeys Pillar planning area boundary: the 

Musselshell Sate-Steppe IBA; Half breed National Wildlife Refuge and IBA; 

Bridger Sage-Steppe IBA; and Bear Canyon IBA. Management decisions and 

direction in the Final RMP/EIS should take into account the location of IBAs, 

n

Thank you for the comment. 

Important Bird Areas (IBAs) are area designated by the National Audubon 

Society. IBAs are sites that provide essential habitat for one or more species of 

bird. IBAs include sites for breeding, wintering, and/or migrating birds. There 
Billings and Pompeys Pillar National Monument

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applying appropriate protections to ensure the continued conservation value of 

these critical habitats. This is especially important given the range-wide 

population declines documented for birds that breed within grassland and 

sagebrush-steppe habitats, likely due to widespread habitat loss and alteration 

(Rich et al. 2004).Specific information and a map on the IBAs within the HiLine 

District planning area appear below:

are four IBAs within the Billings Field Office Planning Area, three have public 

lands managed by BLM.. Discussion of the IBAs is referenced on pages 3-86 

and 3-99. One of the IBAs was nominated due to the presence of breeding 

populations of more than a dozen species on the Montana Priority Bird Species 

List. The foothill canyons in the area have the only known breeding location of 

blue-gray gnatcatchers in Montana (Audubon.org).

Two of the IBAs nominated were identified to accentuate the management of 

these areas for the conservation of sage grouse and other sagebrush obligate 

species. Refer to: http://www.mtaudubon.org/birds/sageiba.html.

Since Important Bird Areas are not a BLM designation, maps will not be

included in the EIS. BLM protections that will protect the two sage grouse IBAs 

can be found in Chapter 2, Greater Sage-Grouse PHMA, RA, and General 

habitat, and Appendix C, and Appendix AA, AB. Executive Order 13186-

Migratory Birds- is cited on page 2-68. The two IBAs are mostly within PHMAs

Halfbreed NWR IBA – Managed by the USFWS and BLM has no management 

authority.

DRMTDK-BL13-0403-

30

Wildlife 

Increase Areas Protected for Sprague's Pipet. Other than minimal timing 

restrictions on development activities, we are concerned that there are no 

special protection or management provisions for Sprague's Pipits, a BLM 

Sensitive Species and US Fish &Wildlife Service Candidate Species. There 

appears to be significant Sprague's Pipit habitat in the northern part of the 

Billings/Pompeys Pillar planning area (see map below). More Sprague's Pipit 

habitat should be given a higher level of protection. This could be accomplished 

by expanding the Greater Sage-Grouse PPA to the west to include protection for 

this grassland bird and adding specific provisions to protect these birds into the 

Final RMP/EIS. As a BLM Sensitive Species and a Candidate Species under an 

Endangered Species Act, with a higher priority than Greater Sage-Grouse, we 

urge the BLM to protect more of this grassland bird's habitat in Wheatland and 

Golden Valley Counties. Page 13 -“ Montana Audubon Comments on 

Billings/Pompeys Pillar BLM Resource Management Plan

n

Thank you for the comment. Refer to Table 2-6.1, “Surface-disturbing and 

disruptive activities would be avoided from April 15 through July 15 in 

Sprague’s pipit habitat. Surface use for oil and gas exploration, (including 

geophysical exploration) is prohibited from April 15 through July 15 in 

Sprague’s pipit habitat. (TL)

Sprague’s pipit habitat is defined as “Optimal or Moderately Suitable” habitat 

classes in MTNHP Maxent Inductive Model of Sprague’s pipit breeding habitat ( 

Map 25) 

Note: There is a very small percentage of public land in Golden Valley and 

Wheatland counties. BLM can only manage habitat on public lands. 

Also, Sprague’s pipit needs to be added to Tables 2-5 and 2-6.2.

DRMTDK-BL13-0403-

31

Wildlife

Eagles._ Golden Eagles should have a longer timing stipulation, with a 

prohibition undisruptive activities from January 1 to August 15 (Draft Montana 

Golden Eagle Management Guidelines 2012). (e.g., p. 2-73)._ The Preferred 

Alternative for Bald Eagle and Golden Eagle Nests and Habitat stipulations 

found on page 2-76 needs to be change: at a minimum, it needs to place this 

stipulation on nests active within the preceding 7 breeding seasons(and not 5 

years, as stated). Seven years is used throughout the plan except in this one 

location for all other raptors. In addition, the Draft Montana Golden Eagle 

Management Guidelines (2012) recommends that nests used in the preceding 

y

Thank you for the comment. Revisions are being made in the Final RMP/EIS 

such as the following: Surface occupancy and use is prohibited within 1⁄4 mile of 

raptor nest sites active within the preceding 7 years. (NSO)

Surface use is prohibited within 1⁄2 mile of active raptor nest sites from March 1 

through July 31. (TL) –source MSO- Consistency

The golden eagle nests active in the preceding 10-years was decreased to 

seven years to be consistent with other raptors. 
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Proposed Resource Management Plan and Final Environmental Impact Statement

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10-years be the standard.

DRMTDK-BL13-0403-

32

Climate

However, the Billings/Pompeys Pillar DRMP/DEIS fails to provide any specific 

description of how climate change will be addressed. We could not find the 

BLM's Rapid Ecological Assessment (REA) program even discussed in the 

DRMP/DEIS. The Northwestern Plains REA, which encompasses this planning 

area, was initiated in Sept 2010 and was supposed to be completed in early 

2013. We ask that the BLM provide greater clarity as to how this REA will be 

incorporated into the Final RMP/EIS

N

Status of the Northwestern Plains REA can be found at 

http://www.blm.gov/wo/st/en/prog/more/Landscape_Approach/reas/nwplains.ht

ml. The final RMP will be completed before the Northwestern Plains REA is 

complete.

DRMTDK-BL13-0403-

33

Wildlife

the BLM should examine the following additional resources concerning climate 

change:??The National Wildlife Federation recently released a report, Shifting 

Skies: Migratory Birds in a Warming World (available at: 

http://www.nwf.org/News-and-Magazines/MediaCenter/Reports/Archive/2013/06-18-13-Migratory-Birds-in-a-WarmingWorld.aspx).??Audubon's 2009 birds and climate report (available at: 

http://birdsandclimate.audubon.org/).This report documents how 177 of 305 

North American migratory bird species have already shifted their winter 

destinations to the north by an average of 35 miles over the past 40 years. Page 

16 -“ Montana Audubon Comments on Billings/Pompeys Pillar BLM Resource 

Management Plan

n

Thank you for the comment. The updated information will be considered in the 

Final RMP/EIS.

DRMTDK-BL13-0403-

34

NEPA Please contact Gary Langham (Chief Scientist, 202- 600-7975, 

glangham@audubon.org) to discuss use of Audubon's climate predictions n Thank you for your comment. 

DRMTDK-BL13-0403-4

Wildlife

Audubon's IBAs are slightly different in size than the sage-grouse core areas 

established in 2010 by FWP. Because both efforts relied on the same initial 

approach to determining core areas, we suggest erring on the side of caution 

and considering both boundaries when determining the boundary of the BLM's 

Billings/Pompeys Pillar Sage-Grouse Protection Priority Areas (PPA), avoiding 

development and disturbance within either the FWP identified core area or the 

Montana Audubon classified Important Bird Areas (see Figure 2 below). 

Combining these two boundaries would specifically add acreage to both of the 

BLM's proposed PPAs.

n

Thank you for the comment. BLM can only manage habitat on public lands. 

Core area acreage outside of the PHMA designations were excluded either 

because of land ownership or previous habitat disturbance.

DRMTDK-BL13-0403-5

Riparian/ 

wetlands

For riparian and wetland areas, the DRMP/DEIS does not describe the 

environmental consequences on wetland and riparian vegetation from the 

alternatives. We would expect this under the Vegetation section, but it is absent. 

This should be corrected in the Final RMP/EIS.

n

Pages 4-157 through 4-182 describes impacts to riparian and wetland areas 

from the alternatives. 

DRMTDK-BL13-0403-6

Riparian/ 

wetlands

We are concerned that under the current RMP, 52% (75.5 miles) of riparian 

areas are classified as "Streams Functioning at Risk" or "Streams 

Nonfunctioning" (see Table 3-17).Although the DRMP/DEIS identifies the 

general reasons for stream degradation (invasive and non-native vegetation 

infestations, bank alteration from livestock grazing, channel instability, and lack 

n

Thank you for your suggestion. Riparian management is a priority in the BiFO. 

When possible, management changes are being made to improve riparian 

areas that are Functioning at Risk or Non-Functioning, and to maintain riparian 

areas that are Properly Functioning.
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of riparian obligate recruitment and riparian vigor), it does not describe the 

causes of degradation in any detail. Because of the sensitivity of this habitat, we 

would request that BLM staff categorize the main causes for riparian degradation 

by percentage and/or miles, and describe how the agency plans to address the 

root causes of this degradation.

Causes and issues are identified during scoping of new projects, particularly 

livestock grazing permit renewals. A database is being developed that will 

satisfy your request, however it will not be finished before the RMP. 

DRMTDK-BL13-0403-7

Riparian/ 

wetlands

The miles found in Table 3-17 for riparian areas do not match the miles found in 

Table 2-1, which is confusing. Alternative B in Table 2-1 indicates that 189 miles 

of riparian area would be designated a "high priority recovery area," yet Table 3-

17 indicates that there are only 75.5 miles of stream that are "Streams 

Functioning at Risk" or "Streams Nonfunctioning. " We are unclear what the 

difference numbers mean.

n

Thank you for catching this error. The numbers will be re-calculated and 

corrected in respective chapters/tables/analysis. 

Table 2-1 should indicate the number of miles by alternative, of “Priority 

Riparian Habitat” which in alternative B is 78, C is 13 and D is 51. It will be 

corrected. 

The difference between table 2-1 and table 3-17, is that specific types of 

riparian areas are identified by alternative in 2-1, while all known riparian areas 

are identified in 3-17. The number in 3-17 will be higher than any numbers in 2-

1.

The alternative tabke has been changed to address your comment.

Alternative B:

Priority Riparian Habitats would include riparian areas associated with 

Perennial streams, fish bearing streams, cottonwood galleries and riparian 

areas within sage grouse PHMAs.

Alternative C:

Priority Riparian Habitats would include riparian areas associated with YCT 

populations and suitable recovery habitat, Blue and Red Ribbon streams and 

Cottonwood Galleries.

Alternative D:

Priority Riparian Habitats would include riparian areas associated with perennial 

streams and cottonwood galleries.

DRMTDK-BL13-0403-8

Riparian

All wetlands and riparian areas should be designed NSO areas-”with no 

exception for waivers, exemptions and modifications-”for all development 

activities, unless roads and bridge abutments are required at river or stream 

crossings. In addition, buffers need to be established that adequately protect fish 

and wildlife/aquatics (i.e., all wetland and riparian areas). Examples of adequate 

buffers can be found in numerous publications, including Ellis, 2008.

N Thank you for your comment. 

DRMTDK-BL13-0403-9

Water 

Floodplains should be a NSO area-”with no ability to grant waivers, exemptions 

and modifications-”for all development activities. It appears that Alternative B 

contains this provision, but Alternative D does NOT. Instead, Alternative D only 

y

Thank you for your comment. A new text has been added to chapter 2 to 

address your comment and a new stipulation has been included in Appendix C. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

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has this provision apply to "designated" 100-year floodplains. Because floodplain 

delineation (i.e., designation) has NOT occurred in most (if not all) of the 

planning area, this stipulation provides virtually no protection to these sensitive 

areas. We specifically ask that the BLM require that all floodplains be protected 

from development. In those areas where floodplain delineation has not taken 

place, the developer would have to delineate the floodplain on a case-by-case 

basis. This information should be required-”and these areas should then be 

added to the state's floodplain maps.

DRMTDK-BL13-0404-1

Travel mngt

For all wilderness quality lands identified in the Draft RMP, please:- Close the 

areas to new road construction, powerline or pipeline rights-of-way, mining, oil 

and gas leasing, motorized recreation, and new facility construction unless 

related to protection of their wilderness character. Also, please:- Reconsider the 

motorized trail network in the Pryor Mountains and identify opportunities for at 

least one quiet, designated non-motorized route. For example, closing the 

Demijohn Flat route to motorized use would provide a quiet trail while also 

helping to protect sensitive cultural resources .- Close the two-track trail into 

Bear Canyon to motorized use beyond the canyon mouth because two parallel 

motorized routes provide motorized access into this part of the Pryors.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed”

Also note that BLM Manual 1626 (Travel and Transportation) specifies that 

BLM establish a comprehensive program for both motorized and non-motorized 

travel. This will be done in this RMP.

Please see the end of Table 2.6.1 for Lands with Wilderness Characteristics, 

management prescriptions, and then refer to other sections in the table for the 

specific areas/units not found to possess wilderness characteristics and their 

management prescriptions – many have the same regardless of designation

Thank you for your comments.

In regards to your comment, 

While statements of opinion (including agreement or opposition) do not require 

specific responses or text revisions under NEPA regulations, they have been 

considered by the Billings Field Office and Montana State Office and 

documented in the administrative record associated with the Billings and 

Pompeys Pillar National Monument RMP/EIS

Specifically note that the following changes have been made to the document:

• There is a designated non-motorized trail component of the Travel and 

Transportation System. It can be found in Appendix O

• This non-motorized trail system includes a trail in Bear Canyon, as requested 

by numerous commenters. 

• Sage Grouse PHMAs are designated as NSO. 

• Lands which have passed lands with wilderness characteristics inventory are 
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not necessarily managed for lands with wilderness characteristics values, (Bad 

Canyon, Weatherman Draw, Bear Canyon) but none of the areas are open for 

OHV use unless for administrative purposes 

• Other management restrictions are also in place through different resource 

programs and are identified in the RMP. 

DRMTDK-BL13-0404-2

Wildlife

- Close all Sage Grouse Priority Protection Areas to oil and gas leasing, or 

stipulate the areas for "No Surface Occupancy" with no exceptions, waivers or 

modifications.

n

Thank you for the comment. Your comment will be considered when 

alternatives are selected in the Final RMP/ EIS. The No Lease and NSO 

alternatives are included in the analysis and alternatives.

DRMTDK-BL13-0405-1National 

Historic 

Trails

Executive Summary, ES 181.6.1.18.3 The environmental consequences of 

implementing the agency preferred Alternative D is not included in this summary 

paragraph on National Historic Trails (NHTs) and should be added. Chapter 4 

Environmental Consequences, 4-6204.6.8.1 Same comment as above

n

Thank you very much for comment. The RMP text has been altered to reflect 

your comment and concerns

DRMTDK-BL13-0405-2National 

Historic 

Trails

Chapter 4 Environmental Consequences, 4-5814.4.6 The map that illustrates the 

Lewis and Clark and Nez Perce NHTs is number 166, not 175 n

Thank you very much. The Alternative D discussion has been added to the 

RMP text.

DRMTDK-BL13-0405-3National 

Historic 

Trails

Chapter 4 Environmental Consequences, 4-5854.4.6.3.5 This paragraph 

describes potential impacts to NHTs from recreation that are common to all 

alternatives. The discussion of NHT routes should include water trail 

designations as this is the recommended type of trail development for the Lewis 

and Clark NHT segment from Buffalo Mirage Access site near Park City to the 

mouth of the Yellowstone River (Lewis and Clark National Historic Trail 

Comprehensive Plan for Management and Use, January 1982).Given the 

potential confusion between the different route designations associated with 

NHTs (historic route, land or water trails, and auto routes), we suggest rewording 

the third sentence to read, "Additionally, many NHT visitors follow the trail via 

designated auto tour routes rather than hiking or water trails, although there are 

opportunities for hiking and other outdoor activities along the historic route." The 

last sentence of this paragraph appears incomplete or out of place

n

Thank you very much for comment. The RMP text has been altered to reflect 

your comment and concerns. Also in reference to the 5th comment in the table 

found in the letter submittal, table 2-6.3 does provide information on changes 

between Alternatives for resources and activities that may affect the PPNM. 

DRMTDK-BL13-0405-4

ACEC

Map 157 & 158 The maps provided of Pompeys Pillar National Monument show 

the slight change in Management Areas A and B between the current condition 

(Alternative A) and the action alternatives, which are all the same. Given the 

significance of the site and specific management issues associated with the 

monument, we suggest consideration of adding additional maps to better 

demonstrate the differences between the current management and action 

alternatives outlined in Table 2-6.3. It would also be informative to include 

information on proposed management actions by alternative beyond the 

monument boundaries and in the vicinity that may impact the monument such as 

right-of-way exclusion zones and visual resource management classifications

N

Thank you for expressing your concerns. 

The changes in acreage are due to better technology (use of GIS) when 

calculating acreages. 

Beyond the 432 acres of BLM managed public land at of PPNM and ACEC, 

there is no adjacent public land within to manage the viewshed. The ACEC is 

an avoidance area for ROWs. 

 

DRMTDK-BL13-0405-5National 

Historic 

Trails

With the recent release of the Miles City, HiLine, and this draft RMP, the NPS 

noted inconsistencies in the approach to addressing the management and 

protection of NHTs across these BLM planning areas. While we understand that 

n

Thank you for the comments. The BiFO staff has brought the subject to the 

attention of the NLCS lead for the Montana/Dakotas
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

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there will be differences based on local and regional issues, the NPS would like 

to work with the BLM on finding opportunities for greater consistency in 

management of the Lewis and Clark National Historic Trail

DRMTDK-BL13-0407-2

Wildlife

Much research just recently completed indicates Greater Sage-Grouse are very 

fragile to increasing habitat changes such as energy development, ground 

vibrations, noise, land disruption, and human encroachment. It is noted that BLM 

lands in South Central Montana are absolutely critical for migration, nesting, 

breeding, and connectivity of Greater Sage-Grouse habitat. Therefore it is 

recommended that all Greater Sage-Grouse Protections Areas be closed to oil 

and gas leasing and that a buffer zone of 4 miles be emphasized as critical for 

survival of Greater Sage-Grouse. It is also noted and emphasized that Greater 

Sage-Grouse are a bellwether for many other wildlife and plant species that are 

now feeling impact of human encroachment.

n

Table 2-6.1, page 2-77, Alternative B states, “Closed to future oil and gas 

leasing, exploration and/or development and prohibit other surface disturbing 

and disruptive activities (NL).

Surface occupancy and use would be prohibited in all PHMA habitat areas.

Leases would not be renewed upon expiration

Table 2-6.1, pages 2-76, Alternative B, includes the following: “Surface use for 

oil and gas exploration (including geophysical operations) would be prohibited 

from December 1 to March 1 within greater sage-grouse winter range or within

4 miles of a sage-grouse lek (TL). 

DRMTDK-BL13-0407-3Travel 

mngt, 

wildlife

 Bear Canyon is identified as an Audubon Important Bird Area. This is one of 

the first Important Bird Areas identified in Montana which is described as: Bear 

Canyon supports breeding populations of more than a dozen species on the 

Montana Priority Bird Species List. It also has the highest known number of 

nesting Blue-gray Gnatcatchers among the handful of foothill canyons in the 

area that constitute the entire range of the species in Montana. The riparian 

corridor is home to a rich diversity of Neotropical migrants, and the adjacent 

uplands are inhabited by Common Poor wills, Loggerhead Shrikes, Sage 

Thrashers, Green-tailed Towhees, Pinyon Jays, and the occasional broods of 

Greater Sage-Grouse. This area requires special protections to prevent mining 

or energy development and to limit road uses. There are multiple duplicate 

motorized routes in this area which often result in excessive loop ATV use. It is 

specifically recommended that two track leading to mouth of Bear Canyon be 

closed to allow survival of the Bear Canyon Important Bird Area.

n

Thank you for the comment. 

Important Bird Areas (IBAs) are area designated by the National Audubon 

Society. IBAs are sites that provide essential habitat for one or more species of 

bird. IBAs include sites for breeding, wintering, and/or migrating birds. There 

are four IBAs within the Billings Field Office Planning Area, three have public 

lands managed by BLM.. Discussion of the IBAs is referenced on pages 3-86 

and 3-99. One of the IBAs was nominated due to the presence of breeding 

populations of more than a dozen species on the Montana Priority Bird Species 

List. The foothill canyons in the area have the only known breeding location of 

blue-gray gnatcatchers in Montana (Audubon.org).

Two of the IBAs nominated were identified to accentuate the management of 

these areas for the conservation of sage grouse and other sagebrush obligate 

species. Refer to: http://www.mtaudubon.org/birds/sageiba.html.

Since Important Bird Areas are not a BLM designation, maps will not be

included in the EIS. BLM protections that will protect the two sage grouse IBAs 

can be found in Chapter 2, Greater Sage-Grouse PHMA, RA, and GHMA, and 

Appendix C, and Appendix AA, Executive Order 13186- Migratory Birds- is 

cited on page 2-68. The two IBAs are mostly within PHMAs.

Halfbreed NWR IBA – Managed by the USFWS and BLM has no management 

authority.

Thank you for your comments. This comment has been addressed in the Travel 

Management Comment Section and the Wildlife Comment Section. Specifically 

for travel, the routes have been designated as closed to motorized vehicles and 

the main route has been designated as a non-motorized trail 

DR- lands with Lands with Wilderness Characteristics are very limited and once lost, can never n Thank you for your concerns and comments. BLM follows Manual 6301 in 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

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MTDK-BL13-0407-4wilderness 

characteristi

cs

be replaced. Lands with Wilderness Characteristics are extremely limited in the 

South Central RMP - only 3.1% of the entire South Central BLM Region are 

designated as having wilderness characteristics. Prairie, grasslands, and 

foothills are often overlooked in terms of wilderness simply because they do not 

have high altitude mountains. Yet these areas have vast and undisturbed 

naturalness, wildlife, and solitude. It is therefore emphasized that areas including 

but not limited to Penney Peak, Tracts 1 and 4 in Pryor Mountain Unit, 

Weatherman Draw, Bad Canyon, Yellowstone River Islands, and Clark's Fork 

River Islands be added to lands that are designated and treated as lands with 

wilderness characteristics. It is specifically recommended that Demijohn Flat in 

Pryor Mountains be closed to motorized use to allow connectivity with Burnt 

Timber Canyon Wilderness Study Area and other lands with wilderness 

characteristics. This also would protect a culturally sensitive area.

conducting its wilderness inventories and Manual 6302 when considering lands 

with wilderness characteristics during planning. These Manuals implement 

Secretarial Order 3310 and incorporates principles from BLM guidance 

(Organic Act directives) and legal rules developed as part of BLM’s original 

wilderness inventories. 

A number of the units you mentioned (Bad Canyon, Weatherman Draw, some 

of the Yellowstone River islands, Tract 1 in the Pryor Mountains,) do possess 

wilderness characteristics. Tract 4 of the Pryor Mountain Unit does not currently 

meet the size criteria. Please see Appendix K for details. You are correct to 

note that should one of the two mentioned vehicle routes be closed and-or 

become unusable for motorized use, that Tract 4 would then be adjacent to a 

WSA. Please note that the Billings Field Office has chosen a management 

direction in the chosen Alternative which do not specifically manage for lands 

with wilderness characteristics resource values but which have management 

actions which provide for protection of those resources, as in the case of 

Weatherman Draw, Tract 1, the Yellowstone Islands and Bad Canyon.

In regards to your comment regarding the Demijohn Flat route, the RMP has a 

range of possible decisions. In this case, due to the conditions you mentioned 

the Alternative D has been modified to reflect the current conditions. The route 

will be designated as “closed” to motorized vehicles and as a non-motorized 

trail

Refer to map 146

DRMTDK-BL13-0410-1

Edits

There should also be a map of dams, ponds, lakes and if possible wetlands. A 

map of areas with slopes would be nice (topographic map). There should be a 

map of mountain lion habitat areas

n

Thank you for your comment. Text has been edited in response to your 

comment.

DRMTDK-BL13-0410-2

Edits

The vegetation map (map 9) combines too many classes of vegetation in each 

color, that don't always relate. For example we were trying to figure out where 

the areas with tree cover type were and thus figure out your potential mountain 

lion habitats. It seems generally that areas of trees would be the various shades 

of green. But the lightest green shade: 2,001-2,016 combines Woodlands with 

Sparsely Vegetated Systems, and the darkest green shade (2061-2072) 

combines Aspen-Mixed Conifer Forest and Woodland with various 

Woodland/Shrubland types and Shrubland types. It seems the green colored 

areas could have been broken into more consistent and meaningful subsets. 

Why are woodlands merged with sparsely covered areas? Why are 

Aspen/Conifer vegetation merged with Dwarf Sagebrush Shrubland and Steppe? 

Other trees are mixed with other prairie in the 2,153-2,179 set. I have not studied 

all subsets to see if this problem exists for other subsets, but we would like 

wetlands to be different from the other 3 vegetation classes it is merged with and 

some of the other water associated vegetation (in other subsets) could be 

merged into a sub set related to saturated soils. There does not seem much 

n

Thank you for your comment. Text has been edited in response to your 

comment.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-256 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

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logic to the clusters. When listing the classes of vegetation that relate to the 

subsets (see -Vegetation Definitions list), you should create a space or a line 

between each subset break, so it is easier to read and relate to the map legend

DRMTDK-BL13-0410-3

Wildlife 

If identifying potential transmission corridors for power lines, please discuss the 

debate among scientists over whether there is a risk (or no risk) from ELF 

radiation. Please discuss the relationship of your transmission line corridors to 

people's houses (discuss the distance from line corridor to houses), especially 

higher density developments and any potential mitigations to avoid transmission 

lines being placed directly over high density population areas or directly over 

houses of concerned folk who might object to that

N Thank you for your comment. This is beyond the scope of this document

DRMTDK-BL13-0410-4

Wildlife 

Please differentiate between "big game" animals that are "prey" species and 

those that are "predator" species and discuss them differently in the sections on 

affected environment and environmental consequences and mitigations. The 

issues with predators and prey are not always the same. You like the other 

BLMs seem to see the "big game" as the prey species during your effects 

section, when you discuss the effects of BLM management choices. . But you 

have comparatively more references to predators in the Big Game 

consequences section (Chapter 4) than Hi-line (once again you win the prize). 

However we ask in your Chapter 4 "Big Game" discussion, that you differentiate 

between "Big Game" that is prey/herbivore and "big game" that is predator of the 

herbivores when you discuss the effects of your actions

n

Thank you for the comment. Predator control is described in “Management 

Common to all Alternatives”, Table 2.6.1, .

BLM also has a Memorandum of Understanding (MOU) with APHIS –Wildlife 

Services (WS) that describes responsibilities of each of the agencies. WS is 

responsible for preparation of the NEPA documentation, annual Animal 

Damage Management Work Plan, and implementation. BLM cooperates with 

review and approval of their plans on public lands. As a reminder, BLM 

manages habitat, while Montana Fish, Wildlife, and Parks manages the wildlife. 

DRMTDK-BL13-0410-5

Wildlife 

Discuss the effects of large predators on ecosystem and particularly any species 

protected under the Endangered Species Act or otherwise believed to be at risk. 

Will large predators help by reducing medium and small predators, helping with 

riparian areas recover or will they make it worse by eating special species (or 

both)? Please discuss the effect of predators, (large, medium and small ones) on 

your species targeted for protection

n

Predator control was not included as a threat in the FWS’s listing decision; 

however, the BLM and the Forest Service acknowledge that localized 

predation may be a factor in the conservation of greater sage-grouse in some 

areas. In these areas, the states possess primary authority and responsibility 

for managing the wildlife within the state and the BLM and the Forest Service 

are responsible for managing habitat. 

Montana Fish, Wildlife and Parks manage wildlife within Montana, while the 

BLM and Forest Service focus on managing habitat. Consistent with a 

Memorandum of Understanding between the BLM and the US Department of 

Agriculture, Animal and Plant Health Inspection Service-Wildlife Services, the 

BLM and Forest Service will continue to work with Montana Fish, Wildlife and 

Parks to meet state wildlife population objectives. Predator control is allowed on 

BLM- and Forest Service-administered lands and is regulated by the MT FWP 

and Animal Plant and Health Inspection Service (APHIS). APHIS conducts 

environmental analyses in accordance with the National Environmental Policy 

Act (NEPA). The BLM and Forest Service will continue to work with agencies to 

address current predation of greater sage-grouse, and BLM and Forest 

Service-administered lands in the planning area will remain open to predator 

control under state laws. Additionally, the BLM and the Forest Service will 

continue to work with the involved states to meet state wildlife population 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-257

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objectives. 

While adding management actions specifically to manage predators is outside 

the scope of the amendment, the BLM and the Forest Service have authority to 

manage the habitat and have provided numerous management actions across 

the range of alternatives. Altering the sagebrush habitat of the greater sagegrouse can create an influx of predators into an area and lead to a population 

decline. Roads, fences, power lines, trails and other disturbances may make 

access easier for potential predators and increase risks to the species. The 

Draft EIS calls for measures that will substantially reduce disturbances in the 

bird’s habitat, thus reducing predation risk. The Draft EIS also calls for careful 

monitoring of grazing allotments within sage-grouse nesting habitat to ensure 

suitable grass and forb cover is reserved so we can minimize the associated 

predation risks.

 

Predator control is described in “Management Common to all 

Alternatives”, Table 2.6.1, .

BLM has a Memorandum of Understanding (MOU) with APHIS –Wildlife 

Services (WS) that describes responsibilities of each of the agencies. WS is 

responsible for preparation of the NEPA documentation, annual Animal 

Damage Management Work Plan, and implementation. BLM cooperates with 

review and approval of their plans on public lands. Predator control is 

referenced in Appendix AA (section F), “Mitigation Measures and Conservation 

Actions for Greater Sage-Grouse Habitat”.

DRMTDK-BL13-0410-6

Wildlife

Please discuss all your "predator control" programs and how you work with 

APHIS, private landowners and/ or the state with predator control. You have a 

few short mentions of this, saying you have a relationship, but don't explain in 

any depth. We want a full discussion of all your predator control efforts and 

which species they are directed against and how effective they are. For example 

many folks are critical of some coyote removal programs, claiming them as 

ineffective because the coyotes just respond to the deaths by having more 

babies

n

Predator control is described in “Management Common to all 

Alternatives”, Table 2.6.1, page 2-69.

BLM has a Memorandum of Understanding (MOU) with APHIS –Wildlife 

Services (WS) that describes responsibilities of each of the agencies. Predator 

control was not included as a threat in the FWS’s listing decision; however, the 

BLM and the Forest Service acknowledge that localized predation may be a 

factor in the conservation of greater sage-grouse in some areas. In these areas, 

the states possess primary authority and responsibility for managing the wildlife 

within the state and the BLM and the Forest Service are responsible for 

managing habitat. 

Montana Fish, Wildlife and Parks manage wildlife within Montana, while the 

BLM and Forest Service focus on managing habitat. Consistent with a 

Memorandum of Understanding between the BLM and the US Department of 

Agriculture, Animal and Plant Health Inspection Service-Wildlife Services, the 

BLM and Forest Service will continue to work with Montana Fish, Wildlife and 

Parks to meet state wildlife population objectives. Predator control is allowed on 

BLM- and Forest Service-administered lands and is regulated by the MT FWP 

and Animal Plant and Health Inspection Service (APHIS). APHIS conducts 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-258 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

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environmental analyses in accordance with the National Environmental Policy 

Act (NEPA). The BLM and Forest Service will continue to work with agencies to 

address current predation of greater sage-grouse, and BLM and Forest 

Service-administered lands in the planning area will remain open to predator 

control under state laws. Additionally, the BLM and the Forest Service will 

continue to work with the involved states to meet state wildlife population 

objectives. 

While adding management actions specifically to manage predators is outside 

the scope of the amendment, the BLM and the Forest Service have authority to 

manage the habitat and have provided numerous management actions across 

the range of alternatives. Altering the sagebrush habitat of the greater sagegrouse can create an influx of predators into an area and lead to a population 

decline. Roads, fences, power lines, trails and other disturbances may make 

access easier for potential predators and increase risks to the species. The 

Draft EIS calls for measures that will substantially reduce disturbances in the 

bird’s habitat, thus reducing predation risk. The Draft EIS also calls for careful 

monitoring of grazing allotments within sage-grouse nesting habitat to ensure 

suitable grass and forb cover is reserved so we can minimize the associated 

predation risks.

DRMTDK-BL13-0412-1

Travel mngt

My property is located 9 miles west of Highway 72 on Grove Creek Road. In 

looking at the map, I notice that the road through the private property is not 

correct. I am in section 11, parcel 2 and the actual road goes west along the 

north side of my property line. The road established in 1979 no longer exists. I 

am very concerned about closing the BLM roads from Highway 72 to my 

property.

n

Thank you for expressing your concerns. They have been considered by the 

Billings Field Office and Montana State Office and documented in the 

administrative record associated with the Billings and Pompeys Pillar National 

Monument RMP/EIS. Please know that 

BLM does not establish route determinations on private lands. Gold Creek 

Road (GC 1047), provides public access to the private lands in Section 11 

through public lands and this route intersects with Meeteetse Trail, a countymaintained road which originates at Highway 72. Refer to map 150. 

DRMTDK-BL13-0412-2

Fire 

Ecology 

and 

Manageme

nt

I am sending this email regarding my concerns about travel to my property, fire 

protection in case there is a fire in the National Forest. n

Thank you for expressing your concerns. They have been considered by the 

Billings Field Office and Montana State Office and documented in the 

administrative record associated with the Billings and Pompeys Pillar National 

Monument RMP/EIS. 

In regards to the road location you mention, please know that 

BLM does not establish route determinations for roads on private lands. 

Otherwise, Gold Creek Road (GC 1047), provides public access to the private 

lands in Section 11 through public lands and this route intersects with 

Meeteetse Trail, a county-maintained road which originates at Highway 72. 

Please refer to map 150. TF

In response to your comment, the text in Alternative D for the Grove Creek 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-259

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ACEC of the Proposed RMP and Final EIS has been revised to state: Wildfire 

management (natural ignitions) for resource benefit. Full range of fire 

management activities would be used in ACEC in response to human-ignited 

fires. Use of heavy equipment and retardant would be avoided unless approved 

by authorized officer. 

DRMTDK-BL13-0413-1

Wildlife

These comments conclude that the conservation of biological diversity, 

specifically sage-grouse core habitat as well as other BLM sensitive or special 

status species, by conserving intact landscapes with functioning ecological 

processes, should be a major concern and high priority in the Billings District 

RMP due to the areas of important biological diversity and sage-grouse core 

areas in the planning area. While we recognize that the planning area also 

provides for many other resource uses and other guidance governs these 

planning decisions, BLM's implementation of strong sage-grouse conservation 

measures is crucial to the success of efforts being undertaken by a diversity of 

land stewards for this imperiled species.

n

Thank you for the comment. Your comment will be considered when 

alternatives are selected in the Final RMP/ EIS.

DRMTDK-BL13-0413-

10

Riparian/ 

wetlands

In order to ensure the protection of disturbance-sensitive areas, such as sagegrouse priority areas or riparian and wetland habitats, no waivers, exceptions or 

modifications should be allowed for those areas when the BLM identifies a No 

Surface Occupancy stipulation. If waivers, exceptions and modifications are 

allowed, then the BLM should set up a process that allows the public to 

comment when these are actions considered.

n

A process is described in Appendix D.2.6. “Substantial modification or waiver 

is subsequent to lease issuance is subject to public review for at least a 30-day 

period.” Thank you for your concern and comment. It is not necessary to 

eliminate WEMs from sensitive habitats due to the process for which WEMs are 

granted. A developer must submit a plan that describes how the activities will 

not have unacceptable adverse impacts to the resource. This plan is approved 

by the authorized office, who would consult with the appropriate specialists to 

ensure the plan met resource objectives. For complete details of stipulations, 

WEMs and resource objectives, see Appendix C. 

DRMTDK-BL13-0413-

11

Travel mngt

Off-road vehicles can damage vegetation and soils, introduce and foster the 

growth of noxious weeds, and allow recreational shooters easy access to remote 

areas, including prairie dog colonies. WWF recommends that off-road vehicle 

use be limited to designated routes, and existing trails that have not been 

specifically designated for motorized use should be closed to motorized use and 

rehabilitated. The BLM should also ensure that off-road vehicle regulations are 

enforced.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

Specifically, with the exception of one Area designated for cross-country 

Motorcycle Use, the remainder of the FO lands is designated as “limited” for 

OHV use, meaning that travel is restricted to designated or existing routes. 

Closed vehicle routes may be used for non-motorized travel and in some cases 

are designated as specific trails. Compliance with legislations is not an issue for 

the RMP to consider – it is a n enforcement issue. 

DRMTDK-BL13-0413-

12

Wildlife

The body of science on temperate grasslands conservation continues to grow 

especially in regards to sage-grouse conservation. WWF supports the adoption 

of management actions based upon the best available science and supports the 

incorporation of that science into the RMP. In regards to sage-grouse 

conservation, much of the current science was recently compiled in A Report on 

National Greater Sage-Grouse Conservation Measures which was produced by 

Y

Thank you for your comment. 

Please see Appendix AB for a crosswalk between the COT report how this 

document is addressing the threats identified in the COT report. Thank You for 

the comment. BLM intends to rely on the latest research and best available 

science by utilizing existing research and delaying final decisions until the 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-260 Chapter 5: Consultation and Coordination

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the sage-grouse National Technical Team (Sage Grouse National Technical 

Team 2011) as well as in the recently released USGS Summary of science, 

activities, programs, and policies that influence the rangewide conservation of 

Greater Sage-Grouse (Centrocercus urophasianus) Open-File Report (Manier et 

al 2013). WWF supports the incorporation of the information from of these 

reports to the greatest extent possible in the Billings RMP revision. We 

recognize that studies on sage-grouse, sagebrush and energy development in 

the region is also ongoing (e.g., the USGS Range-Wide Genetic Connectivity of 

Greater Sage-Grouse Populations study 

(http://fresc.usgs.gov/research/researchPage.aspx?Research_Page_ID=123 ) 

and several projects on sagebrush, sage-grouse and impacts of energy 

development recently funded by the Plains and Prairie Potholes Landscape 

Conservation Cooperative) and several planning efforts are underway (e.g., the 

recently formed MT Governor's Sage Grouse Advisory Council). Recent 

research Knick (2013), further underscores the low and underestimated 

tolerance of sage-grouse for disturbance. As the body of research on these 

issues continues to develop, we encourage the BLM to err on the side of caution 

in selecting adequate conservation measures for protection that will be followed 

for the next 15-20 years. WWF supports the adoption of conservation measures 

for sage-grouse conservation that are based on the best available science. 

WWF strongly supports incorporating the results of new sage-grouse studies into 

the RMP, and future management, as they become available.

Governor’s Sage Grouse Advisory Council recommendations are final, 

incorporating the “USGS Range-Wide genetic Connectivity of Greater SageGrouse Populations” study when it is complete, and incorporating other future 

research through the “Adaptive Management” approach described in Section 

2.3.4.

DRMTDK-BL13-0413-

13

Edits p. 3-56 "Cooperative Week Management Area" should be "Cooperative Weed 

Management Area". n

Thank you for your comment. Text has been edited in response to your 

comment.

DRMTDK-BL13-0413-

14

Wildlife 

As noted in the plan, parts of the planning area have been identified as sagegrouse core areas. These areas have been identified as critical to sage-grouse 

conservation, by Montana Fish, Wildlife and Parks (MFWP). This RMP revision 

provides a well-timed opportunity to ensure the protection of sage-grouse habitat 

in the area and ensure connectivity to other populations. We encourage the BLM 

to work with stakeholders to balance resource use and pursue strategies based 

on the best available science that have the best chance of stabilizing or 

improving the condition of this priority species and its habitat.

n

Thank you for the comment. BLM can only manage habitat on public lands. 

Core area acreage outside of the PHMA designations were excluded either 

because of land ownership or previous habitat disturbance.

DRMTDK-BL13-0413-

15

Wildlife 

WWF supports the conservation of sage-grouse habitat to conserve this 

imperiled species but also supports the conservation of sagebrush habitat 

because it supports a number of other species and is a unique and imperiled 

vegetative community. Strong measures for conservation of sagebrush habitat 

will also benefit many other less studied species including several of BLM's 

special status species as well as provide benefits associated with large areas of 

intact habitat.

n Thank you for the comment.
Billings and Pompeys Pillar National Monument

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Chapter 5: Consultation and Coordination 5-261

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DRMTDK-BL13-0413-

16

Wildlife, 

Renewable 

Energy

The BLM identified fragmentation from energy development as a primary threat 

to sage-grouse conservation in the eastern region of its range. Impacts to sagegrouse include habitat fragmentation and direct loss, disturbances related to 

energy (oil and gas, and wind) exploration, development and production, 

pathogens (West Nile virus), and overhead powerlines. WWF agrees that 

fragmentation and loss of habitat especially by surface-disturbing or disruptive 

activities and noxious weeds, are critical issues to address in the conservation of 

sage-grouse and advocate that the strongest conservation measures in relation 

to these issues be adopted. WWF agrees with the BLM that within Management 

Zone 1 of the eastern region of sage-grouse range, in the context of private land 

development of energy resources, the ecological and conservation importance of 

sage-grouse on public lands is elevated. The identified impacts should all be 

addressed in BLM's revised RMP and our specific comments on alternatives 

reflect that.

n

Thank you for expressing your concerns. 

Please refer to the DRMP page 2-63, Table2.6-1, Section: “Vegetation: Invasive 

Species and Noxious Weeds - Management Common to All Alternatives” for a 

discussion regarding the treatment of noxious and invasive species for oil and 

gas operations, sage grouse habitat and treatment priorities. 

Concerns with surface-disturbing or disruptive activities, noxious weeds, and 

habitat fragmentation were considered and impacts disclosed in the designation 

of exclusion, avoidance and open areas for renewable energy (both solar and 

wind development) in the plan. Approximately 78,088 acres are excluded from 

any development, 331,088 acres are avoidance, where BLM would generally 

not entertain proposals, though under certain circumstances and dependent on 

the specific proposal, such development might be allowed with special 

stipulations and conservation measures. The preferred alternative considers 

only 5% of the BLM-administered land in the Billings Field Office (20,937 acres) 

as open based on anticipated limited resource concerns in those areas. 

DRMTDK-BL13-0413-

17

Wildlife 

As noted in the plan (p.1-6), in March 2010, the US Fish and Wildlife Service 

published its listing decision for the Greater Sage-Grouse as "Warranted but 

Precluded" and identified inadequacy of regulatory mechanisms as a major 

threat. The conservation measures within the BLM Resource Management Plans 

are its principal regulatory mechanism and must incorporate objectives and 

adequate conservation measures in order to conserve, enhance, and/or restore 

Greater Sage -“Grouse habitat, and thus reduce the need to enlist the species 

as endangered or threatened under the Endangered Species Act.

n

Thank you for the comment. Your comment will be considered when 

alternatives are selected in the Final RMP/ EIS.

DRMTDK-BL13-0413-

18

Wildlife 

WWF commends and supports the BLM's use of most of MT's core areas to 

identify Protection Priority Areas as these are vitally important to the health and 

persistence of sage-grouse populations. Because these areas are of highest 

importance for sage-grouse populations, those actions deemed to best protect 

these areas should be adopted, even if at the expense of other resource values. 

The BLM determined that the impacts from measures adopted, even if at the 

expense of other resources values. The BLM determined that the impacts from 

measures adopted in Alternative B would be negligible inside the PPA (p. 262) 

having the best results for sage-grouse core areas among the alternatives (p. 4-

287) and that both an ACEC or a PPA designation would yield the same results.

n

Thank you for the comment. Your comment will be considered when 

alternatives are selected in the Final RMP/ EIS.

DRMTDK-BL13-0413-

19

Wildlife 

since the BLM Montana-Dakota's template recommends that Protection Priority 

Areas should endeavor to improve and enhance habitat 

(http://www.blm.gov/pgdata/etc/medialib/blm/wo/Communications_Directorate/pu

blic_affairs/sage-grouse.Par.14184.File.dat/s-g_blm_montana_web.pdf), we 

encourage the BLM to adopt more measures to enhance habitat in core areas 

especially in the southern core area that has fewer improvements (p. 4-288). If 

Alternative D's NSO stipulation were to be adopted, it should also exclude any 

waivers, exceptions or modifications if those do not meet the regulatory certainty 

n

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS. Public comment periods are part of the NEPA process and should a 

waiver, exception, or modification be part of the stipulation, the WEMs would be 

considered and analyzed during the NEPA process. Refer to Appendix 
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required, and should include a public process to allow public comment when any 

exceptions or modifications are proposed to these critical areas.

D.2.6, Waivers, Exceptions, Modifications , page D-5. The last sentence of the 

first paragraph states that, “Substantial modification or waiver is subsequent to 

lease issuance is subject to public review for at least a 30 day period through 

the NEPA process. Also, Appendix C, Oil and Gas Lease Stipulations – where 

some stipulations have Waiver, Exception, Modification conditions described. 

Comments should be directed at those descriptions.

DRMTDK-BL13-0413-2

Wildlife 

We recognize that principal issues concerning wildlife habitat are surfacedisturbing and disruptive activities (p. ES-12) as well as other forms of 

fragmentation such as introduction of invasive species (p. ES-11), particularly 

those associated with energy development, and recognize that these also impact 

other resource values. Addressing these issues and minimizing their impacts to 

native species, and specifically sage-grouse, within the Billings RMP should be 

of primary importance. We recognize that the BLM needs to incorporate explicit 

objectives and adequate conservation measures into this RMP to conserve 

greater sage-grouse as part of preventing a listing under the ESA (p. 1-6), and 

that the BLM has clearly identified this as a priority in the Billings District Draft 

RMP/EIS.

n Thank you for the comment.

DRMTDK-BL13-0413-

20

Wildlife 

The BLM should ensure that new information on connectivity from new studies

including the USGS Range-Wide Genetic Connectivity of Greater Sage-Grouse 

Populations study 

(http://fresc.usgs.gov/research/researchPage.aspx?Research_Page_ID=123 ) is 

incorporated and appropriate conservation measures are adopted in the RMP. 

The BLM should clarify in the Environmental Consequences section the impacts 

of the management actions for Alternative D's General Habitat Areas and 

Restoration Areas. Although this is clearly done in other sections it appears to be 

missing in the preferred alternative section.

n

Thank you for your comment. Text has been changed in Chapter 4 to address 

your concerns.

DRMTDK-BL13-0413-

21

Wildlife 

The adopted alternative should include conditions that all pump stations and 

other permanent structures should be placed a minimum of 2 miles (3.2 km) 

from the nearest lek, with a preferred distance of >4 miles (6.4 km) from active 

leks.

n

Thank you for your comment. Appendix AA (section F) describes “Mitigation 

Measures and Conservation Actions for Greater Sage-Grouse Habitat”, which 

includes BMPs for Fluid Mineral development.

DRMTDK-BL13-0413-

22

Wildlife 

While timing limitations may address direct impacts to winter range areas, 

surface disturbing activities could lead to degradation of the habitat. BLM should 

address both direct and indirect impacts to winter range and improve 

documentation of specific winter habitats in which to apply conservation 

measures.

n

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS. note that a CSU (Controlled Surface Use) is also addressed on in 

the DRMP pages 2-76 & 77 for sage grouse winter range. The type of issues 

raised in your comment will be considered by the Billings Field Office during 

implementation of the Approved RMP when project-specific plans are prepared 

or evaluated. 

DR- Wildlife Sage-grouse Restoration Areas that contain core areas should be subject to n Appendix AA (section F), page 13 addresses “Reclamation” for Fluid Minerals 
Billings and Pompeys Pillar National Monument

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MTDK-BL13-0413-

23

stronger conservation measures The BLM should provide more clarity about how 

specific management for the portion of the southern core area that has been 

identified as a restoration area will be addressed, including what will occur upon 

expiration or termination of leases.

development in Greater Sage-grouse habitat.

DRMTDK-BL13-0413-

24

Wildlife

Active Lek buffers should be based on latest science In all sage-grouse areas 

where buffers are used, we agree with the state wildlife agencies that a buffer 

preventing energy development within 4 miles of active leks is preferred (unless 

greater protections are recommended in this document or new information 

indicates it should be greater) to protect as many nests as possible. All pump 

stations and other permanent structures should be placed a minimum of 2 miles 

(3.2 km) from the nearest lek, with a preferred distance of >4 miles (6.4 km) from 

active leks, based upon the best-available data from Naugle et al. (2011). Given 

that recent research Knick (2013) further underscores the low and 

underestimated tolerance for disturbance by sage-grouse, and as the body of 

research on these issues is still under development, we encourage the BLM to 

err on the side of caution in selecting adequate conservation measures for 

protection that will be followed for the next 15-20 years and be committed to 

amending management and permitting protocols as needed in the face of new 

information.

n

BLM intends to rely on the latest knowledge and best available science by 

utilizing existing research. Before beginning the B&PPNM RMP/EIS and 

throughout the planning effort, the BLM and the Forest Service considered the 

availability of data from all sources, adequacy of existing data, data gaps, and 

the type of data necessary to support informed management decisions at the 

land-use plan level. The data needed to support broad-scale analysis of the 

Billings Field Office planning area are substantially different than the data 

needed to support site-specific analysis of projects. The RMP/EIS data and 

information is presented in map and table form and is sufficient to support the 

broad scale analyses required for land use planning. 

The BLM and the Forest Service used the most recent and best information 

available that was relevant to a land-use planning-level analysis including the 

Baseline Environmental Report (BER; Manier et al. 2013). The BER assisted 

the BLM and the Forest Service in summarizing the effect of their planning 

efforts at a range-wide scale, particularly in the affected environment and 

cumulative impacts sections. The BER looked at each of the threats to greater 

sage-grouse identified in the Fish and Wildlife Service’s “warranted but 

precluded” finding for the species. For these threats, the report summarized the 

current scientific understanding, as of report publication date (June 2013), of 

various impacts to greater sage-grouse populations and habitats. The report 

also quantitatively measured the location, magnitude, and extent of each threat. 

These data were used in the planning process to describe threats at other 

levels, such as the sub-regional boundary and WAFWA Management Zone 

scale, to facilitate comparison between sub-regions. The BER provided data 

and information to show how management under different alternatives may 

meet specific plans, goals, and objectives. 

Additionally, the BLM and the Forest Service consulted with, collected, and 

incorporated data from other agencies and sources, including but not limited to 

the U.S. Fish and Wildlife Service and Montana Fish, Wildlife and Parks. 

Other future research and data will be incorporated through the “Adaptive 

Management” approach described in Section 2.3.4, page 2-7.

DRMTDK-BL13-0413-

25

Renewable 

Energy

Renewable energy development should be minimized in sensitive areas In 

addition to oil and gas development, wind potential in the Eastern Region is very 

high. As previously noted, we believe development of wind energy can be 

compatible with wildlife if wind development occurs outside of sensitive areas. 

The science on wind energy impacts to sensitive species is under development 

n

Thank you for your comment. We agree that development of wind energy can 

be compatible with wildlife in certain circumstances. Because of this, while 

renewable energy (both solar and wind development) is excluded on 78,088 

acres, 331,088 acres have been designated as avoidance areas. BLM would 

generally not entertain proposals within avoidance areas, but under certain 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

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(p. 4-273) and as it is improved conservation measures should reflect the 

science. Because greater sage-grouse avoid tall structures, special care should 

be taken to develop wind energy outside of identified core areas and all 

structures should be placed at least five miles from the nearest lek if the 

population is non-migratory (USFWS 2004 also cited p. 4-273).

circumstances and dependent on the specific proposal, such development 

might be allowed with special stipulations and conservation measures, some 

which may be unknown at this time given continuing research and everchanging renewable energy technologies. The preferred alternative considers 

only 5% of the BLM-administered land in the Billings Field Office (20,937 acres) 

as open based on anticipated limited resource concerns in those areas. 

The 2004 USFWS briefing paper cited on p. 4-273 was prepared in regard to 

studies conducted on the greater prairie chicken. Connelly et al. (2000) 

recommends a two mile buffer for sage-grouse. Rather than buffers, the 

preferred alternative designates sage grouse PHMAs as avoidance areas to be 

managed as described in the response above, regardless of the distance from 

an occupied lek.

DRMTDK-BL13-0413-

26

Wildlife

Fences should be removed, modified or marked in high-risk areas WWF 

commends the BLM for identifying the importance of fence removal or 

modification (p. 2-86). As noted, fencing can potentially impact wildlife species 

by fragmenting habitat or impeding migration among other alterations. Sagegrouse specific impacts include perching sites for predators and collision risk. 

We support the BLM actions common to all alternatives that new fences would 

allow for wildlife passage (except for fences built specifically to keep wildlife out 

of an area) and that fences would also be placed and marked, or modified, to 

reduce wildlife collisions or entanglements. The BLM should also consider 

removing fencing in priority areas and these actions should be implemented in 

all sage-grouse areas especially around leks.

n

Thank you for the comment. Please refer to Table 2-6.1, page 2-68, that 

states, “Fences identified as barriers to wildlife movement on BLM-administered 

lands would be modified or removed to accommodate wildlife passage.” Also, 

please note that over 50 miles of fence marking within 1-2 miles of sage grouse 

leks has already been completed. 

DRMTDK-BL13-0413-

27

Wildlife 

Actions to prevent West Nile virus should be required West Nile virus, which is 

linked to standing water associated with some forms of energy development and 

agricultural water development, also poses a threat to greater sage-grouse. 

Naugle et al. (2004) showed that up to 25% of a population may die due to West 

Nile virus. Although West Nile virus will impact sage-grouse populations (as well 

as humans and horses) in less developed areas, cumulative effects of West Nile 

virus occur in areas with high energy development. To reduce cumulative 

impacts, the BLM should prioritize limiting other impacts such as disturbance in 

areas with West Nile virus potential. The BLM produced an Information Bulletin 

(MT-2011-033) regarding best management practices to reduce the availability 

of breeding grounds for mosquitoes that carry West Nile virus. We recommend 

that these best management practices be implemented across BLM lands and 

particularly in sage-grouse core areas to prevent deaths. WWF has also 

produced, along with partners at the University of Wyoming, a spatially explicit 

map showing where West Nile virus is most likely to become prevalent under 

climate change conditions (Schrag et al. 2010). Areas with a high threat of West

Nile virus should be prioritized for reduction of standing water and other factors 

n

Thank you for your comment. The type of issues raised in your comment will be 

considered by the Billings Field Office during implementation of the Approved 

RMP when project-specific plans are prepared or evaluated. – several 

references to management of West Nile virus are included in Appendix 

AA(section F) and Table 2-6.1, page 2-69. 
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that increase the likelihood of becoming Culex mosquito breeding grounds.

DRMTDK-BL13-0413-

28

Wildlife 

Using the best-available data on the impact of threats to greater sage-grouse, 

we encourage the BLM to incorporate regulations and management practices 

that avoid threats in sage-grouse core areas and address impacts across the 

remaining sage-grouse habitat in this plan which will guide actions for the next 

15-20 years. We also encourage the BLM to build on their strong stewardship 

and use the best available science to incorporate regulations and management 

practices that conserve the rich biological diversity which will also benefit the 

exceptional hunting, recreational, and cultural opportunities and the many other 

resource values of this region for current and future generations.

N Thank you for your comment. 

DRMTDK-BL13-0413-3

Wildlife 

Although federal surface lands within the Billings District are scattered the 

planning area has been recognized for containing areas of high biodiversity in 

both a global and regional context. World Wildlife Fund (WWF) has identified the 

Northern Great Plains Ecoregion as one of the most biologically significant 

landscapes in the world. In 2004, along with partner organizations in the 

Northern Plains Conservation Network, WWF produced an ecoregional 

assessment for the NGP titled: Ocean of Grass: A Conservation Assessment for 

the Northern Great Plains (Forrest et al. 2004) and in 2012 an updated 

biodiversity assessment was released, the results of which are publicly available 

on an interactive web map (World Wildlife Fund 2012; Figure 1). In addition, an 

accompanying assessment (Schrag and Climb 2013) was produced to 

summarize key threats to biological diversity in the area. Both of these 

assessments identified that areas of the Billings District planning area contain 

high levels of biodiversity, mainly as a result of high numbers of sage-grouse, 

other grassland imperiled species, endemic species and intact lands. Other 

assessments have also identified parts of the region as having regionally 

important biodiversity (TNC 1999 and Audubon at 

http://mtaudubon.org/birds/sageiba.html ; Figure 1). Several Audubon Important 

Bird Areas (IBA) (as noted in the plan p. 3-86) are also located within the 

planning area. These include the Musselshell Sage-steppe IBA designated in 

2007, which covers an expanse of sagebrush shrub-steppe and native prairie 

habitat on the western edge of the Great Plains. It supports a significant 

population of Greater Sage-Grouse in central Montana 

(http://netapp.audubon.org/IBA/Reports/3303). The Bridger Sage-steppe IBA is 

also within the planning area. It is dominated by sagebrush shrubs-steppe, with 

native grasslands on upper hillsides 

(http://mtaudubon.org/birds/documents/bridger.web.pdf). According to the IBA 

document, the Carbon Triangle area of this IBA encompasses significant habitat 

for Greater Sage-Grouse and supported the largest concentration of sagegrouse in the south-central portion of the state, at the time written, and roughly 

3% of the male grouse surveyed in the state.

n

Thank you for the comment. BLM intends to rely on the latest research and 

best available science by utilizing existing research and incorporating future 

research through the “Adaptive Management” approach described in Section 

2.3.4, page 2-7. Also, some of the issues raised in your comment will be 

considered by the Billings Field Office during implementation of the Approved 

RMP when project-specific plans are prepared or evaluated through site 

specific NEPA analysis.

BLM coordinates with other agencies, NGOs, and private interests to 

cooperatively improve management and share information to improve wildlife 

habitat management and biodiversity on all land ownerships. Thank you for 

the comment. 

The majority of the high biodiversity areas are protected through RMP actions 

for Sage grouse (PHMAs, RAs,) and other actions such as ACECs, Rangeland 

Health Standards – Standard 5= Biodiversity Standard, etc.)

Important Bird Areas (IBAs) are area designated by the National Audubon 

Society. IBAs are sites that provide essential habitat for one or more species of 

bird. IBAs include sites for breeding, wintering, and/or migrating birds. There 

are four IBAs within the Billings Field Office Planning Area, three have public 

lands managed by BLM. Discussion of the IBAs is referenced on pages 3-86 

and 3-99. One of the IBAs was nominated due to the presence of breeding 

populations of more than a dozen species on the Montana Priority Bird Species 

List. The foothill canyons in the area have the only known breeding location of 

blue-gray gnatcatchers in Montana (Audubon.org).

Two of the IBAs nominated were identified to accentuate the management of 

these areas for the conservation of sage grouse and other sagebrush obligate 

species. Refer to: http://www.mtaudubon.org/birds/sageiba.html.

Since Important Bird Areas are not a BLM designation, maps will not be 

included in the EIS. BLM protections that will protect the two sage grouse IBAs 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

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can be found in Chapter 2, Greater Sage-Grouse PHMA, RA, and GHMA, and 

Appendix C, and Appendix AA, AB. Executive Order 13186- Migratory Birds- is 

cited on page 2-68. The two IBAs are mostly within PHMAs

Halfbreed NWR IBA – Managed by the USFWS and BLM has no management 

authority.

DRMTDK-BL13-0413-5

Climate

The Billings District should consider the importance of its actions in context of 

the greater landscape especially in relation to creating resiliency to climate 

change and ensuring connectivity to habitat outside of the planning area for

species that require it. Managing at larger landscape scales is important 

because climate change is likely to cumulatively, with other human-induced 

stresses increase ecosystem vulnerability. Because of this, the Billings District 

should incorporate recommendations from large-scale regional planning and 

assessments such as the BLM's Rapid Ecological Assessments in the RMP 

revision as they become available.

N

Thank you for your comment. Status of the Northwestern Plains REA can be 

found at 

http://www.blm.gov/wo/st/en/prog/more/Landscape_Approach/reas/nwplains.ht

ml. The final RMP will be completed before the Northwestern Plains REA is 

complete.

DRMTDK-BL13-0413-6

Riparian/ 

wetlands

Riparian and wetland areas are disproportionately important landscape elements 

to biological diversity. They are some of the rarest habitat types in North America 

and up to 80% of vertebrate species in the arid west use these habitats at some 

point in their life cycle. Therefore, they are of critical importance to conserve 

through public lands planning efforts (Krueper 2000). Numerous sensitive 

species in the planning area rely on riparian zones. Riparian vegetation is 

important to maintain aquatic resources, including fish, as well as water quantity 

and quality. WWF commends the BLM for identifying riparian areas for targeted 

recovery efforts. Because of the inordinate importance to biological diversity and 

over resource values, the BLM should prioritize adopting conservation 

measures, based on the best available science, that improve and protect riparian 

and wetland areas. Therefore, WWF supports the measures identified in 

Alternative B for these areas that provide the most intensive protection and 

restoration efforts as well as provide long-term beneficial impacts (p. 4-258). In 

addition, WWF supports using the best available science for establishing the 

buffer distance for key species, which is readily available (e.g. Ellis 2008).

n

Thank you for your comment. The BLM will be weighing the benefits of each 

alternative before making the final choice. Ultimately, the alternative chosen 

would represent the actions that best result in meeting resource objectives 

while allowing for multiple use of public lands.

DRMTDK-BL13-0413-7

Renewable 

energy

We believe development of wind energy can be compatible with wildlife if wind 

development occurs outside of sensitive areas. WWF, in partnership with The 

Nature Conservancy, recently developed maps of wind energy potential on 

previously disturbed lands in the five states encompassed by the Northern Great 

Plains Ecoregion (Montana, Wyoming, North Dakota, South Dakota, Nebraska; 

Fargione et al. 2011 and 2012). Wind potential on disturbed lands far exceeds 

the Department of Energy's goals in each of these states, allowing wind 

development to be focused outside of sensitive grasslands with little reduction in 

energy produced. Most of the areas identified through this study as Low Impact 

n

Thank you for your comment. We have reviewed the referenced study of wind 

and wildlife in the Northern Great Plains prepared by Fargione et al. and 

appreciate the conclusions regarding wildlife sensitivity. The analysis conducted 

in the Billings RMP considered all resource values (not just wildlife and 

sensitive grasslands and habitats) to derive the open, avoidance, and exclusion 

areas delineated in the preferred alternative. The preferred alternative 

designates only 5% of the BLM-administered land in the Billings Field Office 

(20,937 acres) as open based on anticipated limited resource concerns in those 

areas. 
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Areas with High Wind Development potential occur scattered throughout the 

area but mainly in the west (Figure 2). WWF supports the BLM's exclusion of 

wind energy from sage-grouse priority areas as well as for other sensitive 

species habitats and landscapes. WWF advocates for wind energy development 

on already disturbed lands that lie outside all greater sage-grouse core areas 

and exclusion from other areas that provide habitat for other sensitive species.

DRMTDK-BL13-0413-8

Vegetation 

Invasive 

Species 

and 

Noxious 

Weeds

Invasive species are an increasing threat that impact multiple resource uses 

such as grazing, wildlife habitat, hunting and fishing as well as altering critical 

ecological processes. Native vegetative communities are generally associated 

with higher levels of species diversity. Noxious weeds are often correlated with 

surface-disturbing activities such as roads (p. 3-88). WWF commends the BLM

for participation in Cooperative Weed Management Areas especially due to the 

fragmented nature of BLM lands. Because prevention is the best strategy for 

minimizing invasive species, and anthropogenic disturbance is highly associated 

with the introduction of noxious, and invasive species, the BLM should minimize 

surface-disturbing and disruptive activities (such as energy development or 

roads) in undisturbed habitats. In areas where surface disturbance occurs, we 

support of the use of native species in restoration as appropriate to the site (p. 2-

65)

n

Thank you for your comment. 

Please refer to Chapter 2, Table 2-6.1, Page 2-62, pre-amble section 

“Vegetation: Invasive Species and Noxious Weeds” and “Desired Outcomes 

(Goals and Objectives)” discussions in the Draft RMP/EIS: “ The BLM would 

control invasive, and non-native weed species and prevent the introduction of 

new invasive species, including aquatic nuisance species, by implementing a 

comprehensive weed program including: coordination with key partners, 

prevention and early detection, education, inventory and monitoring, and using 

the principles of Integrated Pest Management (IPM) and creating weed 

management areas (WMAs)”. 

Project design features and mitigation measures, such as seed mix 

recommendations are developed at the site specific level, and as such are 

beyond the scope of this document. However, the application of native seed 

mixes as appropriate to the site, are always the preferred alternative.

DRMTDK-BL13-0413-9

Realty, 

Cadastral 

Survey, and 

Lands

Land consolidation would benefit a number of species where uniform 

management over large areas improve conservation outcomes. Fragmented 

ownership can be an impediment to minimizing conflicts and can make 

coordinated management at appropriate scales difficult. WWF supports BLM 

efforts to consolidate ownership while retaining and adding to critical habitat to 

enable more effective management for biodiversity.

n

Thank you for your comment. We agree that land consolidation can be a 

valuable tool in preserving and enhancing wildlife habitat. Land consolidation 

has always been a goal of BLM land exchanges and acquisitions and it will 

receive even more emphasis in the future particularly for the greater sage 

grouse and its habitat.

DRMTDK-BL13-0416-1

Oil and Gas

Montana-Dakota generates, transmits and distributes electricity and distributes 

natural gas in Montana. The company also owns and operates coal- and natural 

gas-fired electric generating facilities, as well as wind electric generation in 

Montana.

n Thank you for your comment.

DRMTDK-BL13-0416-2

Realty, 

Cadastral 

Survey, and 

Lands

Since Montana-Dakota currently owns energy infrastructure on BLM lands in 

Montana and may propose to install new energy infrastructure and energy 

facilities within BLM lands in Montana, the restrictions in the Billings Draft RMP 

could impact the company's operations and potentially increase costs for 

customers. Montana-Dakota predominantly owns and operates gas distribution 

facilities in the Billings region, but will address projected impacts for both gas 

and electric distribution and electric transmission operations and facilities from 

the Billings Draft RMP in this comment letter.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

DRMTDK-BL13-0416-3

Wildlife 

At the outset, Montana-Dakota understands that the greater sage-grouse 

species has declined, that the USFWS will be issuing a final listing decision for 

greater sage-grouse under the Endangered and Threatened Species Act (ESA) 

n Thank you for your comment.
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in the next couple years, and that states have been assigned the task of 

developing conservation measures for adequate protection of the species to 

avert a final listing decision under the ESA. Montana-Dakota appreciates the 

opportunity to comment on the Billings Draft RMP alternatives and has provided 

detailed comment below.

DRMTDK-BL13-0416-4

Wildlife 

Consolidation of Infrastructure Requirements. The BLM states that the Billings 

Draft RMP is to provide a comprehensive framework for land management of

BLM administered lands, among consolidations of existing plans and 

management decisions, that are designed to balance uses with the protection of 

resources pursuant to Federal Land Policy and Management Act of 1976 and 

other applicable law. The BLM is including conservation measures for the 

greater sage-grouse in the Billings Draft RMP to assist in averting an ESA listing 

for sage-grouse. As BLM is aware, the State of Montana has formed a Greater 

Sage-grouse Advisory Council to develop conservation measures by January 

2014 to be enacted into law for protection of the sage-grouse and its habitat in 

Montana. Montana-Dakota recommends the BLM not finalize its sage-grouse 

conservation measures until the agency can review what the State of Montana 

develops, and adopt the same conservation measures that the Montana Greater 

Sage-grouse Advisory Council finalizes in order to maintain as much consistency 

with requirements for electric and gas distribution and transmission line as 

possible. The Montana conservation measures are being developed for the 

same purpose as BLM, to provide adequate protection of the species and to 

avert a final listing decision from USFWS. Applying the same conservation 

measures will be much more efficient for industry to manage and implement.

n

Thank You for the comment. BLM intends to rely on the latest research and 

best available science by utilizing existing research and the Governor’s Sage 

Grouse Advisory Council recommendations, incorporating the “USGS RangeWide genetic Connectivity of Greater Sage-Grouse Populations” study when it 

is complete, and incorporating other future research through the “Adaptive 

Management” approach described in Section 2.3.4, page 2-7. Before beginning 

the B&PPNM RMP/EIS and throughout the planning effort, the BLM and the 

Forest Service considered the availability of data from all sources, adequacy of 

existing data, data gaps, and the type of data necessary to support informed 

management decisions at the land-use plan level. The data needed to support 

broad-scale analysis of the Billings Field Office planning area are substantially 

different than the data needed to support site-specific analysis of projects. The 

RMP/EIS data and information is presented in map and table form and is 

sufficient to support the broad scale analyses required for land use planning. 

The BLM and the Forest Service used the most recent and best information 

available that was relevant to a land-use planning-level analysis including the 

Baseline Environmental Report (BER; Manier et al. 2013). The BER assisted 

the BLM and the Forest Service in summarizing the effect of their planning 

efforts at a range-wide scale, particularly in the affected environment and 

cumulative impacts sections. The BER looked at each of the threats to greater 

sage-grouse identified in the Fish and Wildlife Service’s “warranted but 

precluded” finding for the species. For these threats, the report summarized the 

current scientific understanding, as of report publication date (June 2013), of 

various impacts to greater sage-grouse populations and habitats. The report 

also quantitatively measured the location, magnitude, and extent of each threat. 

These data were used in the planning process to describe threats at other 

levels, such as the sub-regional boundary and WAFWA Management Zone 

scale, to facilitate comparison between sub-regions. The BER provided data 

and information to show how management under different alternatives may 

meet specific plans, goals, and objectives. 

Additionally, the BLM and the Forest Service consulted with, collected, and 

incorporated data from other agencies and sources, including but not limited to 

the U.S. Fish and Wildlife Service and Montana Fish, Wildlife and Parks. 

DRMTDK-BL13-0416-5

Wildlife 

Consideration of Recent Scientific Studies Montana-Dakota is concerned that 

the BLM did not review scientific literature that has found lesser impacts from 

power lines on sage grouse than some have believed. Consequently, there is 

N

Thank you for your comment. - sage grouse transmission lines and guidance 

with LeBeau USGS report. 

BLM intends to rely on the latest research and best available science by 
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concern with the preferred alternative which includes stringent conservation 

measures that appear to be based more on modeling of theories rather than 

scientifically rigorous and peer-reviewed research. Montana-Dakota 

recommends the BLM adopt the conservation measures being developed by the 

Montana Greater Sagegrouse Advisory Council, or consider applying the sagegrouse BMPs that are being developed together between APLIC and wildlife 

agencies to serve as appropriate conservation measures for sage-grouse issues 

related to electric utility facilities.

utilizing existing research and delaying final decisions until the Governor’s Sage 

Grouse Advisory Council recommendations are final, incorporating the “USGS 

Range-Wide genetic Connectivity of Greater Sage-Grouse Populations” study 

when it is complete, and incorporating appropriate recommendations into the 

Final RMP. Other future research, such as recent APLIC guidelines, will be 

considered through the “Adaptive Management” approach described in Section 

2.3.4, page 2-7. 

DRMTDK-BL13-0416-6

Wildlife

Restoration Area Conservation Measures Montana-Dakota recommends that the 

BLM not require the removal or undergrounding of electric distribution or 

transmission lines for restoration considerations in priority conservation areas or 

in areas proposed for restoration due to the significant cost for underground 

installation and the cost and complexity involved with establishing a new route 

for this infrastructure. It is recommended that the BLM work with utilities on a 

case-by-case basis to address potential impacts or concerns from this 

infrastructure to sage-grouse in areas identified for restoration and consider 

BMPs other than removal or undergrounding. Montana-Dakota believes this 

approach is appropriate since electric transmission and distribution line 

infrastructure has a small footprint and has not resulted in significant direct 

displacement of sagebrush habitat.

n

Refer to page AB-6 for Power-line mitigation and conservation measures for 

greater sage-grouse. Other measures will definitely be considered prior to 

considering removal or undergrounding.

For example:

“Determine by cooperative action- agencies, utilities, and landowners- whether 

or not modification of poles to limit perching will prevent electrocution of raptors 

and decrease predation on sage-grouse. Emphasize the following if perch 

prevention modifications do not work to protect sage-grouse and sage-brush 

habitat:

o reroute the line using distance, topography, or vegetative cover; or

o bury the line.

Remove power lines that traverse important sage-grouse habitats when 

facilities being serviced are no longer in use or when projects are complete.”

DRMTDK-BL13-0416-7

Realty, 

Cadastral 

Survey, and 

Lands

Existing Leases Existing leases for electric and gas distribution and transmission 

that are currently located in priority areas of conservation as well as areas 

identified for restoration, should be allowed to be renewed due to the potential 

impact any lease expiration would have by requiring a costly reroute of existing 

gas or electric lines, substations, and gas border stations and may not 

necessarily achieve greater protection for sage-grouse. Existing surface 

occupancy of facilities should be allowed due to the cost of relocating facilities. 

Montana-Dakota believes BLM and utilities can work together on rebuilding 

projects and develop conservation measures if necessary on a case-by-case

basis.

n

Thank you for your comment. 

The ROW avoidance and exclusion areas proposed by alternative are for new 

rights-of-way. The document states “ROW exclusion or avoidance areas would 

be subject to valid existing rights.” The Billings Field Office RMP will continue 

to respect the rights and investments of utility companies crossing over or 

under public lands with authorized by rights-of-way. Existing rights-of-way 

located within priority greater sage grouse habitat will receive additional 

monitoring by BLM personnel, but will not be required to re-build. The most 

likely mitigation for a right-of-way renewal of an overhead electric powerline 

would be the installation of anti-perching devices and bringing powerlines up to 

the existing standards required Avian Powerline Interaction Committee (APIC). 

In the case of pipeline rights-of-way there may be modifications to vegetation 

mowing within the boundaries of the grant. 

For new rights-of-way there will be increased environmental review and an 

emphasis on avoiding sage grouse priority habitat.

DRMTDK-BL13-0416-8

Wildlife

The two quotes shown below are from the USGS report and are not considered 

accurate when reading the actual text from the references and we recommend 

BLM conduct separate review of this literature to ensure the determinations in 

n

Thank you for the comment. We agree that quality of brood-rearing habitat will 

influence habitat selection. The literature will be reviewed prior to the Final 

RMP/EIS.
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references are applied properly in consideration of sage-grouse conservation 

measures. "Sage-grouse avoided brood-rearing habitats within 2.9 mi (4.7 km) of 

transmission lines in south-central Wyoming (LeBeau, 2012). ""Power line 

collisions accounted for 33 percent of juvenile (1st winter) mortality ill lowelevation areas in Idaho (Beck and others, 2006) ". Regarding the statement 

above from the LeBeau 2012 report, the USGS does not include how LeBeau 

characterizes the proximity to transmission lines and should consider this 

additional statement from that reference: "Specifically, sage-grouse within SMH 

selected for brood-rearing habitats farther away from transmission lines. 

However, much of the habitat surrounding the transmission lines located within 

the SMH study area was mostly comprised of a greater percent bare ground, 

which is not characteristic of sage-grouse brood rearing habitats (Connelly et al. 

2000, Aldridge and Boyce 2007) and percent bare ground was represented as a 

negative effect in the top brood-rearing selection model (i.e. , odds of selection 

increased in habitats with less bare ground). ..

BLM intends to rely on the latest research and best available science by 

utilizing existing research and incorporating other future research through the 

“Adaptive Management” approach described in Section 2.3.4, page 2-7.

DRMTDK-BL13-0417-1WILD 

HORSES, 

PMWHR

Here in N.C. the wild horses on barrior Islands are protected by different local 

care takers of each remaining wild herds ! The Shackelford Wild Mustangs who 

now have Presidential Protection signed by Bill Clinton are cared for by the 

N.P.S. (who once wanted to kill them all ) but now share their management with 

the " Shackelford Foundation Inc. " which both are over seen and watched by " 

Friends of The Shackelford Wild Mustangs " Founded by Elizabeth Loftin , 

Hidede Bowl, Tony Seamon, and Ms. Dot Walter Willis ! In Chincoteague N.C. 

the wild horses are protected by the local people and the FIRE DEPT. ! There 

are many trust worthy advocates to share management and look over the care of 

these majestic beauties ! Mustang Meg !!! " Sonya " comes first to my mind and 

Trust Worthiness. Thank-you for considering my solution to a long ongoing 

problem ! Our State Congressmen, Senators, legislators, C.A.M.A. and the 

President of the United States....all agreed with me in 1993 to 1999 in our long 

drawn out battle ! Since the Presidential Protection Wild Horse Act was put into 

place for our wild horses. The Shackelford Horses are not our State Horse ! And 

the N.P.S. has worked alongside of the Shackelford Foundation ! There has 

been no more killings !

N Thank you for your comment 

DRMTDK-BL13-0418-1WILD 

HORSES, 

PMWHR

Please stop these barbaric roundups of the mustangs. These herds have 

roamed our plains for years and aren't hurting anything. N

Thank you for your comment. This document is not tied to any gather as 

gathers are implementation level documents. 

DRMTDK-BL13-0422-1

Wildlife

Concerning the Sage Grouse issue, please refer to the study Landscape-Scale 

Factors Affecting Population Dynamics of Greater Sage-Grouse in North-Central 

Montana, 2001-2004 written by Brendan James Moynahan. The study goes into 

detail on many interesting points, including the fact that the main cause of nest 

failure was that of predators. This three year study does not seem to have been 

used as a resource during the creation of the plans.

n

Thank you for your comment. It is also stated that, “Management of habitats for 

nesting sage-grouse should focus on increasing grass cover to increase 

survival of first nests and contribute to favorable conditions for re-nesting, which 

should be less likely if survival of first nests increases. “Factors Affecting Nest 

Survival of Greater Sage-Grouse in

Northcentral Montana” Moynahan, Brendan J., et al. Univ. of Mt., Missoula, Mt. 
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,Journal of Wildlife Management, Volume 71, Issue 6, Dec.13, 2010.

DRMTDK-BL13-0422-2

Social/econ

You have not address the commutative and County economic impact this plan 

will have to the people of Montana. We believe depending on the travel plan and 

the commercial restriction you Will come forward with. We believe this plan could 

cost everyone mention above could shut down hunting ,commercial enterprise 

and tourism Dollars coming into the state. You have not address impact in Detail 

Schools gas station hotels and eating sporting good and equipment like ATVS 

and SUVs and housing market the growth in these area and tax revenues that 

would be losses that would have been generated from the proposed changes!

n

The analysis addresses the economic consequences of recreation on pg. 4-605 

of the DEIS. None of the alternatives are expected to decrease revenue, 

employment, or income associated with visitors to public lands in the Field 

Office area.

DRMTDK-BL13-0422-3

Travel mngt

CW 2080 needs to be open for full size 4x4 UTV and all motorized travel. 

Without what we call the switch backs which is a key connection route to the 

other side of the FS. This road connects north side with south side and it 

provides a Moab experience. Otherwise would take additional 2 hrs to get 

around and back up the mountain

n

Thank you for your comments. The route has been reviewed by BLM staff and 

the decision has been altered to classify the route CW 2080 as being “open 

with additional management”. 

DRMTDK-BL13-0422-4

WSR

wild and scenic rivers on crooked creek do not belong. The road runs along the 

creek and it is not a river and not wild. When we have water on the road it runs 

directly in to the creek. You would be able to hear the traffic and see them on the 

corners so this needs to be taken out. Also Bad Canyon Creek is also in there 

and it is a creek not a river and it dry up in the summer time in area. There is 

fence and manmade structure close by and Cattle graze in the creek area! There 

is mineral in the area and good Grazing.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses of text revisions 

under NEPA regulations, they have been considered in the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

In regards to your specific comment on Wild and Scenic Rivers, the process 

and criteria for identifying, evaluating and designating wild and scenic rivers 

was set by the Wild and Scenic River Act (P.L. 90-542, as amended) and the 

federal land management agencies can only follow that direction. Please refer 

to that Act for guidance. 

DRMTDK-BL13-0422-5

Travel mngt

Weather man draw and Cotton Wood move to open riding Area and maps 

provided. Need to be open riding area for Motorcycles and make a Moab 

experience for Motorize full size and UTV and ATVs!

n

In regards to your comment, the RMP has a range of possible decisions to 

make. In this case, the Alternative D decision is for Weatherman Draw to 

remain as “Limited”. 

The reason is that FLPMA instructs the BLM to give priority to designation and 

protective management of ACECs and their Resources. 

Recreational opportunities and experiences are not the primary consideration in 

an ACEC. Please see FLPA Section 102 (8) and Section 201(a) and Section 

202 (c.3) 

DRMTDK-BL13-0422-6

Travel mngt

we are asking for looping connecting trail and roads in this area GD1105. Also 

GD1011 need to be open as with the closer of this road would not let you to 

have access the State land and put you out over a mile from the state lands for 

hunting bird and big game retrieval! Also we would like GD1820 where it ends 

and make a Moab trail to connect to GD1018 for extreme 4x4 Access Road not 

maintain inter at your own risk. Same signage they use in Moab. This would give 

n

Thank you for your comment. BLM has no route identified as “GD 1105” or a 

“GD 1820” on its route inventory and cannot respond to these observations. 

However BLM staff believes that the routes in question may possibly be “GD 

1005”, and “GD 1020”.

In response, GD 1020 does not connect to GD 1018. If these are the routes in 

question, the proposed action of extending the routes can be addressed at the 
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a different area experience since it not a long ways from horse thief. We have 

the same opportunities to connect to and make loops in the area GD1013 and 

GD1012!

time of the TMA Implementation Plan. Connecting loops between GD 1013 and 

GD 1012 and GD 1005 would be an implementation level action as well since 

both routes cross into private property and appear to require easements and/or 

new construction.

DRMTDK-BL13-0424-1

Travel mngt

Desire for greater flexibility of Recreational Management Area (RMA) 

Designations to allow future development of full-size OHV recreational 

opportunities--specifically in the Acton Recreational Area and Pryor Mountain 

Areas.

n

Thank you for your comment. The BLM will develop site specific 

Implementation Plans for areas designated as Recreation Management Areas, 

(including both mentioned Acton and Pryor Mountain SRMAs) as well as 

retaining the ability to designate, or eliminate, specific routes anywhere in the 

FO.

DRMTDK-BL13-0425-1

NEPA

Of interest to MLR in the BLM's draft RMP revision is the way in which BLM will 

construct lease stipulations for oil and gas leases on split estate properties that 

have entered into a perpetual conservation easement with MLR. In those 

counties where BLM resources are governed under RMP, MLR holds 120 

separate conservation easements that represent over 190,000 acres and 325 

miles of stream frontage. Further, the majority of those easements are found in 

the Stillwater and East and West Rosebud drainages that have been identified 

by agency analysis as seeing "moderate potential" for oil and gas development. 

Particularly in these areas, many of the landowners have entered into private 

conservation easements, yet they operate on "split estate" ownership. Certainly, 

this can create some conflict between resource development and the 

conservation values. stated in each conservation easement on split properties. 

The BLM has clear authority to condition leases to protect conservation values 

found in conservation easements. As stated in the RMP revision DEIS: In 

summary, while the BLM does not have the legal authority in split estate 

situations to regulate how a surface owner manages his or her property, the 

agency does have the statutory authority to take reasonable measures to avoid 

or minimize adverse environmental impacts that may result from federally 

authorized mineral lease activity. (DEIS, Appendix G) Moreover, the Mineral 

Leasing Act specifies that "The Secretary of Interior, or for the National Forest 

lands, the Secretary of Agriculture, shall regulate all surface-disturbing activities 

conducted pursuant to any lease [including split estate] issued under this 

chapter, and shall determine reclamation and other actions as required in the 

interest of conservation of the surface resources." 30 U.S.C.§ 226(g), 1988 To 

address the issue, given the amount of private land conservation in the planning 

area as well as the emergence of drilling technology and its ability to recover 

resources while protecting conservation easement properties, MLR requests the 

BLM implement one or both of the following: 1) The BLM include a stipulation to 

prevent impacts to split estate conservation easement properties. This could be 

facilitated via a no surface occupancy stipulation that precludes development on 

easement properties, similar to the protections provided in the draft RMP on split 

estate ownership with state-owned surface. Finally, the BLM could implement a 

n Thank you for your comment. Your suggestions will be considered.
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controlled surface use stipulation that requires development to be compatible 

with the terms of the conservation easement. Under this stipulation the lessee 

and the land trust must develop and sign off on a mutually agreeable surface 

use plan before development may occur. 2) The BLM conduct an impacts 

analysis on split estate conservation easement properties. This analysis should 

identify where these lands are located and what the effects of BLM authorized 

activities would be to these lands. MLR would be happy to provide maps of all 

easements in the area that could potentially be impacted.

DRMTDK-BL13-0426-1

Edits

The structure of Billings/Pompey's Pillar DEIS makes it extremely difficult for 

reviewers to track BLM's proposed management options because they are 

inconsistent among chapters while at the same time spread out among the 

various chapter sections in piecemeal fashion. Even the basic descriptions of the 

alternatives and their priorities are missing. One is forced to wade through 

countless pages of resource descriptions for each alternative in separate 

sections, forcing the reader to jump from one section to another to understand 

the proposed management. Moreover, the Joint Association Comments on 

Billings/Pompey's Pillar DEIS/RMP pervasive inconsistencies throughout the 

documents make it impossible for reviewers to comprehend the changes in 

resource uses and management proposed by BLM under each alternative. We 

strongly recommend that BLM adopt a revised format for subsequent planning 

documents that provides resource and decision-related information in an easy to 

follow, consistent format

n Thank you for your comment. 

DRMTDK-BL13-0426-

10

NEPA

BLM has failed to explicitly describe the process of Adaptive Management it 

intends to use. While industry supports the goal of adaptive management, it will 

not be successful without the development of science-based monitoring 

protocols to assess and validate the effectiveness of federal land management 

actions, particularly with respect to regulating oil and gas development, such as 

lease stipulations and conditions of approval (COA) and to adjust management 

decisions in response to this monitoring. We recognize that adaptive 

management, if done properly, can assist land managers through monitoring to 

validate whether the assumptions underlying mitigation measures are met and 

allow needed modifications to be made accordingly. BLM needs to clearly 

articulate its adaptive management policies in the planning documents. Simply 

referencing that it may be used is inadequate

y/n 

Thank your for your comment. Please see Section 2.3.4 of this document and 

the glossary for a definition of adaptive management for a further explanation 

of adaptive management. 

DRMTDK-BL13-0426-

11

NEPA

The DEIS fails to clearly identify the management goals and objectives for each 

alternative. While Table 2-6 describes the proposed actions under each 

alternative and Table 2-7 identifies the purported environmental consequences 

by alternative, the reader is left to guess BLM's what the overall objectives are 

for each alternative. This omission needs to be addressed when preparing the 

revised draft planning documents

N Thank you for your comment. 

DR- Wildlife The basis for BLM's highly restrictive management approach appears to be N Thank you for your comment. The requisite level of information necessary to 
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MTDK-BL13-0426-

12

predicated upon the need to protect the Greater Sage-grouse. Unfortunately, 

BLM has relied upon scientific data which is flawed for a number of reasons, not 

the least of which is the inappropriate reliance upon general scientific 

conventions based upon male lek attendance, but also because it is too general 

to be extrapolated to the planning area, and because it is based upon 

development scenarios that are unlikely to occur within Montana. Moreover, 

recent findings scheduled for publication in the near future irrefutably 

demonstrate that sage-grouse are not extirpated by oil and gas activities and 

that with reasonable mitigation measures, such as limited NSO perimeters 

around active leks along with other reasonable mitigation as well as interim and 

final reclamation procedures, sage-grouse return to previously disturbed areas

make a reasoned choice among the alternatives in an EIS is based on the 

scope and nature of the proposed decisions. As the EIS analyzes land use 

planning-level decisions, which by their nature are broad in scope, the requisite 

level of data and information is more generalized in order to apply to a wideranging landscape perspective. Although the BLM realizes that more data, and 

more site specific data, could always be gathered, the baseline data utilized in 

the EIS provide the necessary basis to make informed land use plan-level 

decisions.

The BLM considered the availability of data from all sources, adequacy of 

existing data, data gaps, and the type of data necessary to support informed 

management decisions at the land-use plan level. The data needed to support 

broad-scale analysis of the BLM Billings planning area are substantially 

different than the data needed to support site-specific analysis of projects. The 

RMP/EIS data and information is presented in map and table form and is 

sufficient to support the broad scale analyses required for land use planning.

Additionally, the BLM used the most recent and best information available that 

was relevant to a land-use planning-level analysis including the Baseline 

Environmental Report ([BER]; Manier et al. 2013). The BER assisted the BLM 

in summarizing the effect of their planning efforts at a range-wide scale, 

particularly in the affected environment and cumulative impacts sections. The 

BER looked at each of the threats to greater sage-grouse identified in the Fish 

and Wildlife Service’s “warranted but precluded” finding for the species. For 

these threats, the report summarized the current scientific understanding, as of 

the BER’s publication date (June 2013), of various impacts to greater sagegrouse populations and habitats. The report also quantitatively measured the 

location, magnitude, and extent of each threat. These data were used in the 

planning process to describe threats at other levels, such as the sub-regional 

boundary and WAFWA Management Zone scale, to facilitate comparison 

between sub-regions. The BER provided data and information to show how 

management under different alternatives may meet specific plans, goals, and 

objectives.

The BLM consulted with, collected, and incorporated data from other agencies 

and sources, including but not limited to the U.S. Fish and Wildlife Service, and 

the Montana Fish, Wildlife and Parks. Additional information provided by state 

and local governments regarding socioeconomics also support the analysis in 

Chapter 4. 

As a result of these actions, the BLM gathered the necessary data essential to 
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make a reasoned choice among the alternatives analyzed in detail in the Draft 

RMP/EIS, and provided an adequate analysis that led to disclosure of the 

potential environmental consequences of the alternatives (see Chapter 4, 

Environmental Consequences and Cumulative Effects). As a result, the BLM 

has taken a “hard look,” as required by the NEPA (see 40 CFR 1502.16), at the 

environmental consequences of the alternatives in the Draft RMP/EIS to enable 

the decision maker to make an informed decision.

As noted in more detail in responses to issue statements identified elsewhere in 

the report, the BLM has complied with the myriad applicable laws, policies, and 

guidance in developing the RMP/EIS. Section 2.2, Developing the Range of 

Alternatives, of the RMP/EIS, states that all alternatives would comply with 

state and federal laws, regulations, policies, and standards, and implement 

actions originating from laws, regulations, and policies. Additionally, in Section 

1.4.2, Planning Criteria, of the Draft RMP/EIS, the BLM has a criterion stating 

that all alternatives would comply with existing laws, regulations, and policies. 

The BLM has reviewed all actions in the Proposed RMP/Final EIS and found 

them to be consistent and within the bounds of all required laws, regulations, 

and policies. Further details regarding BLM compliance with state, county, and 

local plans and policies can be found in Section 1.5, Consistency with Other 

State, County, or Local Plans, of this report.A land use planning-level decision 

is broad in scope and, therefore, does not require an exhaustive gathering and 

monitoring of baseline data. Although the BLM and the Forest Service realize 

that more data could always be gathered, the baseline data provides the 

necessary basis to make informed land use plan-level decisions. Land use 

plan-level analyses are typically broad and qualitative rather than quantitative or 

focused on site-specific actions (BLM Land Use Planning Handbook H-1601-1, 

Chapter II, A-B at 11-13 and Chapter IV, B at 29; Forest Service Handbook 

1909.12 – Land Management Planning). The BLM and the Forest Service will 

conduct subsequent project-specific NEPA analyses for projects proposed for 

implementation under the land use plan, which may include but are not limited 

to fuels treatment, habitat restoration, [etc.; list others as applicable]. The 

subsequent NEPA analyses for project-specific actions will tier to the land-use 

planning analysis and evaluate project impacts at the appropriate site-specific 

level (40 CFR 1502.20, 40 CFR 1508.28). As required by NEPA, the public will 

have the opportunity to participate in the NEPA process for site-specific actions.

DRMTDK-BL13-0426-

13

NEPA

The DEIS fails to provide any information or documentation regarding the 

purported inadequacies of current management of the BFO. We recognize that 

the RMP needs to be revisited on a somewhat regular schedule. However, all 

proposed changes need to be clearly articulated in the planning DEIS to 

illustrate why any changes may be necessary. BLM has not explained why 

N

Thank you for your comment. Please see Chapter 1, Section 1.2.2 Need for 

Revising the Existing Plan, Section 1.3 Planning Process, and Section 1.4.1 

Planning Issues. Since the Record of Decision was signed for the existing 

RMP in 1984, new data have become available, and laws, regulations, and 

policies regarding management of these public lands have changed. In 
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certain changes in management have been proposed and no information 

supporting such changes is provided in the DEIS

addition, decisions in the existing plan do not satisfactorily address all new and 

emerging issues in the Planning Area. These changes and potential 

deficiencies created the need to revise the existing plan. 

DRMTDK-BL13-0426-

14

Air

BLM chose to analyze the PSD increments, which are the amount of pollution an 

area is allowed to increase. It is also important to note that PSD increment 

analysis does NOT apply in this scenario. This analysis is wholly inappropriate 

and is being misused. On page 4-16, BLM attempts to make a clarification to this 

analysis by stating, "The following PSD analysis is not a regulatory analysis; its 

purpose is to provide context for evaluating potential air quality impacts." 

However, what is the purpose of attempting to provide "context" when the 

context being provided is inaccurate and inappropriate? While the numbers 

documented in the DEIS show exceedances of PSD increments, this type of 

analysis is inappropriate for even evaluating air quality impacts. Therefore, we 

recommend it be removed from the document. We also point out that air quality 

management falls within the jurisdiction of the MDEQ, not BLM, making it only 

MDEQ's responsibility to implement the PSD permitting program for major 

sources. It is irresponsible for BLM to apply its flawed analysis on a wide scale 

using conservative estimates in an attempt to frighten the public into believing 

these could be real impacts. It is crucial for BLM to modify its approach in the 

revised planning documents

n

As stated in Section 4.1.1.3.1, the PSD increment analysis is not a regulatory 

analysis and is presented only to provide context.

DRMTDK-BL13-0426-

16

Air

We acknowledge that it is reasonable to expect additional sources by 2015. 

However, any emissions estimates must take into account the amount of 

electrification occurring. Additionally, gas sales on the upstream side of industry 

are expected to increase significantly as pipeline availability increases. For 

example, within the last year industry has electrified hundreds of oil and gas 

wells and, as a result, no longer has natural gas lifting engines or gasoline-fired 

recycle pump engines. Furthermore, more gas is being sold from sites as the 

natural gas pipeline/processing infrastructure has been expanding, thus BLM's 

"actual" flaring data is NOT representative and are, therefore, unacceptable for 

use in extrapolating for future predictions. The DEIS also failed to take into 

account the reduction in emissions associated with the New Source 

Performance Standards (NSPS) 1 and the National Emission Standards for 

Hazardous Air Pollutants (NESHAP) 1 also known as Maximum Achievable 

Control Technology (MACT) standards. Implementation of these regulations will 

also reduce emissions in the planning area. This lack of attention to these rules 

leads to apprehension regarding BLM's commitment to accurately estimate 

emissions, and thus ambient impacts

y

Emission inventories were updated to address recent EPA regulations, 

including the NSPS and NESHAPs and are provided in Sections 4.1.2.3–

4.1.2.6 and in the Air Resource Technical Support Document and Appendix Y. 

Without commenter submission of specific data concerning electrification and/or 

the pace of infrastructure build-out relative to oil and gas development growth, 

the BLM conservatively estimated emissions based on current practices 

coupled with regulatory requirements.

DRMTDK-BL13-0426-

17

Air

We are disturbed that BLM has not defined "good" air quality or what 

"unacceptable impacts" would entail. As such, it is impossible to provide 

comments in any meaningful fashion when these terms are undefined and the 

information used to make these decisions has not and, apparently, will not be 

n

“Good” air quality summarizes the monitoring data provided in Section 3.2.1.3, 

which show that air pollutant concentrations are well below the NAAQS. An 

example of an unacceptable impact includes a violation of the NAAQS or an air 

pollutant concentration trend showing the potential for a future violation of the 
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publically vetted NAAQS.

DRMTDK-BL13-0426-

18

NEPA, 

Wildlife, oil 

and gas

The DEIS fails to provide sufficient discussion, documentation or justification for 

the proposed prohibitions of ROW on immense portions of the planning area. 

This information is a key requirement of NEPA and its omission constitutes a 

significant flaw in the analysis because it fails to consider the impacts such a 

decision would have on future oil and gas development, transportation, along 

with other activities which require ROW. Moreover, the statement that habitat 

loss can result from pipelines obviously fails to take into account that pipeline 

construction is a temporary impact and that all surface disturbance is fully 

reclaimed to BLM standards

N

Thank you for your comment. 

The BLM is required to manage the public lands on the basis of multiple use 

and sustained yield and to meet the needs of present and future generations. 

As the human population continues to increase and social values evolve, 

resource conflicts are likely to increase. More importantly, the American public 

is increasingly aware of the importance of the public lands to its well-being and 

is demanding a larger voice in resource management decisions (H-1601-1). 

Land use plans ensure that the public lands are managed in accordance with 

the intent of Congress as stated in FLPMA (43 U.S.C. 1701 et seq.), under the 

principles of multiple use and sustained yield. As required by FLPMA and BLM 

policy, the public lands must be managed in a manner that protects the quality 

of scientific, scenic, historical, ecological, environmental, air and atmospheric, 

water resource, and archaeological values; that, where appropriate, will 

preserve and protect certain public lands in their natural condition; that will 

provide food and habitat for fish and wildlife and domestic animals; that will 

provide for outdoor recreation and human occupancy and use; and that 

recognizes the Nation’s need for domestic sources of minerals, food, timber, 

and fiber from the public lands by encouraging collaboration and public 

participation throughout the planning process. Land use plans are one of the 

primary mechanisms for guiding BLM activities to achieve the mission and 

goals outlined in the Department of the Interior (DOI) Strategic Plan. (H-1601-1)

The ROW avoidance and exclusion areas have been proposed to prevent / 

avoid impacts tovarious resources. 

With regards to surface disturbance, disturbed areas may be reclaimed to BLM 

standards, but it can take sagebrush ecosystems 30 to well over 100 years to 

fully recover (Eichorn and Watts 1984, Baker 2007, Lesica et al. 2005), hence 

the need for ROW avoidance or exclusion areas. 

DRMTDK-BL13-0426-

19

Soils

The DEIS fails to provide documentation of any justification for the proposed 

increase in restrictions on slopes. For example, has it been documented that 

current activities have resulted in adverse impacts which would justify this 

change? If BLM has no evidence demonstrating that current measures are not 

successful, the proposed change is unwarranted and must be eliminated

n

Thank you for your comment. Text has been changed in Chapter 2 to address 

consistency between BLM MT/DK O&G stipulations

DRMTDK-BL13-0426-2

NEPA

Absent a sufficient and consistent description of the potential environmental 

impacts associated with each alternative directly pertaining to the Billings 

planning area, BLM has failed to meet both of the "twin purposes" of NEPA, 

understanding potential impacts and public disclosure of said impacts. See 

Baltimore Gas & Electric v. Natural Resources Defense Council, 462 U.S. 87, 97 

(1983). For this reason alone, the BLM must prepare a revised draft 

environmental impact statement. 40 C.F.R. § 1502.9(a)

N Thank you for your comment. 

DR- Water Page 4-89, 4.2.5.4.2, Impacts from Water -” "Fluid mineral development n Unfortunately, even with stipulations and BMPs designed to avoid adverse 
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MTDK-BL13-0426-

20

generally impacts water resources by increasing NPS, including increased 

erosion and sedimentation from surface disturbance and unnatural drainage 

patterns associated with roads. "COMMENT: This statement is provocative and 

ignores that existing stipulations and practices already require full protection of 

water resources. In fact, the DEIS describes BMPs to be utilized to avoid these 

very impacts in Appendix B, which specifically outlines Erosion and Sediment 

Control Practices, along with a host of other measures, designed to protect all 

aspects of water quality. Therefore, this statement is inappropriate because it 

fails to acknowledge the routine use of stipulations and other site-specific 

mitigation measures along with site-specific BMPs

impacts to water quality from various sources of development pollution, design, 

construction, and implementation flaws sometimes occur that allow for impacts 

to water resources.

Catastrophic weather events could also cause a failure of a perfectly 

constructed mitigation measure. 

The statement is not meant to be provocative, it only is meant to indicate that 

fluid mineral development does have the potential to impact water quality. The 

statement is not saying fluid mineral development ‘will have’ these impacts, the 

statement is saying, “if there is an impact, it is likely to be “by increasing NPS, 

including increased erosion and sedimentation from surface disturbance and 

unnatural drainage patterns associated with roads.”

DRMTDK-BL13-0426-

21

Paleontolog

y

The DEIS fails to specify what constitutes a "Recorded Paleontological Site" that 

would require an NSO stipulation. For instance, would this stipulation apply to 

known sites that do not contain vertebrate fossils, or non-vertebrate/plant 

remains that are common and of lower scientific interest? More specificity is 

needed to accurately assess this NSO requirement

n

Thank you for your comment. Text will be revised to define “known or recorded 

paleontological site”

Also, Please see the definitions in the potential fossil yield classification –

chapter 3 – 3.11.2.4 

DRMTDK-BL13-0426-

22

Wildlife

In many instances, the species habitat delineations in the DEIS are inconsistent 

with those identified by the Montana Department of Fish, Wildlife & Parks (FWP). 

We ask BLM to explain these discrepancies in a revised planning document, 

particularly due to the fact that the State manages most of the species for which 

habitat is identified. Such discrepancies are highly problematic for operators who 

work on both State and private lands that may be adjacent to public lands 

because two separate processes could be required for the same project if it 

crosses jurisdictional boundaries. We strongly recommend that BLM work 

closely with State agencies to eliminate the discrepancies in wildlife data and 

spatial representations utilized by BLM in the draft planning documents

n

Thank you for the comment. Several species maps were derived from MTFWP 

maps. Updated maps from the original maps may be added in the Final 

RMP/EIS. 

DRMTDK-BL13-0426-

23

Wildlife 

While the NSO, CSU, and TLS for fish and wildlife species may have been 

aggregated in maps regarding oil and gas "leasing standard stipulations" and 

"major moderate constraints," BLM failed to separately map the habitat areas 

with associated management restrictions for all species' habitat for which lease 

stipulations be imposed. In other BLM RMPs, it is routine to map habitat areas 

that may or may not include restrictions and management prescriptions 

separately from maps that illustrate the overall restrictions on future fluid mineral 

leasing. We recommend that BLM provide individual maps depicting each of the 

various habitats, along with associated land-use restrictions and special 

management areas, for all species that are discussed in the DEIS

n

Thank you for the comment. 

Individual species maps are compiled on Maps 50-57 that identify Fluid 

Minerals Standard Lease Terms and Major/Moderate Constraints, the individual 

species maps are not included.

DRMTDK-BL13-0426-

Wildlife 

BLM has failed to justify or provide any scientific documentation supporting the 

management restrictions for the black-tailed and white-tailed prairie dogs in the 

DEIS, particularly the NSO stipulation within 1/4 mile of habitat. These 

n thank you for your comment. 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-279

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24 stipulations do not correspond with the U.S. Fish and Wildlife Service's (FWS) 

recent listing determinations for the species and its conclusions about the impact 

of oil and gas development on their habitat

DRMTDK-BL13-0426-

25

Wildlife 

BLM has failed to establish why a colony is considered to be "active" if it has 

been used in the past ten years. Without a clear explanation for the ten year 

"active" definition, this restriction is unreasonable and arbitrary. For example, if a 

colony was used nine and half years prior to a proposed surface disturbance and 

has not been used since, it is reasonable to assume that the nest either has 

been abandoned or no longer contains the resource values to attract prairie 

dogs. Yet it will still be considered "active" by BLM and would trigger the 

stipulations and restrictions identified in Chapter 2, even though the area may 

never have an "active" colony again. BLM has not identified which colonies 

within the planning area have been active within the past ten years. In order to 

demonstrate that habitat can be maintained so that prairie dogs are not 

precluded from using colonies, operators must have a clear understanding of the 

location of active colonies and adequate justification that they have been in fact 

active sometime in the recent past. BLM needs to provide maps which identify 

active and inactive colonies in the revised DEIS.

n thank you for your comment. 

DRMTDK-BL13-0426-

26

Wildlife 

In addition, the language in Chapter 2 regarding the definition of "active" prairie 

dog colonies is inconsistent with Appendix C, which states that "Prairie dog 

habitat is defined as the maximum extent of areas occupied by prairie dogs at 

any time during the last 20 years" (DEIS at C-170). This inconsistency must be 

corrected in the revised DEIS

n

Thanks for the comment and agreed that there is a discrepancy in the time 

frames for prairie dog habitat. On C-170 and Glossary –page 28 definition of 

Prairie Dog Habitat is 20 years. Active Prairie dog habitat in Alternative B is 10 

years?

This discrepancy will be edited in the Final.

DRMTDK-BL13-0426-

27

Wildlife 

BLM has failed to define activities that may be considered "not detrimental" to 

the prairie dog, associated species, or their habitats in its description of 

exception criteria for NSO and CSU stipulations. Without this explanation, BLM 

may unreasonably deny exceptions for activities that may not be detrimental, 

including certain oil and gas activities. BLM must recognize that oil and gas 

development and the construction of associated infrastructure may be 

considered to be "not detrimental" to the prairie dog, associated, species, or their 

habitats due to the employment of best management practices, including efforts 

to limit surface disturbance, as well FWS' conclusions about the impacts of 

development and persistence of prairie dog towns

n thank you for your comment. 

DRMTDK-BL13-0426-

28

Wildlife BLM must also clearly identify and map black-footed ferret habitat in a revised 

DEIS n

3.7.3.5 Mammals, pages 380 and 381, describe black-tailed and white-tailed 

prairie dog acreage within the Billings Field Office. This acreage would be 

considered black-footed ferret habitat and due to the relative small acreage a 

Map was not included. According to the Glossary definition, page 5, “Blackfooted ferret habitat: a complex of prairie dog towns within 1.5 kilometers of 

each other comprising a total of 1,000 acres.” , there is not black-footed ferret 

habitat on public lands within the field office.

DR- Wildlife Page 2-43, All alternatives -” "Prior to surface disturbance, potential black-footed n With a negative black-footed ferret (BFF) examination, no restrictions would be 
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MTDK-BL13-0426-

29

ferret habitat (prairie dog colonies and complexes 80 acres or more in size and 

not designated as black-footed ferret reintroduction sites) would be examined to 

determine the absence or presence of black-footed ferrets (CSU). The findings 

of this examination could result in some restrictions to the operator's plans or 

could even preclude use and occupancy that would be in violation of the 

Endangered Species Act of 1973."COMMENT: BLM has failed to provide detail 

regarding the types of restrictions that could be placed on operator's plans 

based on the examination described above. In order for affected public lands 

users in the planning area to fully understand the impact of this management 

prescription; a revised DEIS must contain an adequate description of the type of 

restrictions that could result due to the findings of this examination

implemented for ferrets, other than protection or mitigation for the prairie dogs. 

A positive BFF finding would trigger consultation with U.S. Fish and Wildlife 

Services (USFWS), Endangered Species Office. Restrictions would be 

determined by USFWS.

DRMTDK-BL13-0426-3

Wildlife 

We find BLM's use of Greater Sage-grouse data not directly applicable to the 

planning area highly problematic and outside the requirements of NEPA. While 

we recognize NEPA allows for the best available science to be used during 

planning, the fact that none of the data referenced by BLM applies to the lands 

and habitat under the jurisdiction of Billings Field Office cannot be utilized as the 

basis for decisions, particularly given that they are based upon data derived from 

intensively developed natural gas fields that are completely uncharacteristic to 

the planning area

n

Before beginning the Billings and Pompeys Pillar National Monument RMP/EIS 

and throughout the planning effort, the BLM and the Forest Service considered 

the availability of data from all sources, adequacy of existing data, data gaps, 

and the type of data necessary to support informed management decisions at 

the land-use plan level. The data needed to support broad-scale analysis of the 

planning area are substantially different than the data needed to support sitespecific analysis of projects. The RMP/EIS data and information is presented in 

map and table form and is sufficient to support the broad scale analyses 

required for land use planning. 

The BLM and the Forest Service used the most recent and best information 

available that was relevant to a land-use planning-level analysis including the 

Baseline Environmental Report (BER; Manier et al. 2013). The BER assisted 

the BLM and the Forest Service in summarizing the effect of their planning 

efforts at a range-wide scale, particularly in the affected environment and 

cumulative impacts sections. The BER looked at each of the threats to greater 

sage-grouse identified in the Fish and Wildlife Service’s “warranted but 

precluded” finding for the species. For these threats, the report summarized the 

current scientific understanding, as of report publication date (June 2013), of 

various impacts to greater sage-grouse populations and habitats. The report 

also quantitatively measured the location, magnitude, and extent of each threat. 

These data were used in the planning process to describe threats at other 

levels, such as the sub-regional boundary and WAFWA Management Zone 

scale, to facilitate comparison between sub-regions. The BER provided data 

and information to show how management under different alternatives may 

meet specific plans, goals, and objectives. 

Additionally, the BLM and the Forest Service consulted with, collected, and 

incorporated data from other agencies and sources, including but not limited to 

the U.S. Fish and Wildlife Service and Montana Fish, Wildlife and Parks. 

As a result of these actions, the BLM and the Forest Service gathered the 

necessary data essential to make a reasoned choice among the alternatives 
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analyzed in detail in the DRMP/EIS, and provided an adequate analysis that led 

to an adequate disclosure of the potential environmental consequences of the 

alternatives. As a result, the BLM and the Forest Service have taken a “hard 

look,” as required by the NEPA, at the environmental consequences of the 

alternatives in the DRMP/EIS to enable the decision maker to make an 

informed decision. Finally, the BLM and the Forest Service have made a 

reasonable effort to collect and analyze all available data. 

The requisite level of information necessary to make a reasoned choice among 

the alternatives in an EIS is based on the scope and nature of the proposed 

decision. The baseline data provided in [Chapter XX] and various appendices 

including [cite appendix(ces)] in the [name of particular amendment] is sufficient 

to support, at the general land use planning-level of analysis, the environmental 

impact analysis resulting from management actions presented in the 

DRMP/EIS. 

A land use planning-level decision is broad in scope and, therefore, does not 

require an exhaustive gathering and monitoring of baseline data. Although the 

BLM and the Forest Service realize that more data could always be gathered, 

the baseline data provides the necessary basis to make informed land use 

plan-level decisions. Land use plan-level analyses are typically broad and 

qualitative rather than quantitative or focused on site-specific actions (BLM 

Land Use Planning Handbook H-1601-1, Chapter II, A-B at 11-13 and Chapter 

IV, B at 29; Forest Service Handbook 1909.12 – Land Management Planning). 

The BLM and the Forest Service will conduct subsequent project-specific NEPA 

analyses for projects proposed for implementation under the land use plan, 

which may include but are not limited to fuels treatment, habitat restoration, 

[etc.; list others as applicable]. The subsequent NEPA analyses for projectspecific actions will tier to the land-use planning analysis and evaluate project 

impacts at the appropriate site-specific level (40 CFR 1502.20, 40 CFR 

1508.28). As required by NEPA, the public will have the opportunity to 

participate in the NEPA process for site-specific actions.

DRMTDK-BL13-0426-

30

Wildlife 

BLM has provided no justification for the management restrictions for the 

mountain plover in the DEIS, particularly the NSO stipulation within 1/4 mile of 

plover habitat. These stipulations do not correspond with the FWS' recent listing 

determinations for the species and its conclusions about the impact of oil and 

gas development on their habitat

n

Page 27776, Federal Register Notice, Vol. 76, No. 92, May 12, 2011, for 

Mountain Plover also states,” We expressed concern over the rising trend in oil, 

gas, and mineral exploration in mountain plover breeding habitat and, while we 

suggested habitat changes might not be detrimental, we cautioned that roads 

and human disturbance could impact mountain plover breeding.” 

DRMTDK-BL13-0426-

31

Wildlife 

Moreover, we are unable to locate in the DEIS any scientific justification that an 

additional 1/4 buffer around mountain plover habitat, on top of already 

designating habitat areas as NSO, is necessary to protect the species during 

nesting season. In addition, the proposed areas where NSO stipulations will 

apply in the planning area are wildly inconsistent throughout the EIS. Language 

in Chapter 2, which requires an NSO stipulation for areas within 1/4 mile of 

n

The 1⁄4 mile buffer’s objective is to protect nesting activities during the nesting 

period from April 1 – July 15th. The NSO’s objective is to protect mountain 

plover habitat. These are two separate stipulations, one to be used for nesting 

activity, and the other for longer term habitat protection. 

Any inconsistencies will be edited in the Final RMP/EIS.
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mountain plover habitat, is inconsistent with language in Chapter 4 and 

Appendix H, which state that "Surface use is prohibited within 1/4 mile of active 

mountain plover nest sites" (DEIS at 4-441 and H-25). Further, Appendix C 

makes no mention of the 1/4 mile area within habitat, stating only "Surface 

occupancy and use is prohibited within mountain plover habitat" (DEIS at C165). These broad inconsistencies must be corrected in a revised DEIS

DRMTDK-BL13-0426-

32

Wildlife 

Page 2-43, Alternative D -” "NSO -” within 1/2 mile of ferruginous hawk nest sites 

which have been active within the past 2 years. "COMMENT: The DEIS fails to 

scientifically document the need for this buffer to significantly exceed the FWS's 

recommended 200 meter (660 feet) buffer around active hawk nests. 

Accordingly, the buffers in the revised DEIS need to be modified to comport with 

FWS guidelines

n

According to the following link from USFWS, Wyoming Endangered Species 

office: 

http://www.fws.gov/wyominges/Pages/Species/Species_SpeciesConcern/Rapto

rs.html , the Spatial buffer for ferruginous hawks is 1 mile from March 15- July 

31. 

DRMTDK-BL13-0426-

33

Wildlife 

The proposed restrictions on oil and gas development do not correspond to the 

current status of big game populations in the planning area. In Chapter 3, BLM 

explains the relative stability of most species in the planning area, despite a 

wide-ranging array of threats (DEIS at 3-66 and 3-67). Nevertheless, BLM 

proposes to apply many unwarranted restrictions on future oil and gas 

development in big game habitat, including parturition areas and winter range. 

Most notably, the Preferred Alternative seasonally prohibits surface occupancy 

on 258,592 acres of big game winter range and would apply CSU stipulations on 

another 266,819 acres. Given the stability of big game populations, what is 

BLM's scientific justification for these stipulations? We strongly recommend that 

BLM reconsider its proposal to impose the proposed stipulations for big game 

and develop more practical stipulations that correspond with current population 

figures, along with valid existing lease rights, and balance responsible multiple 

use-development with protection and conservation of species' and their the 

habitat

n

The goals, objectives, items in “Management Common” and Alternatives 

described in Wildlife Habitat and Special Status Species - Chapter 2 are a 

compilation of several years of research review and public scoping. Several 

references apply to the impacts of surface disturbing and disruptive activities to 

big game along with BMPs for the protection of wildlife.

DRMTDK-BL13-0426-

34

Wildlife 

While Chapter 4 includes a brief explanation of the differences between CAPS 

SCORE 1 (moderate value) and CAPS score 2 (high value) winter range, the 

stipulations in Appendix C or Chapter 2 fail to correspond to Map 15, which only 

indicates those areas that have 'high' and 'moderate' values for big game winter 

range. We recommend that BLM make consistent the stipulations in Appendix C 

and Map 15 in a revised DEIS by indicating that the high value habitat 

represents CAPS SCORE 2 and moderate value habitat represents CAPS 

SCORE 1 in Map 15. In addition, while Appendix C indicates the stipulations that 

will apply to CAPS SCORE 1 and CAPS SCORE 2 areas, Chapter 2 does not. 

This must be corrected in a revised DEIS

n

Thank you for the comment. Revisions will be made in Chapter 2 and Map 15.

A summary description of the CAPS (Crucial Area Planning System) is included 

in Appendix H, pages H-37- H-39. Other narrative has been added to this 

section to explain that this data will be used when MTFWP data does not have 

Crucial Winter Ranges identified for a specific species. Designated Crucial 

Winter Ranges will be used in lieu of CAPS data when the data is available. 

Any references to CAPS data will be updated when Crucial Winter Ranges are 

designated.

DRMTDK-BL13-0426-

35

Wildlife 

Page 2-46, Alternative D -” "TL -” December 1 to March 31 within big game 

winter range. "COMMENT: The period for which timing limitations will apply is 

inconsistent in Chapter 2 and Appendix C. While Chapter 2 states that TL 

stipulations will apply from December 1 to March 31, Appendix C states that TL 

n

Thank you for the comment. Consistency revisions will be made in the Final 

RMP.
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stipulations will apply from December 1 to May 15. Again, the stipulations are 

inconsistent among the chapters and the appendices in the DEIS and must be 

corrected in a revised DEIS

DRMTDK-BL13-0426-

36

Wildlife 

Page 2-45, Alternative D -” "TL -” April 1 to July 1 within established big game 

parturition habitat; CSU -” within big game parturition habitat. "COMMENT: BLM 

failed to provide maps of big game parturition habitat in the DEIS. As such, we 

are unable to determine the actual impact timing limitations in these areas will 

have on future oil and gas development in the planning area. BLM must provide 

individual maps of these areas in a revised DEIS

n

Thank you for your comment. Parturition habitat has not been mapped or 

identified at this time for all species. In the future, as these areas are 

inventoried and identified by Montana Fish, Wildlife, and Parks they will be 

mapped. 

DRMTDK-BL13-0426-

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Wildlife

BLM's proposal to prohibit geophysical exploration in big horn sheep habitat is 

unfounded and inconsistent with BLM Manual 3150 (L)(.11), Onshore Oil and 

Gas Geophysical Exploration Surface Management Requirements, which 

classifies geophysical activities as a "casual use". Casual use is defined in the 

Manual as "Activities that do not cause any appreciable disturbance or damage 

to the public land or resources or existing improvements on that land are 

considered casual use." In fact, the Manual clearly recommends that exploration 

in closed areas as well as in areas subject to no surface occupancy stipulations 

be allowed because "geophysical data collected from areas closed for oil and 

gas development may provide additional insights into the interpretation of data 

collected in other areas that are open to development." We recommend that 

BLM revise its management approach for geophysical activities in all sections of 

the DEIS to comport with established Bureau policy

N

Thank you for your comment. On BLM managed public land within the Billings 

Field Office, the land identified as bighorn sheep habitat is also WSA (No 

Lease), ACEC (NSO), or lands with wilderness characteristics (no lease), so 

the restrictions for bighorn sheep habitat are consistent with the area.

DRMTDK-BL13-0426-

38

Fisheries 

What is BLM's justification for the requirement of an NSO stipulation for future oil 

and gas leases within 1/4 miles of reservoirs with fisheries and 1/2 mile within 

Class I streams? Moreover, BLM has failed to adequately demonstrate how or 

why oil and gas development within these distances would negatively impact 

water quality or fisheries in Chapters 3 or 4. Historic BLM buffers for oil and gas 

development around stream and river channels and banks have been limited to 

300 to 500 feet and have proven to be a reliable mitigation measure to protect 

fish and water resources. Furthermore, BLM would allow oil and gas leasing with 

a CSU stipulation within 300 feet of riparian and wetland areas in this DEIS (p. 2-

47). It is irrational to assume that a 300 foot CSU buffer as applied to riparian 

and wetland areas would not provide the same level of protection to reservoirs 

and streams. Additionally, BLM has not mapped these reservoirs and apparently 

does not know the actual acreage that will be impacted by the 1/4 mile buffer 

around reservoirs (DEIS at 4-441)

n

The NSO stipulation of 1⁄4 mile for reservoirs with fisheries has been in place 

since the 1984 RMP ROD. The justification is to provide an increased level of 

protection to these valuable resources. It is true, the BiFO does not have a 

complete inventory of reservoirs on public lands, nor solid records of fish 

presence/absence in identified reservoirs. However, during NEPA analysis for 

any O&G leasing, reservoirs would be identified and classified as fish bearing 

or not.

The 300 foot setback stipulated for riparian areas, waterbodies, floodplains and 

wetlands is the minimal setback BLM believes would meet the objective of 

protecting water quality and riparian habitat. As other resources are put on the 

table (YCT, sensitive species, critical habitats), BLM increases the set back to 

offer a further level of protection, as supported by the fact that increased spatial 

separation would lower the chances pollutants would impact a given water 

body.

Furthermore, Waivers, Exclusions and Modifications may be granted to a 

developer if said developer can produce a BLM approved plan that exhibits the 

action would not have unacceptable adverse impacts on a given resource.
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DRMTDK-BL13-0426-

39

Wildlife

BLM does not indicate which of the habitats identified in Map 25 will be 

designated as TL in the DEIS. Map 25 indicates that Sprague's Pipit distribution 

is found in optimal, medium, low, and unsuitable habitat areas, but Appendix C 

and Chapter 2 only state that TL stipulations will apply simply to 'habitat.' BLM 

must clearly explain which of these habitat areas will be subject to TL 

stipulations in the revised DEIS

n

Thanks for the comment. 

Sprague’s pipit habitat will be defined as ”Optimal and Moderate” Suitable 

Habitat on Map 25.

DRMTDK-BL13-0426-4

NEPA

BLM has failed to explain its rationale for selecting the Preferred Alternative. It is 

inadequate for BLM to simply identify a preferred alternative without providing 

detailed analysis that supports WHY such an alternative is in the best interest of 

the agency and public. According to the BLM's Land Use Planning Manual and 

Land Use Planning Handbook, II.A.7, pg. 22 (Rel. 1-1693 03/11/05), BLM must 

identify how the Preferred Alternative best meets the multiple use and sustained 

yield requirements of FLPMA. This lack of meaningful analysis constitutes a fatal 

flaw in the DEIS. Therefore, in accordance with 40 CFR 1502.0(a), we find the 

DEIS "inadequate as to preclude meaningful analysis" and recommend the 

agency prepare and circulate a revised draft Joint Association Comments on 

Billings/Pompey's Pillar DEIS/RMP which provides the analysis necessary to 

support each of the management alternatives, including the preferred alternative

N

Thank your for your comment. Rationale for selecting the Preferred Alternative 

is presented in Chapter 2, Introduction.

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The NTT Report is not supported by the Western Association of Fish and Wildlife 

Agencies (WAFWA) as BLM's sole source of Sage-grouse management 

direction. In a letter sent to the Interior Secretary on May 16, 2013 WAFWA 

member states made it clear that they never endorsed the sole use of the NTT 

or any other scientific publication to determine appropriate management of 

Sage-grouse habitat. Rather, they believe that a variety of peer-reviewed 

publications which collectively provide the best available science for sagegrouse should have been used by BLM as the basis for conserving the Sagegrouse, thereby avoiding a listing under the Endangered Species Act (ESA). 

WAFWA went on to recommend that management and regulatory mechanisms 

be based upon the best available science which would provide the best strategy 

for near- and long-term management of sage-grouse and provides the best 

opportunity for precluding the need to list the species under the ESA

n

The NTT report (or BER, or COT) is not the sole source of management 

decisions for the range of alternatives. A National Technical Team (NTT) was 

formed as an independent, science-based team to ensure that the best 

information about how to manage the greater sage-grouse is reviewed, 

evaluated, and provided to the BLM and the Forest Service in the planning 

process. The group produced a report in December 2011 that identified 

science-based management considerations to promote sustainable greater 

sage-grouse populations. The NTT is staying involved as the BLM and the 

Forest Service work through the Strategy to make sure that relevant science is 

considered, reasonably interpreted, and accurately presented; and that 

uncertainties and risks are acknowledged and documented. 

A baseline environmental report, titled Summary of Science, Activities, 

Programs, and Policies That Influence the Rangewide Conservation of Greater 

Sage-grouse (Centrocercus urophasianus) (referred to as the BER), was 

released on June 3, 2013, by the U.S. Geological Survey. The peer-reviewed 

report summarizes the current scientific understanding about the various 

impacts to greater sage-grouse populations and habitats and addresses the 

location, magnitude, and extent of each threat. The BER does not provide 

management options. The report is being used by the BLM and the Forest 

Service in our efforts to develop regulatory mechanisms and improve our 

conservation efforts of the greater sage-grouse and its habitat to reduce the 

potential for listing it under the Endangered Species Act. The data for this report 

were gathered from BLM, Forest Service, and other sources and were the "best 
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available" at the range-wide scale at the time collected. The report provides a 

framework for considering potential implications and management options, and 

demonstrates a regional context and perspective needed for local planning and 

decision-making.

In March 2012, the FWS initiated a collaborative approach to develop rangewide conservation objectives for the greater sage-grouse to inform the 2015 

decision about the need to list the species and to inform the collective 

conservation efforts of the many partners working to conserve the species. In 

March 2013, this team of State and FWS representatives, released the 

Conservation Objectives Team (COT) report based upon the best scientific and 

commercial data available at the time that identifies key areas for greater sagegrouse conservation, key threats in those areas, and the extent to which they 

need to be reduced for the species to be conserved. The report serves as 

guidance to Federal land management agencies, State greater sage-grouse 

teams, and others in focusing efforts to achieve effective conservation for this 

species.

The range of alternatives is based upon analysis of public scoping comments 

as well as information provided in the NTT report, the BER, the COT report, and 

State management plans. The alternatives represent different degrees of and 

approaches to balancing resources and resource use among competing human 

interests, land uses, and the conservation of natural and cultural resource 

values, while sustaining and enhancing ecological integrity across the 

landscape, including plant, wildlife, and fish habitat.

Greater sage-grouse conservation measures in A Report on National Greater 

Sage-grouse Conservation Measures (NTT 2011) were used to form BLM and 

the Forest Service management direction under at least one alternative 

(Alternative B and portions of D), which is consistent with the direction provided 

in BLM Washington Office Instruction Memorandum 2012-044 (the BLM must 

consider all applicable conservation measures developed by the NTT in at least 

one alternative in the land use planning process). 

Additionally, all alternatives considered within this planning process are 

consistent with conservation measures and objectives outlined in the COT 

Report and follow the basic principles of: (1) avoiding the impact of an activity; 

(2) minimizing impacts by limiting the degree of activity; and (3) mitigating for an 

impact by improving or enhancing greater sage-grouse habitat. Each of the 

alternatives considers different means for accomplishing this strategy. For 

example, some alternatives place greater emphasis on avoidance of impacts, 

whereas other alternatives place more emphasis on minimization and 

mitigation.

While there was consistent direction provided in alternative develop, such as 

BLM WO IM 2012-044, variation across sub-regionals was needed to 
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accommodate the local issues and specific state and Forest Service 

requirements.

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Wildlife

Another major fundamental concern the signatories to this letter wish to raise is 

the inherent flaw in BLM's basic assumptions, due in part to the flawed 

recommendations contained in the NTT report, which fail to recognize that the 

level of disturbance associated with a well is not a constant throughout its life. 

The highest level of surface disturbance associated with oil and gas 

development occurs primarily during the construction, drilling and completion 

phases, which can last a little as a day or two up to a few months, depending 

upon the time it takes to complete the well. Once a well goes into production, 

these activities subside dramatically and only regular monitoring and 

maintenance of the well are required. Shortly after well completion, the operator 

typically begins interim reclamation actions designed to partially restore any 

impacted habitat. This partial reclamation will remain in effect until the well has 

been depleted. Upon conclusion of production activity, the operator will then 

move forward with plugging and abandonment procedures, which also includes 

final reclamation that will ultimately result in full restoration of the site and its 

return to productive habitat

n

Thank you for your comment. The NTT report (or BER, or COT) is not the sole 

source of management decisions for the range of alternatives. A National 

Technical Team (NTT) was formed as an independent, science-based team to 

ensure that the best information about how to manage the greater sage-grouse 

is reviewed, evaluated, and provided to the BLM and the Forest Service in the 

planning process. The group produced a report in December 2011 that 

identified science-based management considerations to promote sustainable 

greater sage-grouse populations. The NTT is staying involved as the BLM and 

the Forest Service work through the Strategy to make sure that relevant 

science is considered, reasonably interpreted, and accurately presented; and 

that uncertainties and risks are acknowledged and documented. 

A baseline environmental report, titled Summary of Science, Activities, 

Programs, and Policies That Influence the Rangewide Conservation of Greater 

Sage-grouse (Centrocercus urophasianus) (referred to as the BER), was 

released on June 3, 2013, by the U.S. Geological Survey. The peer-reviewed 

report summarizes the current scientific understanding about the various 

impacts to greater sage-grouse populations and habitats and addresses the 

location, magnitude, and extent of each threat. The BER does not provide 

management options. The report is being used by the BLM and the Forest 

Service in our efforts to develop regulatory mechanisms and improve our 

conservation efforts of the greater sage-grouse and its habitat to reduce the 

potential for listing it under the Endangered Species Act. The data for this report 

were gathered from BLM, Forest Service, and other sources and were the "best 

available" at the range-wide scale at the time collected. The report provides a 

framework for considering potential implications and management options, and 

demonstrates a regional context and perspective needed for local planning and 

decision-making.

In March 2012, the FWS initiated a collaborative approach to develop rangewide conservation objectives for the greater sage-grouse to inform the 2015 

decision about the need to list the species and to inform the collective 

conservation efforts of the many partners working to conserve the species. In 

March 2013, this team of State and FWS representatives, released the 

Conservation Objectives Team (COT) report based upon the best scientific and 

commercial data available at the time that identifies key areas for greater sagegrouse conservation, key threats in those areas, and the extent to which they 

need to be reduced for the species to be conserved. The report serves as 

guidance to Federal land management agencies, State greater sage-grouse 

teams, and others in focusing efforts to achieve effective conservation for this 

species.
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The range of alternatives is based upon analysis of public scoping comments 

as well as information provided in the NTT report, the BER, the COT report, and 

State management plans. The alternatives represent different degrees of and 

approaches to balancing resources and resource use among competing human 

interests, land uses, and the conservation of natural and cultural resource 

values, while sustaining and enhancing ecological integrity across the 

landscape, including plant, wildlife, and fish habitat. 

Greater sage-grouse conservation measures in A Report on National Greater 

Sage-grouse Conservation Measures (NTT 2011) were used to form BLM and 

the Forest Service management direction under at least one alternative , in the 

case of the Billings and Pompey Pillar RMP/EIS – Alternative B and portions of 

Alternative D, which is consistent with the direction provided in BLM 

Washington Office Instruction Memorandum 2012-044 (the BLM must consider 

all applicable conservation measures developed by the NTT in at least one 

alternative in the land use planning process). 

Additionally, all alternatives considered within this planning process are 

consistent with conservation measures and objectives outlined in the COT 

Report and follow the basic principles of: (1) avoiding the impact of an activity; 

(2) minimizing impacts by limiting the degree of activity; and (3) mitigating for an 

impact by improving or enhancing greater sage-grouse habitat. Each of the 

alternatives considers different means for accomplishing this strategy. For 

example, some alternatives place greater emphasis on avoidance of impacts, 

whereas other alternatives place more emphasis on minimization and 

mitigation.

While there was consistent direction provided in alternative develop, such as 

BLM WO IM 2012-044, variation across sub-regionals was needed to 

accommodate the local issues and specific state and Forest Service 

requirements. 

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Wildlife

Table 2-5 presents several different classifications of sage-grouse lease terms 

and stipulations. The information contained in Appendix C (Alternative D) is 

completely inconsistent with that presented in Table 2-5. For example, Table 2-

5 discusses timing limitation stipulations for greater sage-grouse winter range 

within 2 miles of a lek from December 1 to March 1. However, Appendix C 

(Alternative D -” Page C-184) states "Surface use is prohibited within sage 

grouse winter range from December 1 through March 1. Sage grouse winter 

ranges not identified, due to lack of inventories, are delineated by a 3 mile buffer 

from lek sites." Such inconsistencies make it impossible to provide reasoned 

comments on BLM's proposed action. Please clarify. The admission that BLM 

has been unable to rely upon an existing inventory which clearly identifies sagegrouse winter ranges relates to the very concern raised at the beginning of these 

comments. BLM does not currently possess the data required to make land 

n

Thank you for the comment. The discrepancies have been noted and revisions 

are being made in the Final RMP/EIS to make consistent recommendations 

throughout the document. 
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management decisions. Table 2-5 discusses timing limitation stipulations for 

greater sage grouse nesting habitat within 3 miles of a lek from March 1 to June 

15; and for "now oil and gas leases" in greater sage-grouse habitat. However, 

Appendix C (Appendix D -” Page C-189) states "Sage Grouse Nest Areas 

(Restoration Areas and General Habitat Areas) - surface use is prohibited from 

March 1 through June 30 within 3 miles of sage grouse leks. This stipulation 

does not apply to operation and maintenance of production facilities." Is it June 

15 or June 30? Does this also mean to apply only to "new oil and gas leases" as 

alluded to in Table 2-5?

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NEPA

We strongly object to current management being used as the baseline for 

determining potential environmental consequences when compared to other 

alternatives. Alternative A is far from a baseline because it reflects already 

implemented prescriptive management decisions and restrictive lease 

stipulations. We question why BLM did not determine the effectiveness of the 

measures currently in place based upon the baseline data collected before 

current management was implemented. In so doing, BLM would get a picture of 

how current management is actually working. Clearly, BLM is utilizing this 

methodology to arbitrarily "raise the bar" in order to rationalize future 

management options that are in reality unjustifiable

N

Thank your for your comment. 

When the proposed action involves updating an adopted management plan, the 

no-action alternative is the continuation of the current management plan. 

The baseline is a description of the affected environment at a fixed point in 

time, whereas the no-action alternative assumes that other things will happen to 

the affected environment even if the proposed action does not occur.

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Wildlife

Throughout the Affected Environment discussion regarding sage-grouse, much 

of the information presented is based on studies of Sage Grouse Management 

Zone 1 (MZ1), which includes northeastern Wyoming and far western North and 

South Dakota. This broader scale may or may not be directly applicable to the 

Billings/Pompey's Pillar planning area. The discussion should be refined to the 

Billings/Pompey's Pillar planning area consistent with the direction provided on 

Page 3-1. Individual comments along this same vein are made below reflecting 

this concern as it applies to specific topics. Although analysis of MZ1 (or MZ2) 

would be appropriate as a study area for analysis of cumulative impacts to sagegrouse (see comments directed to Cumulative Effects below), potential direct 

and indirect impacts to sage-grouse and sage-grouse habitat resulting from the 

RMP should address conditions and potential direct and indirect impacts specific 

to the Billings/Pompey's Pillar planning area

n

Habitat in MZ1 is comparable throughout the Eastern Montana and NE 

Wyoming area. The Billings Field Office only has a small area south of Bridger, 

MT. to the Wyoming state line, that is within MZ2. BLM considered that habitat 

is very similar between the two management zones and analyzed them as one 

entity for consistency. From page 3-86, - “descriptions of MZ1 are mostly the 

same as those that would be described for the northern portion of MZ2 found in 

the planning area.”

Currently, a research project on sage-grouse in MZ2 is being conducted. Local 

management considerations will be developed based on the findings of this 

research. 

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Wildlife

It is obscure how the management directives in the planning area relate to the 

designations of Management Zone 1 (MZ1) and Management Zone 2 (MZ2). If 

the issues and descriptions are mostly the same for MZ1 and MZ2, what is the 

purpose of separating MZ1 and MZ2 into different management zones? The text 

on pages 3-86 and 3-87 describes the ecology and flora of MZ1 but does not 

address the flora of MZ2, in which the majority of sage-grouse habitat in the 

planning area is located. Because the management zones are separated on the 

basis of floristic provinces, it would be expected that the flora would differ 

between the two zones. How does the differing flora in MZ1 and MZ2 affect 

n

Thank you for your comment. Habitat in MZ1 is comparable throughout the 

Eastern Montana and NE Wyoming area. The Billings Field Office only has a 

small area south of Bridger, MT. to the Wyoming state line, that is within MZ2. 

BLM considered that habitat is very similar between the two management 

zones and analyzed them as one entity for consistency. From page 3-86, -

“descriptions of MZ1 are mostly the same as those that would be described for 

the northern portion of MZ2 found in the planning area.”

Currently, a research project on sage-grouse in MZ2 is being conducted. Local 

management considerations will be developed based on the findings of this 
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proposed management of sage-grouse in the planning area? The text on page 

88 and 89 continue to expand on the ecological characteristics of MZ1 in relation 

to fire ecology and grazing effects on sage-brush habitat, noting how MZ1 differs 

from other management zones. Similarly, effects of energy development in MZ1 

are addressed in detail, but the relationship of the effects of energy development 

in MZ1 to the planning area in general and MZ2 in particular are not addressed. 

Please correct this

research. 

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Wildlife 

Page 3-87, "Greater sage-grouse populations have declined in portions of the 

MZ1 through wholesale loss of habitat as well as through impacts to birds on the 

remaining habitat through disturbance and direct mortality. "COMMENT: What is 

the source of this information and to which parts of the Billings/Pompey's Pillar 

planning area does this statement apply? What are the sources of direct 

mortality in the Billings/Pompey's Pillar planning area (or outside of the planning 

area) that have caused declines sage-grouse in populations? At the population 

level it is very difficult to ascribe population declines to direct mortality. 

Populations are cyclic and influenced by many factors including weather. The 

report by Samson et al (2004) is simply a general discussion of birds associated 

with prairie grassland habitats in the Great Plains. Although the past and current 

effects of management in parts of MZ1 are addressed in this RMP/EIS, the 

influence of these factors on sage-grouse in the Billings/Pompey's Pillar planning 

area (specifically) is unclear. What is the status of sage-grouse populations in 

Billings/Pompey's Pillar planning area? The draft RMP/EIS seems to equate 

Sage-Grouse MZ1 with the planning area (even though it states sage grouse 

habitat within the planning areas lies in MZ2), but does not present a rationale 

for how the MZ2 planning area is similar or dissimilar to the MZ1 planning area. 

Much of the discussion hinges on information gathered on a broader scale, 

which may or may not have direct applicability to the Billings/Pompey's Pillar 

planning area (i.e., MZ1 includes populations and subpopulations of sagegrouse in both northeastern Wyoming or far western North and South Dakota). 

Please clarify the above, and provide a more robust discussion of the 

Billings/Pompey's Pillar planning area specifically

n

Refer to the DRMP, Ch. 3, pgs. 3-85 and 86 for BIFO current sage-grouse 

population information. Habitat threats are described on pg. 3-85. These 

habitat threats can be directly related to long term mortality of sage-grouse. 

Habitat in MZ1 is comparable throughout the Eastern Montana and NE 

Wyoming area. The Billings Field Office only has a small area south of Bridger, 

MT. to the Wyoming state line, that is within MZ2. BLM considered that habitat 

is very similar between the two management zones and analyzed them as one 

entity for consistency. From page 3-86, - “descriptions of MZ1 are mostly the 

same as those that would be described for the northern portion of MZ2 found in 

the planning area.”

Currently, a research project on sage-grouse in MZ2 is being conducted. Local 

management considerations will be developed based on the findings of this 

research. Refer to Ch. 3, pgs. 3-85 and 86 for BIFO current sage-grouse 

population information. Habitat threats are described on pg. 3-85. These 

habitat threats can be directly related to long term mortality of sage-grouse. 

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Wildlife 

The publication of Samson et al (2004) does not address sagebrush ecosystems 

in Sage- Grouse MZ1. This paper addresses prairie grasslands in the Great 

Plains, which represents a much larger area. Nor does Samson et al (2004) 

differentiate between prairie grasslands and sagebrush steppe. It is necessary 

for BLM to clearly present information on (quantify) the amount of sagebrush 

habitat that has been converted to agricultural uses within the Billings/Pompey's 

Pillar planning area specifically. The DEIS seems to equate Sage-Grouse MZ1 

with the Billings/Pompey's Pillar planning area, but does not present a rationale 

for how MZ1 is similar or dissimilar to the planning area. As discussed above, 

MZ1 includes populations and subpopulations of sage-grouse in both 

n

A discussion of CRP acreage and trends statewide is included on pages 4-287 

and 288 of the DRMP. Data comparing agricultural uses specific to the field 

office and sage-grouse management zones is not available.
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northeastern Wyoming or far western North and South Dakota

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Page 3-88, "Individual species have different thresholds of fragmentation 

tolerance; greater sagegrouse have large spatial requirements and eventually 

disappear from landscapes that no longer contain large patches of habitat while 

smaller birds like Sprague's pipit can persist in landscapes with smaller patches 

of habitat because their spatial requirements are smaller." COMMENT: BLM fails 

to provide any citation for its information regarding patch size thresholds for 

sage-grouse. This concept has important management implications and patch 

size thresholds for sage-grouse must be identified in order to avoid habitat 

fragmentation impacts. We recommend this information be included in revised 

planning documents

n

thank you for your comment. Before beginning the Billings and Pompeys Pillar 

National Monument RMP/EIS and throughout the planning effort, the BLM and 

the Forest Service considered the availability of data from all sources, 

adequacy of existing data, data gaps, and the type of data necessary to support 

informed management decisions at the land-use plan level. The data needed to 

support broad-scale analysis of the planning area are substantially different 

than the data needed to support site-specific analysis of projects. The RMP/EIS 

data and information is presented in map and table form and is sufficient to 

support the broad scale analyses required for land use planning. 

The BLM and the Forest Service used the most recent and best information 

available that was relevant to a land-use planning-level analysis including the 

Baseline Environmental Report (BER; Manier et al. 2013). The BER assisted 

the BLM and the Forest Service in summarizing the effect of their planning 

efforts at a range-wide scale, particularly in the affected environment and 

cumulative impacts sections. The BER looked at each of the threats to greater 

sage-grouse identified in the Fish and Wildlife Service’s “warranted but 

precluded” finding for the species. For these threats, the report summarized the 

current scientific understanding, as of report publication date (June 2013), of 

various impacts to greater sage-grouse populations and habitats. The report 

also quantitatively measured the location, magnitude, and extent of each threat. 

These data were used in the planning process to describe threats at other 

levels, such as the sub-regional boundary and WAFWA Management Zone 

scale, to facilitate comparison between sub-regions. The BER provided data 

and information to show how management under different alternatives may 

meet specific plans, goals, and objectives. 

Additionally, the BLM and the Forest Service consulted with, collected, and 

incorporated data from other agencies and sources, including but not limited to 

the U.S. Fish and Wildlife Service and Montana Fish, Wildlife and Parks. 

As a result of these actions, the BLM and the Forest Service gathered the 

necessary data essential to make a reasoned choice among the alternatives 

analyzed in detail in the DRMP/EIS, and provided an adequate analysis that led 

to an adequate disclosure of the potential environmental consequences of the 

alternatives. As a result, the BLM and the Forest Service have taken a “hard 

look,” as required by the NEPA, at the environmental consequences of the 

alternatives in the DRMP/EIS to enable the decision maker to make an 

informed decision. Finally, the BLM and the Forest Service have made a 

reasonable effort to collect and analyze all available data. 

The requisite level of information necessary to make a reasoned choice among 

the alternatives in an EIS is based on the scope and nature of the proposed 

decision. The baseline data provided in [Chapter XX] and various appendices 
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including [cite appendix(ces)] in the [name of particular amendment] is sufficient 

to support, at the general land use planning-level of analysis, the environmental 

impact analysis resulting from management actions presented in the 

DRMP/EIS. 

A land use planning-level decision is broad in scope and, therefore, does not 

require an exhaustive gathering and monitoring of baseline data. Although the 

BLM and the Forest Service realize that more data could always be gathered, 

the baseline data provides the necessary basis to make informed land use 

plan-level decisions. Land use plan-level analyses are typically broad and 

qualitative rather than quantitative or focused on site-specific actions (BLM 

Land Use Planning Handbook H-1601-1, Chapter II, A-B at 11-13 and Chapter 

IV, B at 29; Forest Service Handbook 1909.12 – Land Management Planning). 

The BLM and the Forest Service will conduct subsequent project-specific NEPA 

analyses for projects proposed for implementation under the land use plan, 

which may include but are not limited to fuels treatment, habitat restoration, 

[etc.; list others as applicable]. The subsequent NEPA analyses for projectspecific actions will tier to the land-use planning analysis and evaluate project 

impacts at the appropriate site-specific level (40 CFR 1502.20, 40 CFR 

1508.28). As required by NEPA, the public will have the opportunity to 

participate in the NEPA process for site-specific actions.

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Wildlife

While the DEIS addresses grazing in MZ1, there is no specific discussion of 

grazing and the associated range condition within sage-grouse habitats in the 

Billings planning area. Water developments and associated West Nile virus are 

addressed for MZ1 but again, no mention is made of whether or how West Nile 

virus has affected sage-grouse in the Billings planning area, specifically. Absent 

information related directly to the BFO, this statement is unfounded. The revised 

planning documents must directly discuss how grazing and West Nile virus have 

impacted the planning area

n

please see table 3-16 which addresses acres/grazing allotments meeting 

standards and guides. Research on West Nile virus in this Field Office area 

is very limited. West Nile virus was first detected in this study area in central 

Montana in August 2005. West Nile virus was likely a major contributor to the 

decrease in survival observed in this study between August 2004 (0.94 to 0.98) 

and August 2005 (0.84 to0.94). (Breeding Ecology, Survival Rates, and Causes 

of Mortality of Hunted and Nonhunted Greater Sage-grouse in Central Montana, 

MSU Masters Thesis, J. Sika, 2006. Due to the lack of information in the field 

office area, a reference to it was included. Information from surrounding areas 

has been referenced.

DRMTDK-BL13-0426-5

NEPA

Another significant problem with the BLM's planning documentation is the 1-Km 

resolution datasets and 1:2,000,000 scale maps used in the BLM planning 

process. While this scale of maps may be a viable tool for multi-state or subcontinental planning efforts, it becomes totally meaningless at field office or even 

county level. With respect to the Greater Sage-grouse, datasets and mapping at 

these scales grossly mischaracterize historic and potential habitat by including 

non-habitat as well as overlooking microhabitat characteristics, especially in 

diverse and fragmented landscapes. Likewise, threats to sage grouse are also 

entirely overestimated when using sub-continental scale mapping, such as that 

used in the planning effort. It is ironic that when BLM requires maps from 

industry, they must be at a 1:24,000 scale rather than the scale BLM believes is 

N Thank you for your comment. 
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appropriate for a much larger planning effort

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Page 3-89, "Currently, nearly 16% of the MZ is within 3km of oil and gas wells, a 

distance where ecological effect is likely to occur (Knick et al 2011)."COMMENT: 

Energy development in MZ1 is addressed; however, energy development in MZ2 

and in particular the Billings/Pompey's Pillar planning area is not addressed in 

similar detail. What percentage of Billings/Pompey's Pillar planning area (MZ2) is 

within 3km of oil and gas wells and how would that affect proposed sage-grouse 

management in this specific planning area? Absent information related directly to 

the BFO, this statement is unjustifiable. The revised planning document must 

discuss directly the proximity of oil and gas wells to sage-grouse habitat and leks

n

Thank you for your comment. In response to the greater sage-grouse 

management objectives described in the 2006 WAFWA Greater Sage-grouse 

Comprehensive Conservation Strategy, many reports have been prepared for 

the development of management recommendations, strategies, and regulatory 

guidelines. The National Technical Team report (NTT 2011), Conservations 

Objectives Team (COT; FWS 2013), and the Summary of Science, Activities, 

Programs and Policies that Influence the Rangewide Conservation of Greater 

Sage-Grouse (also referred to as the Baseline Environmental Report [BER]; 

Manier et al. 2013) are the most widely used reports that have been 

incorporated in BLM and Forest Service EISs that address the effects of 

implementing greater sage-grouse conservation measures on lands they 

manage.

Management actions by the BLM and the Forest Service in concert with other 

State and Federal agencies, and private land owners play a critical role in the 

future trends of greater sage-grouse populations. To ensure management 

actions are effective and based on the best available science, the BLM’s 

National Policy Team created a NTT in August 2011. The objective for 

chartering this planning strategy effort was to develop new or revised regulatory 

mechanisms, through land use plans, to conserve and restore greater sagegrouse and their habitat on BLM-administered lands on a range‐wide basis over 

the long term. The NTT report (NTT 2011) used the best current scientific 

knowledge to guide the BLM and the Forest Service planning efforts through 

management considerations to ameliorate threats, focused primarily on priority 

greater sage-grouse habitats on public lands. 

On December 27, 2011, the BLM released IM 2012-044. In accordance with 

this IM, the BLM must consider all conservation measures developed by the 

NTT in at least one alternative in the land use planning process. For the 

majority of greater sage-grouse DRMP/EISs, Alternative B fulfills this 

requirement by incorporating the recommendations set forth by the NTT. Other 

alternatives, including those developed by individuals and conservation groups, 

as well sub-regional alternatives developed by regional offices of the BLM and 

the Forest Service, have incorporated elements of the NTT report. 

The COT report (FWS 2013) qualitatively identifies threats/issues that are 

important for individual populations across the range of greater sage-grouse, 

regardless of land ownership. The Summary of Science, Activities, Programs 

and Policies that Influence the Rangewide Conservation of Greater SageGrouse (also referred to as the Baseline Environmental Report [BER]; Manier et 

al. 2013) then provides complimentary quantitative information to support and 

supplement the conclusions in the COT. Both documents helped planning 

teams identify issues within their planning area, determine the context within 
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the management zone, prioritize habitats, and assist in creating a range of 

alternatives with management actions that can alleviate or mitigate threats to 

greater sage-grouse at an appropriate level. Both the NTT report and the COT 

report tier from the WAFWA Greater Sage-grouse Comprehensive 

Conservation Strategy (Stiver et al. 2006).

Alternative B is based on A Report on National Greater Sage-grouse 

Conservation Measures (NTT report) per direction in IM 2012-044. 

Conservation measures included in the NTT based alternative focus primarily 

on greater sage-grouse PPH and include a 3-percent disturbance cap in PPH. 

PPH areas have the highest conservation value to maintaining or increasing 

greater sage-grouse populations.

Map #24 depicts the location of sage-grouse priority habitat in relation to the 

RFD (Reasonable Foreseeable Development) potential for oil and gas.

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Wildlife 

Page 3-89, "Much of the current oil and gas development is occurring on private 

lands with little or no mitigation efforts, which elevates ecological and 

conservation importance of sage-grouse habitat on public lands. "COMMENT: 

What is the source of information that there are little or no mitigation efforts on 

private land? Does this statement apply to MZ1 or directly to the 

Billings/Pompey's Pillar planning area? How does current oil and gas 

development in the planning area compare with respect to private versus public 

land? This statement fails to recognize the initiatives and advances in 

technology that been developed in response to elevated concerns over the 

conservation status of sage-grouse and must be modified in the revised planning 

documents. Ramey et al (2011) identify the following advances in technology 

that avoid and reduce potential effects of oil and gas development on sagegrouse: Directional drilling to reduce surface disturbance by drilling multiple 

wells from one drilling pad; Steerable downhole motors and horizontal well 

bores that can drill as many as many as 20 boreholes from one pad and greatly 

increase the effective radius of production from one well pad; More efficient drill 

bits that reduce drilling times and rates of failure; Lightweight modular drilling 

rigs which deploy more easily and require a smaller foot print; and Slim-hole 

drilling, micro-holes and coiled tubing which reduce waste volumes, surface 

disturbance, and noise

n

Thank you for your comment. The BLM can only make decisions to BLM 

managed public lands and BLM managed federal mineral estate. Oil and gas 

development on private land is handled by the state/county.

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Wildlife 

COMMENT: The listing of sage-grouse as a candidate species under the ESA 

and its "warranted but precluded" status has increased awareness of the 

conservation status and conservation efforts and has led to Wyoming, Montana, 

and other states to develop statewide conservation strategies to protect sagegrouse and their habitat. As such, the RMP/EIS should reference and discuss 

how such efforts would interface with proposed BLM restrictions. The following 

are some of the initiatives that have been developed in response to sage-grouse 

conservation concerns: The Wyoming Governor issued Executive Order 2011-5 

n

BLM intends to rely on the latest research and best available science by 

utilizing existing research and delaying final decisions until the Governor’s Sage 

Grouse Advisory Council recommendations are final, incorporating the “USGS 

Range-Wide genetic Connectivity of Greater Sage-Grouse Populations” study 

when it is complete, and incorporating other future research through the 

“Adaptive Management” approach described in Section 2.3.4.

Before beginning the B&PPNM RMP/EIS and throughout the planning effort, 

the BLM and the Forest Service considered the availability of data from all 
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that establishes guidelines for managing Greater Sage-Grouse Core Area 

Protection. The Montana Governor issued Executive Order No. 2-2013 

establishing a Greater Sage-grouse Habitat Conservation Advisory Council 

which is mandated to gather information, furnish advice, and provide 

recommendations to the Governor on policies and actions for a state-wide 

strategy to preclude the need to list the Greater Sage-grouse under the ESA. 

The FWS, in 2013, issued the Conservation Objectives Team Report, which 

provides state, federal, local, and private entities with permitting or land 

management authority information to support conservation actions for sagegrouse. The Sage-Grouse National Technical Team (2011) produced A Report 

on National Greater Sage-Grouse Conservation Measures, which addresses the 

latest science and best biological judgment to assist in making management 

decisions. WAFWA completed the Greater Sage-Grouse Comprehensive 

Conservation Strategy (2006), which identifies the critical need to develop 

associations among local, state, provincial, tribal, and federal agencies, nongovernmental organizations, and individual citizens to design and implement 

cooperative actions to support robust populations of sage-grouse and the 

landscapes upon which they depend. A joint report (The History and Current 

Conditions of the Greater Sage-Grouse in Regions with Energy Development -

2007) by U.S. Department of Energy, Interstate Oil and Gas Compact 

Commission and ALL Consulting provides a historical overview of the sagegrouse to help clarify its regional significance; identifies current conservation 

plans of important stakeholders; and discusses current and historical 

management approaches. The Natural Resource Conservation Service (NRCS) 

with the Western Governors Association published Conserving the Greater 

Sage-Grouse: Examples of Partnerships and Strategies of Work Across the 

West, which illustrates the depth of commitment and cooperation that is taking 

place across the West to conserve the sage-grouse. In 2010, the NRCS and 

numerous conservation partners (local, state and federal agencies, Tribes, nongovernmental organizations) in the Western US established the Sage Grouse 

Initiative to work towards sustaining working ranches and conserve Greater 

sage-grouse populations in the West using existing voluntary conservation 

programs. In addition, the DEIS should have referenced and directly considered 

information such as the joint report of the Department of Energy, Interstate Oil 

and Gas Compact Commission and All Consulting (2007),

sources, adequacy of existing data, data gaps, and the type of data necessary 

to support informed management decisions at the land-use plan level. The data 

needed to support broad-scale analysis of the Billings Field Office planning 

area are substantially different than the data needed to support site-specific 

analysis of projects. The RMP/EIS data and information is presented in map 

and table form and is sufficient to support the broad scale analyses required for 

land use planning. 

The BLM and the Forest Service used the most recent and best information 

available that was relevant to a land-use planning-level analysis including the 

Baseline Environmental Report (BER; Manier et al. 2013). The BER assisted 

the BLM and the Forest Service in summarizing the effect of their planning 

efforts at a range-wide scale, particularly in the affected environment and 

cumulative impacts sections. The BER looked at each of the threats to greater 

sage-grouse identified in the Fish and Wildlife Service’s “warranted but 

precluded” finding for the species. For these threats, the report summarized the 

current scientific understanding, as of report publication date (June 2013), of 

various impacts to greater sage-grouse populations and habitats. The report 

also quantitatively measured the location, magnitude, and extent of each threat. 

These data were used in the planning process to describe threats at other 

levels, such as the sub-regional boundary and WAFWA Management Zone 

scale, to facilitate comparison between sub-regions. The BER provided data 

and information to show how management under different alternatives may 

meet specific plans, goals, and objectives. 

Additionally, the BLM and the Forest Service consulted with, collected, and 

incorporated data from other agencies and sources, including but not limited to 

the U.S. Fish and Wildlife Service and Montana Fish, Wildlife and Parks. 

As a result of these actions, the BLM and the Forest Service gathered the 

necessary data essential to make a reasoned choice among the alternatives 

analyzed in detail in the DRMP/EIS, and provided an adequate analysis that led 

to an adequate disclosure of the potential environmental consequences of the 

alternatives see Chapter 4. As a result, the BLM and the Forest Service have 

taken a “hard look,” as required by the NEPA, at the environmental 

consequences of the alternatives in the DRMP/EIS to enable the decision 

maker to make an informed decision. Finally, the BLM and the Forest Service 

have made a reasonable effort to collect and analyze all available data. 

The requisite level of information necessary to make a reasoned choice among 

the alternatives in an EIS is based on the scope and nature of the proposed 

decision. The baseline data provided in Chapter 3 and various appendices 

including in the B&PPNM RMP/EIS is sufficient to support, at the general land 

use planning-level of analysis, the environmental impact analysis resulting from 

management actions presented in the DRMP/EIS. 
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A land use planning-level decision is broad in scope and, therefore, does not 

require an exhaustive gathering and monitoring of baseline data. Although the 

BLM and the Forest Service realize that more data could always be gathered, 

the baseline data provides the necessary basis to make informed land use 

plan-level decisions. Land use plan-level analyses are typically broad and 

qualitative rather than quantitative or focused on site-specific actions (BLM 

Land Use Planning Handbook H-1601-1, Chapter II, A-B at 11-13 and Chapter 

IV, B at 29; Forest Service Handbook 1909.12 – Land Management Planning). 

The BLM and the Forest Service will conduct subsequent project-specific NEPA 

analyses for projects proposed for implementation under the land use plan, 

which may include but are not limited to fuels treatment, habitat restoration, 

[etc.; list others as applicable]. The subsequent NEPA analyses for projectspecific actions will tier to the land-use planning analysis and evaluate project 

impacts at the appropriate site-specific level (40 CFR 1502.20, 40 CFR 

1508.28). As required by NEPA, the public will have the opportunity to 

participate in the NEPA process for site-specific actions.

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Wildlife 

Page 3-90, "The cumulative and interactive impact of multiple disturbances and 

habitat loss has influenced the current distribution of greater sage-grouse in 

MZ1. The cumulative extent of human caused changes, the human footprint, on 

sage-grouse habitat in MZ1 is highest at the northern edge of the MZ but occurs 

throughout the MZ (Leu and Hanser 2011) (Figure 3-16). Population centers for 

greater sage-grouse in MZ1 (Doherty et al 2011) generally correspond to areas 

lacking high human footprint and some of these areas have been designated as 

core areas by Montana Fish, Wildlife, and Parks (Montana Fish, Wildlife, and 

Parks 2010). Greater sage-grouse range in MZ1 is very similar to portions of 

range where sage-grouse have been extirpated i.e., areas with high human 

footprints, mostly because of abundance and distribution of sagebrush in the MZ 

(Wisdom et al 2011) suggesting that sage-grouse in MZ1 are more vulnerable to 

declines than other portions of sage-grouse range. "COMMENT: As previously 

noted, the above discussion relates to MZ1 not MZ 2, where the majority of 

sage-grouse habitat in the Billings planning area is located. Does this statement 

apply to MZ2? What is the data for MZ2 that would support this assertion? If 

Sage-Grouse MZ1 is "very" similar to overall portions of the range in which sagegrouse have been extirpated, mostly because of the abundance and distribution 

of sagebrush, please explain why were the seven sage-grouse management 

zones delineated based on floristic provinces? Presumably, they differed based 

on floristic characteristics of which sagebrush is a major component. Suggesting 

that sage-grouse are more vulnerable to declines in MZ1 because of the 

abundance and distribution of sagebrush does not appear to have a scientific 

basis. Based on human effects to sagebrush habitat, it would appear that MZ1 

would be the least likely to experience extirpation of sage-grouse. The following 

n

The habitat delineations were created by the BLM, Forest Service, and FWS in 

collaboration with State fish and wildlife agencies that are responsible for 

managing and monitoring greater sage-grouse populations. Based on the 

Baseline Environmental Report and in cooperation with the Montana Fish, 

Wildlife and Parks, the BLM created the PHMA and GHMA (Mainer et al. 2013). 

For the Billings and Pompeys Pillar National Monument RMP/EIS revision, the 

BLM and Forest Service worked with the Montana Fish, Wildlife and Parks and 

presented the scientific information used to determine the PHMA and GHMA 

delineations and findings.

Additionally, the BLM and the Forest Service used the best available scientific 

data, including recent sources such as the COT report, NTT report, and BER to 

develop management recommendations, strategies and regulatory guidelines to 

meet the greater sage-grouse management objectives in the 2006 WAFWA 

Greater Sage-grouse Comprehensive Conservation Strategy. These 

documents were based on recent, published, and peer-reviewed scientific data 

developed by an interdisciplinary team of Federal and State scientists and 

resource managers.
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statement from Page 3-81 would support the contention that sage-grouse in MZ1 

are the least likely to experience impacts from the "human foot print," "Current 

estimates suggest that about 16 percent of the management zone is within 6.9 

kilometers of urban development, although Sage-Grouse Management Zone 1 

generally has lower rates of population increases compared to other 

management zones (Knick et al 2011)." How does the vulnerability to extirpation 

in MZ2 relate to BLM's contention in the DEIS that sage-grouse in MZ1 are more 

vulnerable to extirpation? The above-cited quotation is the same for the MCFO, 

HiLine, and Billings/Pompey's Pillar planning areas. It appears that the draft 

RMP/EISs relied on the same information in MZ1 to formulate management 

actions; however, none of these documents relates sage-grouse populations and 

habitat in MZ1 or MZ2 to population and habitat conditions in their respective 

planning areas. Is there an assumption that all of the planning areas have the 

same factors driving sage-grouse management and the same environmental 

conditions and constraints affecting the ecology of sagegrouse regardless of 

management zone and planning area?

DRMTDK-BL13-0426-

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NEPA

COMMENT: Under Executive Order No. 2-2013, Montana Governor Bullock 

mandated the establishment of a Greater Sage-grouse Habitat Conservation 

Advisory Council with a stated purpose "to gather information, furnish advice, 

and provide to the Governor recommendations on policies and actions for a 

state-wide strategy to preclude the need to list the Greater Sage-grouse under 

the Endangered Species Act (ESA), by no later than January 31, 2014." Will this 

advisory council supplant the Montana Sage Grouse Working Group (and/or 

local working groups) or will these groups continue to address sage-grouse 

management? In addition, please clarify BLM's anticipated role in recognizing 

and/or adopting recommendations of the advisory council as part of revisions to 

the draft RMP/EIS.

N

Thank your for your comment.

Please see Chapter 4 for the environmental consequences and Section 1.5 and 

Chapter 5 for discussions of inconsistencies between the Proposed RMP and 

county or local plans.

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Wildlife

COMMENT: The DEIS fails to discuss the assumed relationship of sage-grouse 

and sage-grouse habitat in MZ1 (as discussed throughout Chapter 3) compared 

to the Billings/Pompey's Pillar planning area. Most of the cited references that 

address effects of oil and gas development on sage-grouse have been 

conducted in the southeast Montana and Wyoming in the area of MZ1 where 

intensive development has been ongoing for decades. Ramey et al (2011) report 

that: "Current stipulations and regulations for oil and gas development in sagegrouse habitat are largely based on studies from the Jonah Gas Field and 

Pinedale Anticline. These and other intensive developments were permitted 

decades ago, using older, more invasive technologies and methods. The density 

of wells is high, due to the previous practice of drilling many vertical wells to tap 

the resource (before the use of directional and horizontal drilling of multiple wells 

from a single surface location became widespread), and prior to concerns over 

sage-grouse conservation. These fields and their effect on sage-grouse are not 

n

Thank you for the comment. 

Habitat in MZ1 is comparable throughout the Eastern Montana and NE 

Wyoming area. The Billings Field Office only has a small area south of Bridger, 

MT. to the Wyoming state line, that is within MZ2. BLM considered that habitat 

is very similar between the two management zones and analyzed them as one 

entity for consistency.

Currently, a research project on sage-grouse in MZ2 is being conducted. Local 

management considerations will be developed based on the findings of this 

research. 
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necessarily representative of sagegrouse responses to less-intensive energy 

development. Recent environmental regulations and newer technologies have 

lessened effects to sage-grouse. "In addition, Taylor et al (2007) analyzed six oil 

and gas development areas in Wyoming with various degrees and ages of 

activity to determine sage-grouse population trends relative to intensity and 

timing of oil and gas development. They report that: Sage-grouse population 

trends are consistent among populations regardless of the scope or age of 

energy development fields, and that population trends in the six development 

areas mirror trends state-wide; Application of the BLM standard sage-grouse 

stipulations appear to be effective in reducing the impact of oil and gas 

development on male-lek attendance; Male lek attendance in areas that are not 

impacted by oil and gas development is generally better than areas that are 

impacted; Displacement from impacted leks to non-impacted leks may be 

occurring; research is needed to assess displacement and its implications for 

developing sage-grouse conservation strategies; Lek abandonment was most 

often associated with two conditions, including high density well development at 

forty-acre spacing (sixteen wells per square mile), and regardless of well spacing 

when development activity occurred within a the quarter-mile lek buffer; 

Extirpation of sage-grouse has not occurred in any of the study areas; Longterm fluctuations in sage-grouse population trends in Wyoming reflect processes 

such as precipitation regimes rather than energy development activity; however, 

energy development can exacerbate fluctuations in sage-grouse population 

trends over the short-term.

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Wildlife

COMMENT: The sheer length and disorganization of Chapter 4 (e.g., weaving 

among alternatives, topic areas, cumulative effects, etc.) makes it virtually 

impossible to discern the crux of issues related to sage-grouse populations in 

the Billings/Pompey's Pillar planning area. What are the potential impacts to 

sage grouse populations within the Billings/Pompey's Pillar planning area due to 

each of the Alternatives examined as a function of proposing different land 

classifications and various NSO/CSU restrictions associated with those 

classifications? It is evident that the population status of sage-grouse in the 

planning is not well known. Are current populations increasing, decreasing or 

remaining stable? Without a clear description of the existing sage-grouse 

resource within the planning area, it is impossible to assess the predicted effects 

of various management alternatives on sage-grouse populations. Is the 

preferred alternative expected to result in populations that are larger, smaller, or 

remain at current level? How would this differ among alternatives?

n

Refer to pages 3-85 through 90 for a summary of sage grouse populations, 

habitat, and threats. Fluid Minerals impacts to wildlife are described on 4-246 

and Section 4.3.1.1.2, pages 4-422 to 4-425 and in Cumulative Impacts, 

Section 4.6.4, pages 4-624 to 4-615. Impacts from Wildlife Habitat and Special 

Status Species Management in Alternative D “Preferred Alternative” are 

described in Section 4.2.7.6.4 on pages 4-280 and 281.

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Wildlife 

COMMENT: Chapter 3 and the impact discussion in Chapter 4 addressing 

predicted impacts to sagegrouse, appears to rely solely upon on research 

conducted in MZ1, an area that encompasses sagegrouse habitats in large 

areas of Montana, Wyoming, and the Dakotas. In so doing, the DEIS fails to 

n

Habitat in MZ1 is comparable throughout the Eastern Montana and NE 

Wyoming area. The Billings Field Office only has a small area south of Bridger, 

MT. to the Wyoming state line, that is within MZ2. BLM considered that habitat 

is very similar between the two management zones and analyzed them as one 
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address the cumulative effects of land management on sage-grouse projected to 

occur within the Billings/Pompey's Pillar planning area. Rather it relies on the 

broad discussion of MZ1 and MZ2. Moreover, this section repeats much of the 

material addressed in Chapter 3.MZ1 is extensively referred to in Chapter 3; 

however, BLM fails to address the relationship of sagegrouse and their habitat in 

MZ1 to the BLM planning area. From the text in the DEIS, it appears that MZ1 is 

thought to be important for sage-grouse management; however, there is no 

reference to MZ1 in the cumulative effects section. Why does Chapter 3 have a 

section dedicated to MZ1 but impacts of the proposed Billings/Pompey's Pillar 

management actions are not addressed relative to MZ1?The section on 

cumulative impacts would be an ideal place to address the relationship among 

planning and management activities in MZ1 and MZ2 and the Billings planning 

area. At a minimum, the Billings DEIS needs to address the potential cumulative 

effects of the proposed planning activities in the Miles City and Hi Line planning 

areas as they relate to the Billings/Pompey's Pillar planning area.

entity for consistency. From the DRMP page 3-86, - “descriptions of MZ1 are 

mostly the same as those that would be described for the northern portion of 

MZ2 found in the planning area.”

Currently, a research project on sage-grouse in MZ2 is being conducted. Local 

management considerations will be developed based on the findings of this 

research. Text has been added to Chapter 4 to address cumulative impacts 

with regards to MZ1 and MZ2 - Billings Field Office.

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Livestock 

Grazing

While grazing may have the potential to affect sage-grouse habitat; the DEIS 

fails to discuss how sage-grouse habitat and displacement of sage-grouse have 

been affected by grazing practices in the planning area or even the broader 

region of MZ1 and MZ2. The revised planning documents must evaluate the 

cumulative effects of livestock grazing on public and private land on sage-grouse 

and their habitat.

n

In response to your comment, the text in Section 4.2.7.7of the Proposed RMP 

and Final EIS has been expanded to clarify the discussion of cumulative effects 

to the greater sage grouse within MZ1 and MZ 2.

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59

Oil and gas

COMMENT: This statement is based upon the assumption that all oil and gas 

activities would involve "full-scale" development. "Full-scale" development needs 

to be identified in terms of well density and other disturbance factors. Is all future 

development in the planning area expected to be full-scale -” full-scale in terms 

of the Pinedale Anticline or Jonah? These development areas are profound 

anomalies within the context of typical development throughout most of the 

Rocky Mountain region and we strongly object that they are being used as a 

baseline for examining potential development in other areas, particularly those in 

the Billings FO. The revised planning documents must base their analysis upon 

what has typically occurred within THIS planning area.

n

Thank you for your comment. The RFD for the B&PPNM plan revision is 4 

wells per year occurring on BLM managed federal mineral estate per year. 

There are no high potential oil and gas development areas occurring in the 

federal mineral estate. Full-scale would be four wells per year. 

DRMTDK-BL13-0426-6

Wildlife

Most of the conventional literature regarding sage-grouse starts with the 

assertion that -” 60% of historic range has been lost. This is based on work done 

by Schroeder et al in 2004, and has become the cornerstone of mainstream 

sage-grouse research. It too is at a 1:2,000,000 scale and provides the basis for 

much of the US Fish and Wildlife Service (FWS) and BLM policy regarding sagegrouse. Of great concern, however, is the fact that this scale provides wholly 

unsuitable data when conducting any analysis or planning at FO level. The most 

recent paper by Knick et al concluded that sage-grouse lek abandonment will 

occur with as little as 3% human disturbance with a 3-mile radius of a lek. 

Unfortunately, their methods apply cumulative human impacts over the past 100 

n

Before beginning the B&PPNM RMP/EIS and throughout the planning effort, 

the BLM and the Forest Service considered the availability of data from all 

sources, adequacy of existing data, data gaps, and the type of data necessary 

to support informed management decisions at the land-use plan level. The data 

needed to support broad-scale analysis of the Billings Field Office planning 

area are substantially different than the data needed to support site-specific 

analysis of projects. The RMP/EIS data and information is presented in map 

and table form and is sufficient to support the broad scale analyses required for 

land use planning. 

The BLM and the Forest Service used the most recent and best information 
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years to a static snapshot of lek status (active or abandoned). In other words, no 

consideration was given to the timing of the human disturbance with respect to 

the status of a lek in question. It is assumed that any lek abandonment was due 

to cumulative human impacts

available that was relevant to a land-use planning-level analysis including the 

Baseline Environmental Report (BER; Manier et al. 2013). The BER assisted 

the BLM and the Forest Service in summarizing the effect of their planning 

efforts at a range-wide scale, particularly in the affected environment and 

cumulative impacts sections. The BER looked at each of the threats to greater 

sage-grouse identified in the Fish and Wildlife Service’s “warranted but 

precluded” finding for the species. For these threats, the report summarized the 

current scientific understanding, as of report publication date (June 2013), of 

various impacts to greater sage-grouse populations and habitats. The report 

also quantitatively measured the location, magnitude, and extent of each threat. 

These data were used in the planning process to describe threats at other 

levels, such as the sub-regional boundary and WAFWA Management Zone 

scale, to facilitate comparison between sub-regions. The BER provided data 

and information to show how management under different alternatives may 

meet specific plans, goals, and objectives. 

Additionally, the BLM and the Forest Service consulted with, collected, and 

incorporated data from other agencies and sources, including but not limited to 

the U.S. Fish and Wildlife Service and Montana Fish, Wildlife and Parks. 

As a result of these actions, the BLM and the Forest Service gathered the 

necessary data essential to make a reasoned choice among the alternatives 

analyzed in detail in the DRMP/EIS, and provided an adequate analysis that led 

to an adequate disclosure of the potential environmental consequences of the 

alternatives see Chapter 4. As a result, the BLM and the Forest Service have 

taken a “hard look,” as required by the NEPA, at the environmental 

consequences of the alternatives in the DRMP/EIS to enable the decision 

maker to make an informed decision. Finally, the BLM and the Forest Service 

have made a reasonable effort to collect and analyze all available data. 

The requisite level of information necessary to make a reasoned choice among 

the alternatives in an EIS is based on the scope and nature of the proposed 

decision. The baseline data provided in Chapter 3 and various appendices 

including in the B&PPNM RMP/EIS is sufficient to support, at the general land 

use planning-level of analysis, the environmental impact analysis resulting from 

management actions presented in the DRMP/EIS. 

A land use planning-level decision is broad in scope and, therefore, does not 

require an exhaustive gathering and monitoring of baseline data. Although the 

BLM and the Forest Service realize that more data could always be gathered, 

the baseline data provides the necessary basis to make informed land use 

plan-level decisions. Land use plan-level analyses are typically broad and 

qualitative rather than quantitative or focused on site-specific actions (BLM 

Land Use Planning Handbook H-1601-1, Chapter II, A-B at 11-13 and Chapter 

IV, B at 29; Forest Service Handbook 1909.12 – Land Management Planning). 
Billings and Pompeys Pillar National Monument

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5-300 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

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The BLM and the Forest Service will conduct subsequent project-specific NEPA 

analyses for projects proposed for implementation under the land use plan, 

which may include but are not limited to fuels treatment, habitat restoration, 

[etc.; list others as applicable]. The subsequent NEPA analyses for projectspecific actions will tier to the land-use planning analysis and evaluate project 

impacts at the appropriate site-specific level (40 CFR 1502.20, 40 CFR 

1508.28). As required by NEPA, the public will have the opportunity to 

participate in the NEPA process for site-specific actions.

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Oil and Gas

Page AB-9, "In cases where Federal oil and gas leases have been issued 

without adequate stipulations for the protection of sage-grouse or their habitats 

being provided in the applicable RMP decision, as revised or amended, include 

mitigation measures and conservation actions as permit Conditions of Approval 

(COAs) when approving exploration and development activities through 

completion of the environmental record of review (43 CFR 3162.5), including 

appropriate documentation of compliance with NEPA."COMMENT: Please 

explain in more detail how COAs would correspond with the annotation made in 

Table 2-5 "Lease Terms and Stipulations by Alternatives" that it applies to "New 

Oil and Gas Leases". Based on the paragraph above, it appears that COAs may 

apply to current lease areas as well as "new oil and gas leases"? Please explain 

in more detail how the information in Appendix AB corresponds to the specified 

lease terms and conditions, and what this would mean to lessees/producers. We 

also recommend that BLM clearly articulate how it intends to ensure such COA's 

would be administered to preserve valid existing lease rights.

n Thank you for your comment. This will be clarified in the document.

DRMTDK-BL13-0426-

61

Wildlife

This section includes questions generated from a comparative review of the 

HiLine, MCFO, and Billings/Pompey's Pillar DEISs, with a particular focus on the 

various management restrictions within sage-grouse habitat. Tables 1 and 2 

serve as summaries of main sage-grouse management parameters and 

management prescriptions included in each of the three referenced RMP/EIS 

documents and serve as reference points for several specific comments 

presented below: Table 1Sage-Grouse Management Parameters on BLMAdministered Land Planning Area BLM Sage Grouse Habitat Estimated # of 

Leks BLM Sage-Grouse Habitat Acreages General Habitat Areas ProtectionPriority Areas Restoration Areas/Source Population Area Miles City Field 

Office2.5 Million acres 386 leks of unconfirmed status, 455 confirmed active 

leks, 33 extirpated leks, and 19 confirmed inactive leks. BLM Oil/Gas 

Lease(1): 800,000 acres BLM Surface: 400,000 acres BLM Oil/Gas Lease: 

1,403,000 acres BLM Surface: 792,000 acres BLM Oil/Gas Lease: 289,000 

acres* BLM Surface: 109,300 acres** Of these totals, 8,000 acres of Oil/Gas 

Lease and Surface are part of the Source Population Area. HiLine Unknown (2) 

154 leks BLM Administered Federal Mineral Estate (BLM-FME) (1): unknown 

(2) acres BLM Surface: unknown acres (2)Grassland Bird/Greater Sage 

n

Thank you for your comment. The categories of” Federal mineral estate” and 

“Oil and Gas Lease” are not intended to represent the same classification. 

Federal mineral estate includes all federal mineral estate, both surface and 

subsurface (Split estate –refer to Glossary definition) and the “Oil and Gas 

lease” category describes either leasable Federal mineral estate or actual 

leased acreage. ????

Acreage from Chapter 3, Page 3-85 (Table 3-29), reports a total of 336,479 

acres in Billings Field Office. This acreage was prepared from DRAFT Montana 

Fish, Wildlife, and Parks sage grouse habitat data several years ago. This data 

will be edited to reflect more recent data from Table 2-1.

Acres of various classes of sage-grouse habitat within Billings Field Office; and 

Number of leks on BLM-administered lands in the planning area are described 

on pages 3-85 and 86 and Table 2-1.
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Grouse Priority Area: BLM-FME: 1,028,661 BLM Surface: 930,265 acres 

Sage Grouse Priority Protection Area: BLM-FME: 318,143 acres BLM Surface: 

298,772 acres BLM-FME: Unknown acres (3) BLM Surface: 46,786 acres 

Billings/Pompey's Pillar336,479 Acres(4) 19 active leks on BLM Surface (8 

inactive) 30 lek sites are on FME.BLM-FME: 116,452 acres BLM Surface: 

78,575 acres BLM-FME: 191,543 acres BLM Surface: 154,140 acres BLMFME: 63,437 acres BLM Surface: 45,555 acres(1) See comment below for 

questions concerning "Oil and Gas Lease" and Federal Mineral Estate" 

terminologies.(2) See comment below for a question concerning total BLM acres 

of sage-grouse habitat within the HiLine Planning Area(3) See comment below 

for a question concerning total BLM acres of "Federal Mineral Estate" within 

Restoration Areas (HiLine RMP/EIS)(4) See comment below regarding the total 

acreage reported in Chapter 3, Page 3-85 (Table 3-29) of the Billings/Pompey's 

Pillar RMP/EIS. Table 2Management Prescriptions for Three BLM Planning 

Areas in Montana BLM Sage-Grouse Habitat Categories Planning-General 

Habitat Acres-Nesting/Brood Rearing-Protection-Priority and Source PopulationRestoration Areas Miles City (1)-Surface-disturbing activities would be avoided 

within 2 miles of leks, CSU stipulations within 2 miles of leks, Low-voltage power 

lines buried within 2 miles of leks-Surface-disturbing activities would be avoided 

within 4 miles of leks. Timing restrictions (BMP Appendix)-NSO-CSU stipulations 

HiLine (2)-NSO within 1 mile of leks-CSU stipulations -NSO ----Billings/ 

Pompey's Pillar-CSU stipulations, NSO on "new oil and gas leases" within 0.6 

miles of a lek, Timing restrictions within 3 miles of leks (March 1 -” June 15)-

Timing restrictions within 3 miles of leks (Mar.1 -” June 15), CSU stipulations, 

Geophysical exploration allowed on existing roads, Timing-restrictions (Marl. -

”June 15) within 4 miles of leks-NSO-NSO on "new oil and gas leases" within 0.6 

miles of a lek, Timing restrictions within 3 miles of leks (Mar.1 -” June 15), CSU 

stipulations, Geophysical exploration allowed on existing roads, Timingrestrictions (Marl. -”June 15) within 4 miles of leks(1) Miles City indicates that 

sage-grouse protection areas will not be designated as ACECs and no 

compensation for impacts would be required in sage-grouse impacts (which may 

conflict with CSU stipulations)(2) Hi Line also has NSO restrictions in sagegrouse wintering areas from Dec. 1-” March 31. Comment: As summarized in 

Table 1 above, when discussing specific acreages of sage-grouse habitat that 

would fall under various management restrictions (based on the respective 

Preferred Alternatives), the Billings/Pompey's Pillar DEIS and the HiLine DEIS 

reference BLM Administered "Federal Mineral Estate" and "Surface" under each 

main sage-grouse management classifications (e.g., General Habitat, Priority 

Protection Area, Restoration Area). However, the MCFO DEIS references "Oil 

and Gas Lease" and "Surface" as the two main categories of BLM 

administration. Please clarify the questions below: Are the categories of 
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"Federal Mineral Estate" and "Oil and Gas Lease" intended to represent the 

same classification? If not, please explain any difference. If yes, please clarify 

terminologies among all Montana BLM RMP/EISs to aid the public (and potential 

operators) in consistently interpreting the proposed sage-grouse habitat 

restrictions. Are all proposed surface management restrictions applied equally 

regardless of whether the BLM Administered Lands in question are "Surface or 

"Federal Mineral Estate" and/or "Oil and Gas Lease"? Is it assumed that if a 

particular "Surface" acreage is under BLM Management then the mineral estate 

within that same acreage is also under BLM Administered "Federal Mineral 

Estate" and/or "Oil and Gas Lease" as well? Comment: Are the 2.5 million acres 

reported as sage-grouse habitat under BLM Administration (within the MCFO 

planning area) a summation of the "Oil and Gas Lease" acreages reported for 

the three main management categories reported in MCFO DEIS Table 2.22? 

See summary in Table 1 above (General Habitat Acres [800,000 acres], 

Protection-Priority Areas [1,403,000 acres] and Restoration Areas and Source 

Population Area [289,000 acres]). Comment: Three appendices within the 

MCFO DEIS address management practices to avoid, minimize, and 

compensate for losses to sage-grouse habitat (i.e., BMPs Appendix, Minerals 

Appendix, and Fish and Wildlife Appendix). These appendices list specific 

practices and restrictions that apply to oil and gas development in sage-grouse 

habitat but do not specify which practices are stipulations that must be met for 

leasing and development. It is difficult to determine what an oil and gas operator 

will have to comply with relative to actions in sage-grouse habitat. Table 2 

(below) summarizes what appear to be the primary management restrictions, but 

they have been summarized from various sections of the DEIS and may not be 

comprehensive. The MCFO DEIS (and the HiLine and Billings/Pompey's Pillar 

DEISs accordingly) must identify required stipulations and guidelines (are these 

the same as BMPs?) in a comprehensive table within either DEIS Chapter 2 or 

3.Comment: Two of the three DEISs indicate that CSU stipulations will be 

developed for activities in various sage-grouse habitats; however, it is unclear in 

the MCFO DEIS how CSU stipulations will be developed. By comparison, the 

HiLine DEIS identifies how CSU stipulations will be developed in Appendix E.5 

and the Billings Pompey's Pillar DEIS describes the development of CSU 

stipulations in Appendix C. Both the HiLine and Billings / Pompey's Pillar DEISs 

indicate that the proponent must prepare a plan to maintain the functionality of 

sage-grouse habitat to assist in identifying CSU stipulations. How will CSU 

stipulations be identified in the MCFO planning area? Comment: Please clarify 

the total acreage of BLM-Administered acreage of sage-grouse habitat within the 

Billings/Pompey's Pillar planning area. Chapter 3, Page 3-85 (Table 3-29), 

reports a total of 336,479 acres. However the total appears to be 371,432 acres 

when summing the acreages presented in Chapter 2, Page 2-19 (Table 2-1). 
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Please clarify. Comment: Please clarify and/or provide the total BLM acres of 

"Federal Mineral Estate" that would be included within the "Restoration Areas" 

category for the HiLine planning area. This information appears to be missing in 

the HiLine DEIS. Comment: Please clearly depict what management 

restrictions/prescriptions would be required for the two proposed ACECs within 

the HiLine planning area; specifically the Grassland Bird/Greater Sage-Grouse 

Priority Areas ACEC (461,220 acres) and Greater Sage-Grouse Protection 

Priority Area ACEC (930,265 acres). Jointly the two ACECs comprise over 1.39 

million acres and represent an extensive land area. Comment: To understand 

the effects of proposed sage-grouse management in the planning areas for the 

three BLM field offices, the sage-grouse resource (i.e., populations and habitat) 

that would be affected by various management directives need to be identified. 

The DEISs for the three planning areas do not present sage-grouse estimates 

for population sizes (see Table 1) so other metrics that represent the sagegrouse resource which will be subject to the proposed management directives 

need to be presented. To better understand the sage-grouse resource that 

would be subject to the management prescriptions identified in the three DEISs, 

we request the that following information be clearly stated in each DEIS's 

Chapter 3 -” Existing Environment: Acres of various classes of sage-grouse 

habitat within each planning area on BLM administered lands; and Number of 

leks on BLM-administered lands in the planning area. Comment: As shown in 

Table 2 above, the planning prescriptions for surface occupancy and controlled 

surface use for the three planning areas (MCFO, HiLine, and Billings/Pompey's 

Pillar) are variable which raises questions of how NSO restrictions were 

determined. Based on review of the three draft planning documents, it appears 

that all three relied on same data sources to address impacts of oil and gas 

development on sage-grouse. All planning areas have similar sage-grouse 

habitat conditions (i.e., all are in Sage-Grouse Management Zone 1), and all are 

anticipating some level of oil and gas development. It is unclear how different 

NSO restrictions around leks were developed. NSO restrictions around leks vary 

among the planning areas, with buffers around leks being 0.6, 1, 2, and 3 miles. 

Why are these NSO restrictions different for the three planning areas when they 

all relied on similar sources to define potential impacts associated with oil and 

gas development? Does sage-grouse vulnerability to impact or population 

viability differ among BLM planning areas? Additional Literature Cited Ramey, 

R., L. Brown, and F. Black goat. 2011. Oil and gas development and greater 

sage-grouse (Centrocercus urophasianus); A review of threats and mitigation 

measures. The Journal of Energy Development: 35(1); 49-77.Taylor, R., M. 

Dzialak, L. Hayden-Wing. 2007. Greater sage-grouse populations and energy 

development in Wyoming. Accessed March 2013 at 

http://bogc.dnrc.mt.gov/reports.asp
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DRMTDK-BL13-0426-7

NEPA, Oil 

and Gas 

BLM recognized the intent of the both Phases I and II of the EPCA review when 

it issued Instruction Memorandum 2003-233, Integration of the Energy Policy 

and Conservation Act (EPCA) Inventory Results, into the Land Use Planning 

Process. Consequently, BLM Field Offices are now required to review all current 

oil and gas lease stipulations to make sure their intent is clearly stated and that 

stipulations utilized are the least restrictive necessary to accomplish the desired 

protection. Moreover, the IM directs that stipulations not necessary to 

accomplish the desired resource protection be modified or eliminated during the 

planning process. Since the purpose of integrating the EPCA results into 

planning is intended to determine whether existing resource protection measures 

are inadequate, adequate or excessive, we recommend the BILLINGS BLM 

reevaluate its management decisions accordingly and make requisite changes to 

the FEIS. If BLM decides not to reevaluate its decision, we specifically request a 

response from BLM in the Final EIS explaining why this was not done

n

Thank you for your comment. Oil and gas stipulations have been reviewed and 

evaluated by Montana State Office Oil and Gas staff for prior to release of the 

DRMP. 

DRMTDK-BL13-0426-8

NEPA

We also point out that documentation of the need for change is required by 

BLM's 1601 Planning Handbook at § VI, Determining if New Decisions are 

Required, Part D, Documenting the Determination to Modify, or Not to Modify, 

Decisions or NEPA Analysis, which directs that "it is important to document 

decisions to modify or not modify the land use plan or NEPA analysis when 

these decisions are reached as part of the formal land use plan evaluation 

process (Section v). (Emphasis added) We ask BLM to explain its rationale to 

exclude this requirement from the DEIS in final EIS

N

Thank you for your comment. The lifespan of a RMP/EIS is 15-20 years. 

When the BLM Billings Field Office began the RMP revision process in 2008, 

the 1984 RMP was 24 years old. Since the Record of Decision was signed for 

the existing RMP in 1984, new data have become available, and laws, 

regulations, and policies regarding management of these public lands have 

changed. In addition, decisions in the existing plan do not satisfactorily address 

all new and emerging issues in the Planning Area. These changes and 

potential deficiencies created the need to revise the existing plan. 

DRMTDK-BL13-0426-9

Oil and Gas

Therefore, since the purpose of integrating the EPCA results into planning is 

intended to determine whether existing resource protection measures are 

inadequate, adequate or excessive, it is even more crucial that the BFO 

reevaluate its management decisions accordingly and make requisite changes to 

the FEIS. Discussion of the specific requirements of a resource to be 

safeguarded, along with a discussion of the perceived conflicts between it and oil 

and gas activities must be provided along with an analysis of available mitigation 

measures. Clearly, an examination of less restrictive measures must be a 

fundamental element of a balanced analysis and documented accordingly in the 

FEIS

n

Thank you for your comment. BLM has developed a range of alternatives to 

reflect resource conservation as well as commodity use. 

The BLM is required to adopt the least restrictive development stipulations that 

will satisfy the resource objectives.

DRMTDK-BL13-0430-1

Recreation 

The RMP's four alternatives would each close a certain number of acres to 

recreational shooting ranging from 11,348 acres to 34,109 acres. The only 

reason given for the closures is a generalized statement that it is for "resource 

and safety concerns." We can surmise that some of the areas are closed 

because they might have developed recreation sites or resource values that are 

especially vulnerable. The RMP provides a Detailed Table of Alternatives 

(Resource Uses and Support) on Page 2-126 that displays how each of the 

alternatives would affect recreational shooting by acres opened or closed for 

each of the ACECs and other management units. However, there is no 

n

Thank you for your comments and concerns. Table 2-6.2 does provide rationale 

in text form for those areas which had restrictions proposed for them. However, 

as a result of your concerns, the tables have been revised to better reflect the 

decision and the difference in acreages involved. A note has been included in 

Table 2-62 with references to other decision sections (Appendix E) 
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substantive information that accompanies the table to explain the reason for 

each of the proposed closures and the variance in acreage among the 

alternatives.

DRMTDK-BL13-0430-2

Recreation 

The 17 Mile site, an isolated tract of 2,080 acres fronting on a public road, is one 

of only a small number of recognized and supported informal, but intensively 

used, recreational shooting areas in all of the planning area. It is described as 

having no other recreational use and no commercial grazing. At the present time 

it is the only BLM identified recreational shooting site on public lands within 

reasonable proximity to Billings for more concentrated recreational shooting to 

take place. If a recreational shooting inventory of other public lands was 

conducted, there is the potential for additional sites. However, even though other 

sites may be discovered, the 17-Mile site deserves added protections for its 

primary use as a recreational shooting site. The area is not identified for right of 

way exclusion or avoidance thus making its continued and current exclusive use 

for recreational shooting vulnerable to a ROW grant that could result in it being 

closed to shooting. The uniqueness (Ref. p. 3-193; Maps 95 and 96) of use of 17 

Mile in the Billings area, even the Billings District, argue for consideration as a 

SRMA rather than an ERMA. ERMA recreation management actions are, "... 

limited to only those of a custodial nature."

N

Thank you for your comment. Please refer to Chapter 2-62 and maps 102-105 

for the amount of area open in the Billings Field Office for target shooting, 

including the 17 Mile Area – as it can be seen the public is not overly restrained 

from target shooting in the BIFO lands, as consistent with the Hunting, Fishing 

and Shooting Sports Roundtable Memorandum of Understanding (MOU) and 

EO 13443. 

In regards to the designation of the 17 Mile Area as a SRMA and not as an 

ERMA, this action is not in accordance with BLM IM 2011-106 and 43 CFR 

8364 and 43 CFR 8365. The BLM‟s policy prohibits the agency from directly 

operating shooting ranges, or from issuing new leases of public lands for 

shooting ranges, principally because of the agency’s potential liability related to 

lead contamination of the environment. New shooting ranges cannot be 

authorized by any type of lease or other land use authorization that does not 

transfer fee title to the applicant. 

The map inconsistency noted between Maps 95 and 96 with Table 2-62 has 

been remedied.

DRMTDK-BL13-0430-3

NEPA, 

Travel mngt

We appreciate the recognition of Executive Order 13443 'Facilitation of Hunting 

Heritage and Wildlife Conservation" and the direction if provides to Federal land 

managers to work with state wildlife agencies, private landowners and other 

partners to improve hunter access and availability of public lands for hunting. 

Unfortunately, there are no specific examples of how this RMP would actually 

implement the Executive Order. The RMP proposes to close 377 miles of roads 

to public use. There is nothing in the RMP that discusses what, if any, impacts 

that will impose on hunter access, particularly the closure of roads that have 

been traditionally used by hunters. If the Executive Order is to be acknowledged 

as a guiding force for hunter access and opportunities, then the RMP should 

have provided an analysis of how the impact of these closures would affect 

hunters.

N

Thank you for your comment. Implementation of any of the acts would be 

addressed at implementation level planning. Thank you for expressing your 

concerns. While statements of opinion (including agreement or opposition) do 

not require specific responses or text revisions under NEPA regulations, they 

have been considered by the Billings Field Office and Montana State Office and 

documented in the administrative record associated with the Billings and 

Pompeys Pillar National Monument RMP/EIS. In regards to the specific route 

designations you support, the RMP has a range of possible decisions. The 

BIFO staff has reviewed your recommendations and its own route inventory 

data, the Transportation and Travel Management Manual 1626, and has 

chosen Alternative D as its preferred balance to establish a long term, 

sustainable, multi-modal system of roads, primitive roads, and trails that 

addresses public and administrative access needs to and across BLM –

managed lands, best supports the agency’s planning goals and objectives to 

provide resource management, and to manage travel and transportation on 

public lands in accordance with law, Executive Orders, Proclamations, and 

policy. 

DRMTDK-BLTravel mngt Concerning Road closures, there are many roads that could be closed that the 

public has no access to because they cross private land to get to the property. n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

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13-0431-1 Roads I would suggest closing are: GC1028, 1027, 1029, GC1004, GC1062, 

GC1016, GC1060 in section 30, but keep it open in sec 25, TWP 8S, RGE 20E, 

GC 1061, GC1048 in section 2 except where giving access to private land in 

section 11 to the south.

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

In regards to the specific route designations you support, the RMP has a range 

of possible decisions. The BIFO staff has reviewed your recommendations and 

its own route inventory data, the Transportation and Travel Management 

Manual 1626, and has chosen Alternative D as its preferred balance to 

establish a long term, sustainable, multi-modal system of roads, primitive roads, 

and trails that addresses public and administrative access needs to and across 

BLM –managed lands, best supports the agency’s planning goals and 

objectives to provide resource management, and to manage travel and 

transportation on public lands in accordance with law, Executive Orders, 

Proclamations, and policy. 

DRMTDK-BL13-0431-

10

Social/econ

I am not sure what Social-economic model was used for evaluating management 

of this area, but it needs to include the numerous private land holding here and 

future homes for many people. It is not just a change of managing the grouse 

that needs to be the focus and how it reduces grazing, but how someone who 

owns property there and has plans to retire or build a cabin loses the opportunity 

to do so or his costs are greatly increased because of right of way issues or lack 

of fire management. All of us who own property there can be affected by your 

plans for this area and the actual economic costs need to be factored in.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

For economic impacts due to sage grouse, please see the socio-economics 

section in chapter 4.

DRMTDK-BL13-0431-

11

Travel mngt

Many of the roads which are listed for closure are routinely traveled by citizens, 

officials, and emergency vehicles that require access to preform official duties. 

Adding an additional layer of restrictions on this type of travel could effect human 

concerns, and create adverse conditions on the BLM property's . The listed road 

closures in the preferred plan would deny access to several private property's 

and some historical reference point.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

DRMTDK-BL13-0431-2

Travel mngt 

Roads that should be kept open with no additional management are: GC1002, 

1003, 1010, 1009, 1008, 1047, 1070, 1001 from the Gove Creek Road to the 

Ruby Creek Road, 1070, 1031 from the Grove Creek road to the river, as well as 

1034 to 1035 to the private land. I strongly disagree with any management 

control over roads that give private individuals access to their property. Any 

management plans should never include closing roads that make someone's 

land become landlock. To insure that that does not happen, I recommend the 

above roads be open all vehicles with no administrative management.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

Please refer to map 150.

DRMTDK-BL13-0431-3

ACEC

Roads that would be good to remain open with additional management are 

1013, 1012, 1015, 1074, 1067, 1073, 1072, 1078, 1068, 1066, Administrative 

use only roads would be 1044, 1011, 1042, 1043, 1033, 1038, 1034 past 1035, 

1037, 1038, 1032, 1077.Some roads that give the public access to other public 

land, namely GC1024, 1050, 1051 & 1052 should remain open to the state 

public land, with additional management. These might be managed as ATV or 

N

Thank you for your comments. 

In specific regards to the ability of BLM to designate routes where historical use 

has been occurring, please see the discussion of RS-2477 in the RMP (chapter 

1, section 1.4.1.5). 
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4x4 only access. For that matter 1048, might also be good for ATV use as well. 

Finally, concerning roads, many roads, including the roads up into the Spires 

and the roads to the Dillworth homestead, Post Office and headquarters, predate 

the BLM and were public roads before they were BLM. Before roads area 

closed, the BLM should inventory where they have the authority over the road or 

whether the road is public and has been since the 1800's. Concerning this issue, 

the earliest survey of the Meeteetse Trail does show a road going up into the 

spires. For this reason, and because of the recreational opportunities, this road 

should be left open or allowed to be used for ATV use up to the cabin

In regards to specific routes and their decisions, the BLM staff used an 

interdisciplinary approach which is described in detail in Appendix O, and the 

inventory sheets for individual routes are available for review.

DRMTDK-BL13-0431-4

ACEC, 

I have problems with the conflicts being created by putting the Grove Creek area 

into an ACEC. This area is very small and not significant enough to warrant 

critical environmental concerns. Sagegrouse have flourished here with the 

current road densities and even allow recreational hunting because of the health 

of the population.

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS. 

Please see Appendix E for the resource evaluation on this ACEC. Also please 

refer to FLPMA Sections 103, 201, and 202 for the direction which it provides 

regarding the high priority BLM is to give in the designation and management of 

ACECs.

DRMTDK-BL13-0431-5

Cultural 

Another issues is that The Native American historical sites of more significance 

than just hunting camps have not been established. As one who has extensively 

explored this area, I have never seen any significant artifacts. I would be 

surprised as well that these public land areas were used much by them; they 

probably camped along Grove Creek or Dilworth Creek at the springs and 

flowing water areas which are now on private land. Look at the study conducted 

by Bales and Strait of Ethno science, Inc in 2003. They only found evidence of 

hunting camps, tepee rings and rock cairns that may have been from Native 

Americans or early settlers.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

DRMTDK-BL13-0431-6

Social/econ

this area has had huge settler, miner and rancher activity since the 1800's, 

including a post office and stage coach route. It was used to access the National 

Forest area (before it was National historical usage of this area and precludes 

the publics continued enjoyment. 4 , it would have a huge impact on the private 

landowners with restricting right of way improvements and acquisition of new 

right of ways, for power, phone and road access. If no one owned land here, that 

might be acceptable, but over 30% of the land is privately owned around this 

proposed ACEC.

n Thank you for your comment. 

DRMTDK-BL13-0431-7

Fire 

Ecology 

and 

Manageme

nt

the concerns about fire management and the issues of being able to fight fires 

with bulldozers may seem good for grouse, but it is inappropriate to allow fires to 

burn and not quench them as quickly as possible when you have so many 

private landowners in this area whose property would be damaged by fires. All 

means to stop fires needs to be exercised. This also would help protect the sage 

n

In response to your comment, the text in Alternative D for the Grove Creek 

ACEC of the Proposed RMP and Final EIS has been revised to state: Wildfire 

management (natural ignitions) for resource benefit. Full range of fire 

management activities would be used in ACEC in response to human-ignited 

fires. Use of heavy equipment and retardant would be avoided unless approved 
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grouse. by authorized officer

DRMTDK-BL13-0431-8

ACEC Management of this area under ACEC would adversely affect private property 

owners, as this area is mixed with private property that is being developed. N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS.

Please see Appendix E for the resource evaluation on this ACEC. Also please 

refer to FLPMA Sections 103, 201, and 202 for the direction which it provides 

regarding the high priority BLM is to give in the designation and management of 

ACECs.

DRMTDK-BL13-0431-9

Fire 

Ecology 

and 

Manageme

nt

concerning fire management issues, you need to note that the winds are much 

too strong in this area to permit an " ignore type policy" of fire management. A 

better alternative would be to allow the local citizen based fire suppression 

equipment to react and extinguish such fires. This would be a more expedient 

way of protecting structures dwellings and adjacent lands.

n

In response to your comment, the text in Alternative D for the Grove Creek 

ACEC of the Proposed RMP and Final EIS has been revised to state: Wildfire

management (natural ignitions) for resource benefit. Full range of fire 

management activities would be used in ACEC in response to human-ignited 

fires. Use of heavy equipment and retardant would be avoided unless approved 

by authorized officer

DRMTDK-BL13-0432-1

NEPA

The Phillips County growth policy and Land Use Resource Plan is not even 

listed in. the RMP. This indicates that the RMP was not reviewed to see if it was 

consistent with our policies. The Phillips County Commissioners request that we 

are cooperators on the step down plans such as the travel plan. We have a 

vested interest in the roads and should be in on the plan from the beginning. 

Page 1122 -"Develop a transportation management plan across ownership 

boundaries in greater sage grouse habitats" BLM only has jurisdiction over BLM 

lands not private land. We agree with the statement on page 7 issue 10 of the 

RMP summary, "Management must recognize the economic activities that are 

dependent on the land and it's natural . resources".

N

Thank you for your comment. Phillips County is not located within the Billings 

Planning Area, it does not border the planning area, and Phillips County is not a 

cooperating agency on this RMP/EIS. Phillips County had been added to the 

Billings & Pompeys Pillar National Monument RMP/EIS mailing list.

DRMTDK-BL13-0432-2

WSR

Page 7 issue 11 asks the question" how should they (lands with wilderness 

characteristics) be managed to protect those values?" This question is not really 

answered, just that Section 202 of the FLPMA requires the BLM to rely on 

resource inventories in the development and revision of the land use plans 

including inventory information regarding wilderness characteristics". This 

doesn't answer how they should be managed . .Page 16 ''Newly acquired lands 

would be evaluated to determine if they should be designated as a reserved 

common allotment." "If a reserve common allotment is designated, an activity 

plan would be developed that identifies how the allotment would be managed to 

maintain rangeland health and the procedures for selecting an applicant to use 

the allotment." Page 16: Allotments within priority habitat areas for sage grouse 

where grazing preference is relinquished or cancelled would be evaluated in a 

site specific document to determine if they should be closed to grazing, 

designated as reserve common allotments or reassigned. We do not agree with 

n

Thank you for your comment. The comments made apply to the Hiline RMP 

and not the Billings and Pompeys Pillar National Monument RMP. For 

Livestock Grazing alternatives please see table 2-6.2 Livestock Grazing, 

Thank you for your comments. Please be aware that under the Wild and Scenic 

Rivers Act, inventory or designation of a river segment neither implies nor gives 

government control of private lands within the river corridor. Although Congress 

(or the Secretary of the Interior) could and often does include private lands 

within the boundaries of a river study or a designated river, management 

restrictions would only apply to the public lands. The federal government has no 

power to regulate or zone private lands under the Act. People living within a 

river corridor would be able to use their property as they had before any W&SR 

study or designation. The ability of a landowner to buy or sell their property is 

not affected (it should be noted that WSR designations generally cause 

property values to remain stable or increase). Land use controls are solely a 
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using reserved common allotments. There is no guarantee that these allotments 

will be utilized. These allotments should be utilized and not reserved. We have a 

concern of the allotments being reserved for wildlife only and not utilized for 

cattle grazing and wildlife as it was intended. Page 35 Wilderness 

characteristics: ''No changes to livestock grazing allocations would occur on any 

lands managed for wilderness characteristics and all agreements and provisions 

for maintenance and upkeep of existing range improvements would continue to 

remain in effect including access to and maintenance of range improvements. 

New range improvements and land treatments could be allowed provided they 

meet with the objective of enhancing or restoring those wilderness 

characteristics being managed for and meet the intent of the visual quality 

objectives of the VRM class". We agree with this.

matter of state and local zoning; there are no binding provisions on local 

governments. In the absence of state or local protection provisions, the federal 

government may enter into compliance measures with landowners through a 

variety of mechanisms such as purchase of easements, cooperative 

agreements, exchanges or acquisition of private lands from willing sellers at fair 

market prices. 

DRMTDK-BL13-0432-3

Wildlife 

Greater Sage grouse priority areas and Greater Sage Grouse protection priority 

areas should be written the same as the general greater sage grouse areas 

wording, "Consideration would be given to incorporating site specific greater 

sage grouse habitat and management objectives as appropriate." Rather than 

on page 39 and 40 "Site specific greater sage grouse habitat and management 

objectives would be developed for BLM land and incorporated into respective 

allotment management plans or livestock grazing permits as appropriate."

n Thank you for your comment. These pages refer to the Hiline RMP.

DRMTDK-BL13-0432-4

Realty, 

Cadastral 

Survey, and 

Lands

Page 38 - "The BLM would consider opportunities to remove, bury or modify 

existing powerlines. Careful review should be done before considering removing 

powerlines. This could have a negative impact on adjoining landowners who 

chose to do future improvements.

n

Thank you for your comment. This language is from the Hi-Line Draft RMP 

Chapter 2, pages 150, 160, 166, and 167 alternative B-sage grouse PHMAs. 

The draft Billings RMP does not consider removing, burying or modifying 

existing powerlines, other than installing anti-perching devices. Your comment 

is specific to the Hi-Line Draft RMP. 

DRMTDK-BL13-0432-5

NEPA

Under FLPMA, BLM is required to manage the public lands on the basis of 

multiple use and sustained yield. 43 USC § 1701(a)(7) (2006) Oil and gas 

development is a crucial part of the BLM's multiple use mandate and the agency 

must ensure that oil and gas development is not unreasonably limited in the 

RMP.FLPMA clearly identified mineral exploration and development as a 

principal or major use of the public lands. (43 U.S.C. § 1702(1)) To that end, 

FLPMA requires the BLM to foster and develop mineral activities, not stifle and 

prohibit such development.

N

Thank you for your comment. The BLM’s multiple-use mission and the BLM’s 

obligation to comply with the Federal Land Policy and Management Act of 1976 

(FLPMA) and all other applicable laws, regulations and policies are addressed 

in Chapter 1 of the Proposed RMP/Final EIS. BLM carefully considered the 

issues brought forward during scoping the public comment period on the draft 

RMP/EIS and developed alternatives with full consideration of the requirements 

of multiple use management as described in FLPMA. While FLPMA directs the 

BLM to provide for multiple use, the BLM still maintains the authority to limit 

some uses when potential conflicts exist. The RMP/EIS evaluated a range of 

alternatives that provided for varying degrees of energy development along with 

other uses. In areas where energy development would conflict with BLM's 

obligations to protect other resources, BLM considered the impacts of a range 

of alternatives that included restricting, closing or leaving open specific areas to 

energy development to the extent necessary to properly balance management 

of all resources. 

DRMTDK-BLRecreation do not allow any target shooting at any time during the year, as these cause 

tremendous stress to our wild horses and other wildlife. Shooting is an n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

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13-0434-2 endangerment to people besides. under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

Please note that on page 2-172 safety is noted as a specific concern and that 

the closure is only during the period of peak visitation and only in the area 

where people and horses congregate in close proximity with a potential for both 

vegetation and topography screening.

DRMTDK-BL13-0434-3

WILD 

HORSES, 

PMWHR, 

Travel Mngt

Please set the speed limit of 15 mph to protect our horses and public. A sign 

clearly stating this should be set on the range. n

By policy BLM routes have been established at 35 mph. Other routes are set at 

the posted speed limit set by the State of Montana. In this case the BLM 

decision in the RMP is found in Table 2.6.3 and the speed limit and rationale is 

for safety for horses. The speed limit will be 15 mph within the PMWR lands 

located in T. 8 S., R. 28 E. 

DRMTDK-BL13-0434-4WILD 

HORSES, 

PMWHR

Please include the Sorenson Extension and the Tony Island Spring and the open 

meadows. Yes, it will require some work with the National Park Service and the 

Forest Service.

n Thank you for your comment. 

DRMTDK-BL13-0434-5WILD 

HORSES, 

PMWHR

Please preserve our wild horses in their natural habitat. N Thank you for your comment

DRMTDK-BL13-0436-

10

Travel mngt 

The entire route from the canyon mouth (PM 1068) and up the hill (PM 1069) 

and on into Custer NF is through a National Audubon Society Important Bird 

Area. This is about 2 miles on BLM land. Increased traffic will negatively impact 

both birds and bird watchers. Bear Canyon IBA: "Ornithological Summary" "Bear 

Canyon supports breeding populations of more than a dozen species on the 

Montana Priority Bird Species List. It also has the highest known number of 

nesting Blue-gray Gnatcatchers among the handful of foothill canyons in the 

area that constitute the entire range of the species in Montana. The riparian 

corridor is home to a rich diversity of Neotropical migrants, and the adjacent 

uplands are inhabited by Common Poor wills, Loggerhead Shrikes, Sage 

Thrashers, Green-tailed Towhees, Pinyon Jays, and the occasional broods of 

Greater Sage-Grouse." http://netapp.audubon.org/ibaiSite/2939 Additionally, 

Bear Canyon has in recent years been a nesting site for peregrine falcons.

n

Thank you for your comment. Travel management will leave the lower Bear 

Canyon road open to be consistent with Forest Service Travel Management 

and access to the Pryors. The spring and riparian area at the upper end of 

Bear Canyon will be closed to motorized travel and open to foot travel only due 

to erosion and high value wildlife habitat. 

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed”

Refer to map 146 

While statements of opinion (including agreement or opposition) do not require 

specific responses or text revisions under NEPA regulations, they have been 

considered by the Billings Field Office and Montana State Office and 

documented in the administrative record associated with the Billings and 

Pompeys Pillar National Monument RMP/EIS

DRMTDK-BL13-0436-

11

Travel Mngt 

Although Graham Trail might be designated for non-motorized use only, we 

suggest the non-motorized route be Bear Canyon (PM 1068) beginning at the 

canyon mouth mile from Helt Rd for a number of reasons.1. It is an ecologically 

sensitive area and a National Audubon Society IBA, (See above)2. It is part of 

an increasingly popular hiking trail.3. Bear Canyon is the roughest of the three 

routes for motorized access.4. Although the route does connect with a motorized 

n

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed” and as a non-motorized hiking trail. 

Refer to map 146
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route on Custer NF, that CNF route is easily motor accessible from Stockman 

Trail.5. Equestrians, including the Beartooth Back Country Horsemen, are very 

concerned about safety issues related to mixing horses with motorcycles and 

ATVs. This would provide separate staging areas and trails for motorized use 

and horses.6. The inventory sheet for this route (PMl 068) identifies many 

"special resource" concerns with regard to this route including birds, plants, 

soils, and archeological sites. The inventory sheet claims "Mitigation will be 

achieved by employing adaptive management monitoring of the status and/or 

integrity of the potentially impacted sensitive resources or resource issues 

identified above as they relate to various factors (e.g. climate cycles, exotic 

species introduction, visitor use levels [type, intensity, season of use)). " This 

vacuous bureaucratese does not identify any specific action that can or will be 

taken to mitigate impacts of motorized use on the identified resources.7. The 

closure of PM 1 071 to public motorized use would do a lot to minimize impacts 

to Bear Canyon's special resources and make it a better place for hikers and 

equestrians. There would be public access to Bear Canyon rather than a 

motorized thoroughfare through Bear Canyon to the rest of Big Pryor Mountain. 

(Stockman Trail and perhaps Graham Trail would serve that purpose.)8. The 

Route Inventory Sheet for PM 1068 includes the question: "Can the ... uses of 

this route be adequately met by another route that minimizes impacts to the 

sensitive resources identified above ... ?" BLM answers "No." We think the 

correct answer is obviously "Yes" because Stockman Trail goes to the same 

place. The only motorized use of this route that can' t be met by Stockman Trail 

is motorized use of this route. (This would be true of any route.) More importantly 

if non-motorized activity is considered equally with motorized activity, and if a 

"public use of this route" in the question above is considered to be its use as a 

hiking/equestrian trail, then that use cannot "be adequately met by another 

route" because Stockman Trail is a motorized route. Thus the public use is best 

served by closing the route to motorized use.

Also note that BLM Manual 1626 (Travel and Transportation) specifies that 

BLM establish a comprehensive program for both motorized and non-motorized 

travel. This will be done in this RMP

DRMTDK-BL13-0436-

12

Travel mngt 

This 1 mile route is designated open to motorized use in Alt D. It is currently 

signed closed to motor vehicles and there is a barricade across the entrance 

from Horse Haven Rd. This route should be closed to motorized use and 

designated as a non-motorized route because:1. It is the beginning of an 

increasingly popular hiking route informally called the "Big Sky Trail." The 

trailhead is near a good gravel road (Helt Rd) and is accessible without 4WD. 

Although a moderately high clearance vehicle is desirable for the 1.8 mile 

distance on Horse Haven Rd, someone with only a highway vehicle could park 

near Helt Rd and still access the trail with a I Y:z mile extra walk on Horse 

Haven Rd.2. People do not want to, and should not have to walk a mile on route 

PMI034 before escaping motorized commotion and impacts3. There is no 

particular purpose for this to be a motorized route. It dead ends at the CNF 

n

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions mentioned the Alternative D has 

been modified to reflect the current conditions. The route will be designated as 

“closed” to motorized vehicles but opened specifically for non-motorized use.

Refer to map 146

Also note that BLM Manual 1626 (Travel and Transportation) specifies that 

BLM establish a comprehensive program for both motorized and non-motorized 

travel. This will be done in this RMP. 
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boundary. None of the old tracks north of the fence on Custer NF are legal for 

either public or administrative motorized use. CNF has a "no motor vehicles" 

sign at the fence and the gate is locked.4. If motor legal, this route would be an 

"attractive nuisance" tempting people to illegally drive further on BLM or on north 

into CNF where extensive illegal driving is possible. Having this route open to 

motorized use would cause an enforcement problem. How often will the scarce 

BLM and CNF law enforcement people make the 2 mile round trip in to the fence 

to check for violations? The fence was cut fall 2012. The cut fence was neither 

discovered nor repaired by BLM or CNF. Appropriate closure to motorized use at 

Horse Haven Rd means any vehicle tracks from that point indicate illegal activity, 

and would thus be a great aid in simple, efficient enforcement of ORV use 

regulation.5. According to the BLM Inventory Sheet for this route it is a 

"connector" route and provides property access to the Forest Service. But the 

2008 CNF TMP does not designate the tracks north of the fence (on CNF) for 

either a public or administrative motorized use. So PM1 034 does not "connect" 

to any other motorized route, public or administrative.6. There are a number 

of "Special Resource" issues identified in the Inventory Sheet related to this 

route.7. The inventory Sheet answers "No" to the question, "Can ... uses of this 

route be adequately met by another route that minimizes impacts .... ?" This 

question presumes motorized use. Since it is a dead end motorized route the 

answer should be "There aren't many motorized uses of the route." However the 

non-motorized use of this route can be better met by closing it to motorized use.

DRMTDK-BL13-0436-

13

Travel mngt 

Hikers need to climb over or through the barbed wire fence at the BLM/CNF 

boundary. It would be good to install a passage suitable for hikers that would not 

allow passage by 4 WDs and ATVs. Other hiking routes need similar passages. 

Equestrians are blocked entirely by the locked gate. (Tracks indicate equestrian 

use of this and nearby routes.) This would be a good place to install a variation 

of the "Simmons" gate installed in the Grove Creek area to permit equestrian 

passage but not 4WDs and ATVs. In this case it could be smaller and simpler 

because there is no need for even administrative vehicles to pass through.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

This particular comment is not within the scope of the RMP, but it is an 

implementation decision and can be addressed elsewhere. 

DRMTDK-BL13-0436-

14

Travel mngt

RMP map 146 indicates another roughly parallel route just east of PMI034 

making a loop with PMI034. This loop is proposed open to motorized use in Alt 

D. But this route is mostly rehabilitated naturally and is nearly invisible on the 

ground. (Did BLM field check this route?) This route should be declared nonexistent and removed from BLM maps.

n

Thank you for your comments. The route was identified by the BLM ID team. 

The team reviewed its earlier work and the determination and has concluded 

that the route is no longer used by any means of travel, has essentially naturally 

rehabbed and will be closed to all uses and allowed to completely rehab. 

DRMTDK-BL13-0436-

15

Travel mngt

1. This is a classic example of unneeded parallel routes. For most of its length it 

is less than 1/2 mile north of, and in sight of Helt Rd. It follows the base of Big 

Pryor Mountain at the edge of the flat.2. The eastern 1 1/2 (approx.) mile 

between Bear Canyon and Horse Haven Rd (PM1076), provides a loop hiking 

route connecting the Bear Canyon and the Rocky Juniper Trails. (This 6 mile 

loop includes about 1 1/2 mile of motor legal route in Bear Canyon and a short 

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.
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section of Horse Haven Rd., but with this newly proposed motorized route the 6 

mile hiking loop would include 3.3 miles of motorized route.)3. There is no need 

for the slight shortcuts these route segments provide for motor vehicles between 

Horse Haven, Bear Canyon, Stockman, and Graham. Helt Rd provides the 

needed access.4. The claim in BLM's Route Inventory Sheets that these routes 

are not redundant because they have public (motorized) uses that can't 

adequately be met by other routes is simply false. However the non-motorized 

public use of especially PM! 076 cannot be met by another route. Demijohn Flat 

Route PM 1019 (SE from Crooked Creek Rd just south of BLM/CNF boundary.) 

This route is designated open in Alt 0 , but should be closed to public motorized 

use and designated for public nonmotorized use. (It could still be an 

administrative route as in Alt B.)1. This route encourages public motorized 

access to a culturally sensitive area designated as a National Register District 

and an ACEC. The preferred alternative proposes expanding the ACEC to 

include all of the Demijohn Flat National Register District. (E-14) That is a 

compelling reason to make the route nonmotorized.2. To the NE of this route is 

the Burnt Timber Canyon WSA. To the SW of this route is a proposed LWC. This 

route forms the boundary of both. There is no good reason for this motorized 

corridor. Closing this route to motorized use would allow a 1 1/2 mile common 

boundary between the WSA and LWC greatly strengthening both.3. This dead 

end route provides an " attractive nuisance" tempting people to drive beyond the 

designated end. Monitoring and enforcement will require regular 3 mile round trip 

excursions from Crooked Creek Rd by BLM LEOs. This is unlikely to happen 

often due to staff limitations. Efficient, effective monitoring and enforcement 

would be much easier if PMI 019 was designated non-motorized from the 

junction with Crooked Creek Rd.4. This route could provide an easy hiking 

opportunity from Crooked Creek Rd, with a trailhead accessible without 4WD 

vehicles. Most people can walk. We have seen people in the Pryors park their 

UTV and go for a hike; it is likely that many riders, as with automobile drivers, 

would take advantage of the opportunity to complement their ride with a chance 

to stretch their legs. It is no more logical to assume that ORV users are 

incapable of walking than it is to assume that people in cars cannot do so. Many 

people like to walk and visit the Pryors specifically to hike - especially away from 

motor vehicles; the cultural and archeological values of the Demijohn Flats area 

are clearly enhanced by the opportunity to experience and contemplate them 

free from the distraction of vehicle noise and dust. Longer hikes south into the 

Burnt Timber Canyon L WC (Penney Peak area) are also possible beginning on 

this route. Two tracks extend south from the "Y" at the end of PMlO19 in section 

10. Route PMI022 goes about a mile SE. This route may need to be designated 

for administrative use only as in Alt D. Route PM 1021 and PM 1038 (?) wanders 

about 4 miles SW and S into the LWC. This route should be closed to all 

The routes along the base of the mountains (PM 1082, PM 1077, and PM 1076) 

which you have expressed concerns with have been reviewed by the BLM staff 

and the determination is that they will remain as closed. The RMP has been 

altered to reflect this decision. PM 1076 will be specifically designated as a nonmotorized trail component. 

The BLM staff has also reviewed the preliminary decision for PM 1019 

(Demijohn Flat Road) and has changed the route status in the RMP from 

motorized to motorized (administrative access only) and along with PM 1022, 

PM 1038 and PM 1021 will also be designated as a non-motorized trail for 

general public use. 

Regarding the Sykes Ridge routes (PM 1001 and PM 1006) the BLM staff has 

determined that both route segments will remain as open for motorized use in 

the RMP. 

Regarding the potential construction of a non-motorized trail from Bad Pass 

Highway (state route 37) much of the lands are not managed by the BLM and 

the decision is beyond the scope of this plan. 

Regarding the potential for a non-motorized trail using segments of PM 1023 

and PM 1024, the BLM has reviewed the preliminary decisions in the RMP and 

has left all segments of PM 1024 as closed, with the exception of a segment 

from Red Pryor Road (PM 1025) to the top of the ridgeline (which could 

potentially serve as a staging area.). The BLM review determined that PM 1023 

would remain as “open” in the RMP. BLM will consider further the 

establishment of a designated non-motorized trail using components of PM 

1024 and other routes in its follow-up Implementation Plan. Also note that nonmotorized use is allowable on all open motorized, administrative only motorized 

routes, and closed vehicle routes. 
Billings and Pompeys Pillar National Monument

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5-314 Chapter 5: Consultation and Coordination

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motorized use and designated as a non-motorized route. After about 1 mile this 

route is very badly eroded and not passable with motor vehicles. It should not be 

driven . It makes a good hike into the LWC and to Penney Peak. Sykes Ridge 

Route PMI006 and part of PMIOOI. (Mostly in sections 27 & 28 T9S R28E) PM 

1006 is a 2 mile route from PM 1001 and back. The two routes are redundant. 

One route should be closed. We recommend closing PM 1006 and designating it 

as a non-motorized trail. The 445 acres inside the loop should be designated 

and managed as an L WC.1. Since the two routes are redundant closing one will 

not inhibit motor vehicle traffic up and down Sykes Ridge.2. This would reduce 

the many resource concerns identified on the Route Inventory Sheet.3. The 445-

acre island between the routes, excluded from WSA status could become an 

LWC.4. The Route Inventory Sheet identifies hiking as a "primary" use of route 

PM 1006. Access to this hiking route is not difficult for people without a 4WD. It 

is about a I-mile cross country hike from paved Highway 37 in BCNRA to this 

route. Constructing a connecting trail might be considered in the future.5. The 

Route Inventory Sheet for PM 1006 claims the route is not "redundant" and that 

its uses cannot be met by another route. But the use of driving up Sykes Ridge 

can be met by PM 100 I. One identified primary use of hiking can be better met if 

PM 1006 is designated as a non-motorized route. Lisbon - Dandy Mine Loop 

This is an opportunity to designate a non-motorized loop route. (We can't 

determine all the BLM route inventory numbers from the BLM map. The loop 

includes routes PM 1023 and PM 1024. The loop is mostly in sections 4 & 9 T9S 

R27E. (See map.)The route (PM 1023) in section 9 from Crooked Creek Rd up 

to the Dandy Mine and Red Pryor Mountain Rd is designated open for motor 

vehicles in Alt D. This route should be designated for non-motorized use only. 

The rest of the loop including the switchback route, mostly in section 4, from 

Crooked Creek Rd up to the Lisbon Mine is closed in Alt D. This entire loop 

should be designated for non-motorized use only. Some Reasons:1. There are 

an abundance of motorized routes for access to the Pryors, but a scarcity of 

non-motorized routes.2. There are four other motorized routes up Red Pryor 

Mountain. Besides Red Pryor Mountain Rd itself, there is the switchback road 

from Crooked Creek Rd on Custer NF about I 1/2 mile to the north of this loop, 

and two routes up from Horse Haven Rd to the west. These contribute to the 

many loop routes available for motorists.3. The trailhead for this hiking loop is 

accessible without a 4 WD vehicle. Yet the hike provides outstanding views of 

Demijohn Flat, Crooked Creek Canyon and the East Pryor Mountain block. 

Overview of motorized and non-motorized designations The following table 

compares designations of motorized and non-motorized routes in Alternatives A 

(current and no-action), Alt D (BLM Preferred) and the Pryors Coalition proposal. 

Data is from TMA maps 143 and 146 in the RMP. Numbers in the Pryors 

Coalition proposal are based on all the non-motorized routes suggested above in 
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BLM Response to Comment

this letter. Obviously our suggestions are very modest and come nowhere close 

to a balance between motorized and nonmotorized routes. A few more nonmotorized routes might be designated later in implementation-stage planning 

from administrative only and closed routes. But since most recreationally 

desirable routes are already designated and included in the table above, that will 

not greatly improve the imbalance. This is particularly true since the Custer NF 

Travel Plan for the Pryors includes 124 miles of designated motorized routes 

and only a single].6 mile designated non-motorized route.

DRMTDK-BL13-0436-

16

Recreation

While some PC supporters do participate in these activities the list is a very 

incomplete representation of the "visitor services" the public seeks in the Pryors. 

Two of the five categories are hunting. (Some Pryors visitors hunt, most do not.) 

"Vehicle Exploring" is apparently about four-wheeling or ATV cruising. "Viewing 

wild horses" is a narrow category. The only remaining category, "wildlife viewing" 

does not begin to cover the public interest in the Pryors. What about routes 

"associated with" foot or equestrian "exploring"? Or motorized routes for access 

to hiking routes? People are looking for scenery, wildflowers, birds, photography, 

solitude, relaxation, scientific study etc.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

Thank you for your comments. The RMP has been altered to reflect your 

concerns. 

DRMTDK-BL13-0436-

17

Travel mngt

The reason for the seasonal closure should be expanded to include the fact that 

it is winter and the higher elevations are snowed in. Signs and seasonally 

closable barricades like those Custer NF has installed on Big Pryor Mountain 

should be installed.

n

Installation of signs and barricades is an implementation level decision, not an 

RMP level decision and will be addressed in a site specific plan. In accordance 

with the recent “Winter Wildlands Alliance V. US Forest Service” and in 

compliance with EO 11644, the BLM will address snowmobile use as being an 

OHV activity. The text in the RMP has been altered to reflect these comments. 

DRMTDK-BL13-0436-

18

Travel mngt

Only those routes, forks, and branches for which a clear and distinct 

administrative need can be demonstrated should be kept. The rest should be 

decommissioned, and removed from the system.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

DRMTDK-BL13-0436-

19

Travel mngt

The draft RMP does not say much about snowmobiles. Several places it is 

stated that snowmobiles would be " limited to designated routes" in certain areas 

(e.g. ACECs, PMWHR) (2-147, 2-173) and "WSAs would continue to be closed 

to ... snowmobile use" even if Congress releases the areas from wilderness 

consideration (2-169).

n

Following the recent court decision (Winter Wildlands Alliance V. US Forest 

Service) and in compliance with EO 11644, the BLM will address snowmobile 

use as being an OHV activity. The RMP decisions have been altered to reflect 

this. Please see Glossary for definition of “OHV”, Appendix O, and chapters 2, 

3, and 4, Travel and Trail sections. 

DRMTDK-BL13-0436-2

ACEC

Congress could at any time release the WSAs on East Pryor. Then the WSA 

surrogate for ACEC protection would vanish. We do not think the language that 

this area "would be managed as an ACEC" (2-169) is adequate. It should BE an 

ACEC. If Congress does release these WSAs will a whole new process be 

needed to recreate this ACEC if it is canceled in the current RMP?

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS

ACECs are proposed where special management attention is required 

to protect the important and relevant values in relationship to management in 

the BLM preferred alternative in the RMP. Should existing management be 
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present (like a WSA) that protects the relevant and important values then ACEC 

designation is not necessary. Language is included in the RMP that should 

congress (ever) make a decision on wilderness in the Pryors, and this area not 

be designated wilderness, then it would be managed as an ACEC.

As WSAs contain the most restrictive management, there is no need for an 

ACEC to overlap the WSA. The relevant and important values of the East 

Pryor ACEC are addressed through the management of the WSAs. Thank you 

for your comments.

In regards to the overlapping designations of ACEC/Wild Horse Range/WSAs, 

the actual management prescriptions (No Oil and Gas development, etc.) are 

intended to be in place regardless of the land’s designation.

The text in Chapter 2-169 reflects the BLM intent to continue protective 

management actions if Congress releases them from WSA status. 

DRMTDK-BL13-0436-

20

Travel mngt

The RMP says "Motorized travel in TMAs would be limited to designated roads 

and trails." It is not clear whether this statement is intended to include 

snowmobiles. We think the statement should explicitly include snowmobiles as is 

done in other places in the RMP.

n

Following the recent court decision (Winter Wildlands Alliance V. US Forest 

Service) and in compliance with EO 11644, the BLM will address snowmobile 

use as being an OHV activity. The RMP decisions have been altered to reflect 

this. Please see Glossary for definition of “OHV”, Appendix O, and chapters 

2,3, and 4, Travel and Trail sections.

DRMTDK-BL13-0436-

21

Travel mngt

We note the recent (March 2013) Idaho District Court decision that the 

snowmobile exemption in the Forest Service 2005 Travel Management Rule did 

not comply with Executive Order 11644.

y

Thank you for your comment. Following the recent court decision (Winter 

Wildlands Alliance V. US Forest Service) and in compliance with EO 11644, the 

BLM will address snowmobile use as being an OHV activity. The RMP 

decisions have been altered to reflect this. Please see Glossary for definition of 

“OHV”, Appendix O, and chapters 2, 3, and 4, Travel and Trail sections.

DRMTDK-BL13-0436-

22

NEPA The Pryors Coalition is concerned that neither BLM nor CNF appears to have 

any overall Vision or Master Plan for the future of the Pryors. n Thank you for your comment

DRMTDK-BL13-0436-3

ACEC

In Alt A East Pryor ACEC is included in the list of areas "closed to mineral 

material disposals" but is not listed in Alt 0 (2-106). Similarly "mineral materials 

sales and permits" are "not allowed" in East Pryor ACEC in Alt A, but are 

allowed in Alt D (2-147). Surely it is not wise to relax the current protection of this 

very special area. (Is this a mistake in the RMP document?)

N

Thank you for your comments. 

Mineral materials sales and permits are a discretionary action. 

DRMTDK-BL13-0436-4

Oil and Gas we are very concerned about the possibility of mining of fracking sand in the 

Bear Canyon area. n

Thank you for your comment. The BLM is aware of the potential for and interest 

in “frack” sand in the Bear Canyon area. Any proposed activity will be subject to 

the BLM’s 43 CFR 3809 Surface Management Regulations. Actual mining or 

disturbance greater than 5 acres would require the submittal of a Plan of 

Operations and compliance with NEPA. 

DRMTDK-BLTravel mngt Alternative D designates 130 miles of motorized routes and NO non-motorized 

routes. We have not found any discussion in the RMP where the thrust of the y

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 
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13-0436-5 analysis is something balanced and symmetrical-like: "Would particular routes 

be most valuable as a motorized or as non-motorized routes?" Instead the tone 

is " Is there any reason routes should not be motorized?" The presumption 

seems to be that routes should be motorized unless a reason is found for them 

not to be. And there is no indication that "to provide a non-motorized route" was 

ever considered as such a reason. In the Recreation and Visitor Services section 

of Appendix 0 (0-156 to 169) non-motorized activities like hiking, biking and 

equestrian are mentioned (barely) in the first paragraph - but never again. It is 

true as claimed (0-156) that people interested in non-motorized activities also 

use roads, but only as access for other "Visitor Services." The motorized routes 

are not the objective. Different types of motorized routes ("comfortable, low risk" 

or "challenging, high risk driving experiences") are discussed in some detail, but 

non-motorized routes are not mentioned, let alone different types of nonmotorized routes. Non-motorized users should be provided a variety of options, 

including different trail lengths and levels (easy, moderate, strenuous).2 In 

general whenever we use the term "non-motorized" we are referring to hiking, 

equestrian, and mountain bike use. There may be some situations where certain 

of these activities are not appropriate such as mountain bikes in WSAs.

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

The initial work as seen in the draft RMP did not include recent revisions to 

Travel and Transportation planning. BLM Manual 1626 (Travel and 

Transportation) specifies that BLM establish a comprehensive program for both 

motorized and non-motorized travel. This will be done in this RMP. Please refer 

to Appendix O and Table 2.62

DRMTDK-BL13-0436-6

Travel mngt

Equestrians, including the Beartooth Back Country Horsemen, have legitimate 

safety concerns with mixing horses and bicycles. As the number of recreation 

visits to the Pryors continues to increase there may be a need for nonmotorized 

routes closed to mountain bikes.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

This particular comment is not within the scope of the RMP, but it is an 

implementation decision and can be addressed elsewhere.

DRMTDK-BL13-0436-7

Travel mngt

The management plan needs to identify and designate both motorized and nonmotorized routes at the same time in a balanced plan to provide an appropriate 

range of recreational opportunities and to minimize use conflicts. Postponing 

non-motorized designations until later will not work if all the prime routes are 

already designated in the RMP for motorized use. The designation of certain 

tracks for motorized use precludes their designation as non-motorized routes 

later.

y

BLM Manual 1626 (Travel and Transportation) specifies that BLM establish a 

comprehensive program for both motorized and non-motorized travel. This will 

be done in this RMP. Please refer to Appendix O and Table 2.62

DRMTDK-BL13-0436-8

Travel mngt

Most routes are not identified with names or numbers in the RMP on the TMA 

maps or in the text. The key map for the route inventory sheets on the BLM 

website at: http: //www.blm.gov/mt/stJen/folbillings field office/rmp/drmp/travel 

management/pryors.html is incomplete. 54 of the 144 inventoried route 

segments do not have route number labels on the map. Due to the high density 

of routes mapped it is often unclear just which route on the map a route number 

label applies to. Therefore we may not always have the correct route ID number. 

The descriptions should resolve any resulting ambiguity.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

Specifically, though, the maps have been revised and now show route 

numbers. 

DR- Travel The north end of 2 mile of Bear Canyon "road" (In north \t2 of section 3, PM1 n Thank you for your comment.
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MTDK-BL13-0436-9mngt, 

recreation

070) This section in the bottom of the canyon was washed out by a flood in 

spring 2011. It is currently signed closed to motorized use and barricaded. This 

is the only designated non-motorized route in any alternative (Alt B, map 144). In 

Alt 0 this section is designated open to motorized use (map 146). Several 

reasons why this route should be designated for non-motorized use only.1. This 

route is in a sensitive and rare (in the Pryors) riparian area. Bear Canyon is one 

of the few canyons on the south side of the Pryors that has intermittent to 

perennial water available for wildlife. It is also part of a National Audubon 

Society-designated Important Bird Area. Motorized use would significantly 

disturb birds and other wildlife using and dependent on the area.2. This area is 

infested with invasive weeds. 'Efforts to manage those weeds are beginning. 

Motorized use will seriously handicap this effort. Also motor vehicles making a 

quick 1 mile round trip tour into this canyon before going on up the Bear Canyon 

Ridge Rd (PM 1069) would collect weed seeds to distribute throughout the rest 

of Big Pryor Mountain.3. This route is part of an increasingly popular hiking route 

for people who wish to escape motorized commotion. It has been used several 

times already in 2013 by MWA hiking groups. The presence of new cairns 

marking the descent into Bear Canyon indicate additional use by other hikers.4. 

This is a dead end route for motorized use. The old (and illegal) track on north 

into Custer NF is closed to motorized use.

With regard to comment #2, weed infestation: It is a documented fact the 

motorized travel is a vector for the transport of invasive and noxious weeds. 

However, there are many vectors for the transport and deposition of invasive 

and noxious weed seeds, including hiking boots, clothing, pets etc.. Therefore, 

limiting the trail designation to non-motorized would not necessarily eliminate 

the spread of invasive and noxious weeds. Thank you for expressing your 

concerns. While statements of opinion (including agreement or opposition) do 

not require specific responses or text revisions under NEPA regulations, they 

have been considered by the Billings Field Office and Montana State Office and 

documented in the administrative record associated with the Billings and 

Pompeys Pillar National Monument RMP/EIS

In regards to the Bear Canyon route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed”

Refer to map 146

DRMTDK-BL13-0438-1

NEPA

four RMP volumes are 5.5 inches thick and do not include the 2,549 on-line 

pages of Background & Supporting Material for Travel Plan, nor all necessary 

travel mapping. 40CFR part 1500.4 states "Agencies shall reduce excessive 

paperwork by: Reducing the length of environmental impact statements 

(1502.2), by means such as appropriate page limits (1501.7(b)(I) and 1502.7).

N Thank your for your comment. (non substantive)

DRMTDK-BL13-0438-

10

Travel mngt Routes CW2024 and CW2025 should be open to motorized users. This would 

allow access to state land from the west and south for hunting purposes.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS.

In regards to your specific comment regarding access to the Montana State 

Land Parcel, the RMP has a range of possible decisions. In this case, the 

decision to ensure adequate public access resulted in CW 1030, the proposed 

access route, being closed and CW 2024 being designated as “open” while CW 

2025 remains unchanged. 

DRMTDK-BL13-0438-2

Travel mngt

All of the background and supporting information for individual routes that I 

looked at were all dated in 2009. Why wasn't this information available between 

the summer of 2009 and sometime in the latter part of May 2013? The RMP 

process started off well in August and September of 2008 and continued until 

August 2009 with little information from the BLM or dialogue since then until the 

issuance of the RMP DEIS.

n

The BLM hosted a number of public meetings throughout the region in the 

course of preparing this RMP including a series recently once the draft was 

completed, as well as meeting with a number of individuals and organizations 

whenever requested. 
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DRMTDK-BL13-0438-3

NEPA

40CFR1502.22 talks about foreseeable significant adverse effects on the human 

environment in an EIS and there are incomplete or unavailable information, the 

agency shall make clear such information is lacking. Habitat fragmentation, sage 

grouse habitat and cultural resources were factors in the BLM Background & 

Supporting Material for Travel Plan which was not available until after half of the 

comment period had expired. Preferred Alternative D calls for 302 miles of 

Administrative Use Only routes and 59.9 miles of closures which are evaluated 

in the material which was not immediately available or disclosed when the DEIS 

was issued. The documentation and references to habitat and cultural issues 

lead one to believe travel management decisions fall in the adverse effects on 

the human environment discussion.

N

Thank your for your comment. Please see the route reports. All resources and 

resource uses were considered for each route report evaluation. 

DRMTDK-BL13-0438-4

NEPA

I suspect we will have many twists to the sage-grouse issue well into the future. 

How will this affect Montana and its economy in the future; that is the main 

question.

N Thank you for your comment. 

DRMTDK-BL13-0438-5

Travel mngt

Page 3-197 has a table entitled Estimated Number of Vehicles Used OffHighway in Montana (1990-1998), which was used to project regional 

recreational use to 2015. The data is not only out of date but also makes some 

flawed conclusions. For instance, how many of the motorcycles used in the table 

weren't built for off-highway usage?

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS..

DRMTDK-BL13-0438-6

Travel mngt

Route PM1023 is listed as an Open to 50" or Less route. This is a route used by 

all sized vehicles as not only a loop, but a cut across from Helt Road to Crooked 

Creek Road. If this is not changed, some visitors would have to go 

approximately twelve miles out of the way.-There is a switchback north of 

PMl023 which has been used for many years by many recreationists to go from 

Red Pryors Road to Crooked Creek Road. Reading your latest route numbered 

maps, it looks like it goes from PM1017 to PM1025. Alternative D shows the 

route as being closed. This is an important loop and access route which should 

be kept open.

n

Thank you for your comments.

These comments are addressed in the Travel Comments. The vehicle route PM 

1023 and PM 1024 decision has been reviewed by BLM staff and the decision 

is to allow all size vehicle to use PM 1023 The decision for closure of PM 1024 

is that it is a redundant route (PM 1023 provide the same experience and 

opportunity) and it will continue to be closed. 

DRMTDK-BL13-0438-7

Travel mngt There are routes which are not shown on the RMP maps, particularly in the 

Hollenbeck area. n

Thank you for your comments. The BLM has stated that additional routes can 

be added and is aware that in this particular area there are additional existing 

routes. The text in the RMP has been specifically altered to reflect this

DRMTDK-BL13-0438-8

Travel mngt

Looking at the most recent maps which have route numbers, I see routes which 

do not have route numbers or names. Many of these routes are on the 

Cottonwood Weatherman map near the Wyoming border. What is the status of 

this area?

n

In this case, the density of the routes was such that displaying individual routes 

with their numbers was not feasible. The motorcycle routes in the Elk Basin 

area were numbered as being EB 001, EB 002, or EB 003 inclusively. 

In regards to the status of these routes, the RMP has a range of possible 

decisions. In Alternative D, the chosen one, these 103 miles of routes would 

remain open to all types of vehicles. 

DRMTDK-BL13-0438-9

Travel mngt

Routes PMlO71 and PM1072 should be considered for opening to OHV travel. 

This is a connector loop which ties into Bear Canyon Road PM1067. Neither 

route indicates habitat or cultural issues.

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 
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associated with the Billings and Pompeys Pillar National Monument RMP/EIS

In regards to the two routes mentioned, the RMP has a range of possible 

decisions. In this case, due to the conditions documented in the Route 

Inventory the Alternative D has been chosen to best meet regulatory 

obligations. The routes will be designated as “closed”

Refer to map 146

DRMTDK-BL13-0440-1

Wildlife The plan should clearly document its analysis of the NTT report 

recommendations n

The NTT report (or BER, or COT) is not the sole source of management 

decisions for the range of alternatives. A National Technical Team (NTT) was 

formed as an independent, science-based team to ensure that the best 

information about how to manage the greater sage-grouse is reviewed, 

evaluated, and provided to the BLM and the Forest Service in the planning 

process. The group produced a report in December 2011 that identified 

science-based management considerations to promote sustainable greater 

sage-grouse populations. The NTT is staying involved as the BLM and the 

Forest Service work through the Strategy to make sure that relevant science is 

considered, reasonably interpreted, and accurately presented; and that 

uncertainties and risks are acknowledged and documented. 

A baseline environmental report, titled Summary of Science, Activities, 

Programs, and Policies That Influence the Rangewide Conservation of Greater 

Sage-grouse (Centrocercus urophasianus) (referred to as the BER), was 

released on June 3, 2013, by the U.S. Geological Survey. The peer-reviewed 

report summarizes the current scientific understanding about the various 

impacts to greater sage-grouse populations and habitats and addresses the 

location, magnitude, and extent of each threat. The BER does not provide 

management options. The report is being used by the BLM and the Forest 

Service in our efforts to develop regulatory mechanisms and improve our 

conservation efforts of the greater sage-grouse and its habitat to reduce the 

potential for listing it under the Endangered Species Act. The data for this report 

were gathered from BLM, Forest Service, and other sources and were the "best 

available" at the range-wide scale at the time collected. The report provides a 

framework for considering potential implications and management options, and 

demonstrates a regional context and perspective needed for local planning and 

decision-making.

In March 2012, the FWS initiated a collaborative approach to develop rangewide conservation objectives for the greater sage-grouse to inform the 2015 

decision about the need to list the species and to inform the collective 

conservation efforts of the many partners working to conserve the species. In 

March 2013, this team of State and FWS representatives, released the 

Conservation Objectives Team (COT) report based upon the best scientific and 

commercial data available at the time that identifies key areas for greater sage-
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grouse conservation, key threats in those areas, and the extent to which they 

need to be reduced for the species to be conserved. The report serves as 

guidance to Federal land management agencies, State greater sage-grouse 

teams, and others in focusing efforts to achieve effective conservation for this 

species.

The range of alternatives is based upon analysis of public scoping comments 

as well as information provided in the NTT report, the BER, the COT report, and 

State management plans. The alternatives represent different degrees of and 

approaches to balancing resources and resource use among competing human 

interests, land uses, and the conservation of natural and cultural resource 

values, while sustaining and enhancing ecological integrity across the 

landscape, including plant, wildlife, and fish habitat.

Greater sage-grouse conservation measures in A Report on National Greater 

Sage-grouse Conservation Measures (NTT 2011) were used to form BLM and 

the Forest Service management direction under at least one alternative 

(Alternative B and portions of D), which is consistent with the direction provided 

in BLM Washington Office Instruction Memorandum 2012-044 (the BLM must 

consider all applicable conservation measures developed by the NTT in at least 

one alternative in the land use planning process). 

Additionally, all alternatives considered within this planning process are 

consistent with conservation measures and objectives outlined in the COT 

Report and follow the basic principles of: (1) avoiding the impact of an activity; 

(2) minimizing impacts by limiting the degree of activity; and (3) mitigating for an 

impact by improving or enhancing greater sage-grouse habitat. Each of the 

alternatives considers different means for accomplishing this strategy. For 

example, some alternatives place greater emphasis on avoidance of impacts, 

whereas other alternatives place more emphasis on minimization and 

mitigation.

While there was consistent direction provided in alternative develop, such as 

BLM WO IM 2012-044, variation across sub-regionals was needed to

accommodate the local issues and specific state and Forest Service 

requirements.

DRMTDK-BL13-0440-

10

Wildlife

The BLM has the greatest opportunity to affect the status of the white-tailed 

prairie dog, a BLM special status species (note: Table 3-26 at p. 3-77 should 

note that the white-tailed prairie dog is an S1 state species of concern listing, the 

highest level of threat under MFWP assessment16). Defenders is pleased to see 

this is a priority for BLM (Draft Billings RMP, Alternatives, Table 2.61, p. 274). As 

noted in the Draft RMP, the most current estimate of white-tailed prairie dogs in 

2005 on BLM lands was precipitously low (Billings Draft RMP, Affected 

Environment, Table 3-28, p. 380-81), in the order of 100-200 acres. Segland et 

al. (2005) stated that "The current observed decline of the WTPD in Montana 

n

Thank you for the comment. Refer to Chap. 2, pages 2-74 and 75. Note that 

prairie dog management is subject to the, “Conservation Plan for Black-tailed 

and White-tailed prairie dogs in Montana, 2002”, along with several alternatives 

described. Best Management Practices or conservation strategies are 

discussed in that plan.

In reference to shooting the 2002 plan states, “Management regulations for 

prairie dogs will be jointly established by Fish, Wildlife & Parks, and the Fish, 

Wildlife & Parks Commission and subject to public review in the same manner 

as annual rules are established for other species. Regulations pertaining to 
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during this century represents a range contraction for the species, and risk of 

extirpation in the short-term is high." The BLM has previously proposed, in 

cooperation with Montana Fish, Wildlife and Parks ("FWP") a translocation 

program to increase white-tailed prairie dogs on BLM lands (consistent with 

Wildlife alternative D in Draft Billings RMP, Alternatives, Table 2-6.1, p. 2-75 

(and see Segland et al. 2005). However, this proposal did not materialize. 

Although the BLM may not control the majority of surface area occupied by 

white-tailed prairie dogs (Segland et al 2005)17, BLM lands may be the last best 

hope for the white-tailed prairie dog in Montana given the BLM's resources and 

statutory obligation to protect them and their habitat. Therefore Defenders urges 

the BLM to implement the translocation activity. Second, and critically, the BLM 

must enact shooting closures on white-tailed prairie dog colonies immediately, 

and this should be specified in the RMP. As Segland et al noted, "MFWP and 

the Montana Fish, Wildlife, and Parks Commission adopted a year-round 

shooting closure on WTPDs throughout their range in Montana (not including 

school state trust lands, private, or tribal lands) beginning March 2002. An 

extension of this closure was approved in 2003 and 2004." However, the 

Montana legislature refused to extend the management designation for prairie 

dogs in 2007, and has failed to give Montana Fish, Wildlife, and Parks 

management authority to take action to conserve or manage prairie dogs, 

including regulating the take of prairie dogs. Given this void, the BLM truly needs 

to take the initiative to meet its statutory mandate in the planning area. 

Defenders commends the BLM for recognizing its responsibility and cooperating 

in past conservation efforts, but this gap in conservation protection from shooting 

needs to be remedied in order for the BLM to meet its statutory obligations. 

Shooting pressure can result in extinction of small colonies and is likely to impair 

any ability of existing colonies to grow (see review by Segland et al 2005). 

Without an annual shooting closure, unregulated take of white-tailed prairie dogs 

could lead to their demise in Montana, which would in turn be a significant 

change in their range-wide status.

prairie dog shooting will be evaluated on an annual basis.”

Note that white-tailed prairie dogs were translocated in 2006 from dog towns 

disturbed from Highway #72 construction near Belfry to a Historic dog town 

location through a cooperative project with Montana Fish, Wildlife, and Parks.

Prairie dogs are considered BLM Special Status Species (I.M. MT-2009-039) 

and will be considered in all activities proposed on public lands.

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Further, Defenders urges the BLM to adopt as part of this plan, a statement of 

"best management practices"18 for black-tailed and white-tailed prairie dogs that 

includes at a minimum the following:1) Shooting closures/management Shooting 

has significant effects on prairie dog populations (Pauli 2005; Keffer et al. 2000; 

Segland et al 2005). BLM needs to close at least some core habitat within each 

conservation area it identifies to shooting. Shooting closures initiated by federal 

managers to maintain black-footed ferret habitat currently exist on federal lands 

in South Dakota, Wyoming, Colorado and in the past, in Montana as well. The 

BLM has the legal authority to regulate prairie dog shooting on BLM lands (see, 

e.g., 64 Fed. Reg. 56213 (Oct.18, 1999). Colonies free of shooting will provide 

refugia where prairie dog production, instead of being taken by shooters, can 

n

Thank you for the comment. Refer to Chap. 2, pages 2-74 and 75. Note that 

prairie dog management is subject to the, “Conservation Plan for Black-tailed 

and White-tailed prairie dogs in Montana, 2002”, along with several alternatives 

described. Best Management Practices are discussed in that plan.

In reference to shooting the 2002 plan states, “Management regulations for 

prairie dogs will be jointly established by Fish, Wildlife & Parks, and the Fish, 

Wildlife & Parks Commission and subject to public review in the same manner 

as annual rules are established for other species. Regulations pertaining to 

prairie dog shooting will be evaluated on an annual basis.”
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provide a source of prairie dogs to "restock" colonies that are decimated by 

shooting elsewhere and by plague. New access roads should avoid intersecting 

a prairie dog colony or bisecting two adjacent colonies, to avoid access by 

recreational shooters (see, e.g. BLM 2007, recommendation 9). Work with 

Montana Fish, Wildlife and Parks to reestablish restrictions on prairie dog 

shooting, including both seasonal closures for non-priority areas and annual 

closures for priority and white-tailed prairie (see, e.g. BLM 2007, 

recommendation 14).2) Poisoning Ensure there is no unauthorized control of 

prairie dogs on BLM lands. Prairie dog control on public land should not be 

authorized except for human health and safety reasons (see e.g. BLM 2007, 

recommendation 7). Notify the public that unauthorized use of poisons for prairie 

dog control is not allowed on BLM lands (see e.g. BLM 2007, recommendation 

8). 3) Prairie dog expansion/supplementation Utilize translocations of prairie 

dogs and other habitat enhancing techniques to maximize the footprint of prairie 

dog occupancy in white-tailed prairie dogs and to meet statewide Category 1 

and 2 contributions for black-tailed prairie dogs. Establish land stewardship 

agreements with other agencies and/or private landowners where large (1,000 

acre) prairie dog towns or complexes exist adjacent to BLM land ownership. 

These agreements can control potential uses that may be detrimental to prairie 

dogs and their habitats, while preserving the landowner's intent for use (see e.g. 

BLM 2007 recommendation 17).The BLM should avoid the sale or exchange of 

lands with prairie dogs and should attempt to acquire parcels with prairie dogs 

on them (see e.g. BLM 2007 recommendation 16). BLM should review the list of 

disposal property in Appendix H of the Draft RMP to confirm that it is not 

disposing of property that has had active prairie dogs in the past 10 years or that 

may contribute to a Category 1, 2, or 3 prairie dog conservation goals. 

Defenders believes that prairie dog management will be more effective if an 

aggressive program of land consolidation is undertaken throughout the planning 

area generally. Retention of lands inside conservation priority areas should be 

specifically incorporated into retention and acquisition priority criteria. 

Consolidating BLM management in priority areas will reduce potential prairie dog 

edge conflicts with neighbors and allow for more efficient administration.4) 

Plague management Current plague mitigation for prairie dogs involves 

application of deltamethrin dust (Biggins et al 2010), which has been shown to 

be effective in suppressing flea populations, thus interdicting plague outbreaks in 

prairie dogs. Currently some half dozen black-footed ferret reintroduction areas 

in the U.S. and Canada deploy deltamethrin as part of the management regime 

for black-footed ferret and prairie dog conservation. BLM needs to consider use 

of deltamethrin or other plague management tools to maintain prairie dog 

numbers, particularly in white-tailed prairie dogs and in some subset of colonies 

within priority zones to maintain prairie dog colonies for prairie dog associates 

Note that white-tailed prairie dogs were translocated in 2006 from dog towns 

disturbed from Highway #72 construction near Belfry to a Historic dog town 

location through a cooperative project with Montana Fish, Wildlife, and Parks.

Prairie dog poisoning has not been authorized on public lands in the Billings 

Field Office.

Prairie dogs are considered BLM Special Status Species (I.M. MT-2009-039) 

and will be considered in all activities proposed on public lands.

Currently, several dynamic factors are influencing prairie dog management. 

These include plague and vaccine research, landowner incentive programs, 

prairie dog town mapping, complex Category designations (1, 2, 3), and blackfooted ferret reintroduction. BLM is actively participating in the Prairie Dog 

Working Group and will support plans and research results developed by the 

group.

According to the Glossary definition, page 5, “Black-footed ferret habitat: a 

complex of prairie dog towns within 1.5 kilometers of each other comprising a 

total of 1,000 acres.” , there is not Category 1, black-footed ferret habitat, on 

public lands within the field office. The potential may exist if other land 

ownerships are considered in complex designations.

All Special status species, including prairie dogs, are considered during the 

Grazing Permit Renewal process.
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and potential future blackfooted ferret reintroduction.5) Surface disturbance 

Further oil and gas exploration and development should be excluded on 

occupied prairie dog colonies. Defenders supports the NSO designation within 1⁄4 

mile for all prairie dog colonies in the Preferred Alternative D. Defenders 

disagrees, however, with stipulations described for mountain plovers (Draft 

Billings RMP, Appendices H, p. H-25-26), and recommends that NSO be 

extended, without waivers, to all mountain plover habitat (prairie dog colonies), 

regardless of plover occupancy or season of use. More importantly, it is not 

known to what extent prairie dog colony dependent grassland birds such as 

mountain plovers, burrowing owls and ferruginous hawks may exhibit avoidance 

behavior to oil and gas field development activity, so any surface occupancy 

needs to be adaptively managed to avoid loss of nesting habitat for plovers. 

When drilling multiple oil or gas wells, if geologically and technically feasible, drill 

from the same pad using directional (horizontal) drilling technologies (up to 16 

wells per pad, as technologically feasible) to lessen surface impacts on prairie 

dog colonies/towns (see, e.g. BLM 2007, recommendation 21).When possible, 

no seismic activity should be allowed in occupied or recovering prairie dog 

habitat (see e.g., BLM 2007, recommendation 11).BLM should amend rights-ofway classification to include "exclusion" for all prairie dog colonies (for mountain 

plover and other associated species), with the exception of allowing small scale, 

non-surface (buried) transmission within 500 feet of an existing road (see Draft 

Billings RMP, Alternatives, Table 2- 6.2, p. 2-111 et seq.).While prairie dog 

habitat can be maintained with some loss to surface disturbance (see e.g. Clark 

et al 1986), surface mining of coal, gravel, bentonite and other minerals is 

essentially a complete surface conversion and therefore incompatible with 

maintaining prairie dog habitat, including intra-colony areas needed for 

connectivity within prairie dog complexes. Therefore, these activities should also 

be "excluded" for all prairie dog colonies.6) Organizational/coordination steering 

committee should be formed to develop and prioritize management practices 

and assist BLM and other stakeholders in prairie dog conservation efforts (see 

e.g., BLM 2007, Recommendation 12). The Billings Field Office should continue 

to participate in the Montana Prairie Dog Working Group and actively participate 

in its implementation (BLM 2007, recommendation 13). The Billings Field Office 

should participate in efforts to remove unprotected status of prairie dogs in 

conjunction with the Montana Prairie Dog Working Group (see e.g., BLM 2007, 

recommendation 14). BLM should encourage, support, and/or establish a prairie 

dog research program, addressing issues such as: The effect(s) of oil and gas 

development on prairie dogs, sylvatic plague control and population viability 

analysis.7) Grazing Miles City STANDARD #5 of the Standards for Rangeland 

Health and Guidelines for Livestock Grazing Management for Public Lands 

Administered by the Bureau of Land Management for Montana and the Dakotas: 
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provides that "habitats are improved or maintained for special status species 

(federally threatened, endangered, candidate or Montana species of special 

concern)." (Draft Billings RMP, Appendix I).This means that native plant 

communities will be "maintained or improved to ensure the proper functioning of 

ecological processes and continued productivity and diversity of native plant life 

forms. Where native communities exist, the conversion to exotic communities 

after disturbance will be minimized. "On any given grazing allotment containing 

prairie dogs, the Bureau and grazing permittee should manage for a mosaic of 

range conditions (see e.g., BLM 2007 recommendation 9). Areas occupied by 

prairie dogs may have reduced vegetation while other areas of the allotment 

which do not contain prairie dogs may have thicker stands of grass and forbs.

DRMTDK-BL13-0440-

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Wildlife 

Ensure that prairie dog conservation is being addressed on all livestock permit 

renewal evaluations and associated environmental assessments for oil and gas 

developments, rights-of-way grants, organized recreational events, etc. (see 

e.g., BLM 2007, recommendation 17).

n

Thank you for the comment. The BLM addresses these concerns in NEPA 

documentation during routine operations. This is not an RMP issue. Prairie 

dogs are considered BLM Special Status Species (I.M. MT-2009-039) and will 

be considered in all activities proposed on public lands.

DRMTDK-BL13-0440-

13

Livestock 

Grazing

Grazing should be reduced or eliminated during drought. Practices should avoid 

vegetation stand conversions (BLM 2007, Recommendation 18). n

In Table 2-6.2 on page 2-116 of the DRMP under management common to all 

alternatives it is stated “During periods of drought, adjust livestock numbers 

commensurate with the needs of other resources in the area (riparian, wildlife, 

etc.)

In Table 2.6.1, pages 2-59 and 2-60 of the DRMP, there are several 

management actions prescribed under the alternatives to improve the resiliency 

of the native vegetative communities which would reduce the likelihood of 

vegetative stand conversions. There are varied action alternatives (page 2-60) 

to convert non-native crested wheatgrass seedings to native vegetative 

communities.

DRMTDK-BL13-0440-2

Wildlife

The MMCAs were purportedly used in the RMP and EIS process as a tool to 

help develop management alternatives (AB-1). However, it is unclear how they 

influenced alternative development in the plan. Given the mixed derivation of 

Appendix M, it is also unclear if the DRMP/EIS analyzed the entirety of the NTT 

recommendations as directed by the Washington Office (BLM Memo 2012-044), 

or only some of the NTT prescriptions mixed in with recommendations from 

other sources.

n

Thank you for your comment.

In response to the greater sage-grouse management objectives described in 

the 2006 WAFWA Greater Sage-grouse Comprehensive Conservation 

Strategy, many reports have been prepared for the development of 

management recommendations, strategies, and regulatory guidelines. The 

National Technical Team report (NTT 2011), Conservations Objectives Team 

(COT; FWS 2013), and the Summary of Science, Activities, Programs and 

Policies that Influence the Rangewide Conservation of Greater Sage-Grouse 

(also referred to as the Baseline Environmental Report [BER]; Manier et al. 

2013) are the most widely used reports that have been incorporated in BLM 

and Forest Service EISs that address the effects of implementing greater sagegrouse conservation measures on lands they manage.

Management actions by the BLM and the Forest Service in concert with other 

State and Federal agencies, and private land owners play a critical role in the 

future trends of greater sage-grouse populations. To ensure management 
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actions are effective and based on the best available science, the BLM’s 

National Policy Team created a NTT in August 2011. The objective for 

chartering this planning strategy effort was to develop new or revised regulatory 

mechanisms, through land use plans, to conserve and restore greater sagegrouse and their habitat on BLM-administered lands on a range‐wide basis over 

the long term. The NTT report (NTT 2011) used the best current scientific

knowledge to guide the BLM and the Forest Service planning efforts through 

management considerations to ameliorate threats, focused primarily on priority 

greater sage-grouse habitats on public lands. 

On December 27, 2011, the BLM released IM 2012-044. In accordance with 

this IM, the BLM must consider all conservation measures developed by the 

NTT in at least one alternative in the land use planning process. For the 

majority of greater sage-grouse DRMP/EISs, Alternative B fulfills this 

requirement by incorporating the recommendations set forth by the NTT. Other 

alternatives, including those developed by individuals and conservation groups, 

as well sub-regional alternatives developed by regional offices of the BLM and 

the Forest Service, have incorporated elements of the NTT report. 

The COT report (FWS 2013) qualitatively identifies threats/issues that are 

important for individual populations across the range of greater sage-grouse, 

regardless of land ownership. The Summary of Science, Activities, Programs 

and Policies that Influence the Rangewide Conservation of Greater SageGrouse (also referred to as the Baseline Environmental Report [BER]; Manier et 

al. 2013) then provides complimentary quantitative information to support and 

supplement the conclusions in the COT. Both documents helped planning 

teams identify issues within their planning area, determine the context within 

the management zone, prioritize habitats, and assist in creating a range of 

alternatives with management actions that can alleviate or mitigate threats to 

greater sage-grouse at an appropriate level. Both the NTT report and the COT 

report tier from the WAFWA Greater Sage-grouse Comprehensive 

Conservation Strategy (Stiver et al. 2006).

Alternative B and portions of Alternative D are based on A Report on National 

Greater Sage-grouse Conservation Measures (NTT report) per direction in IM 

2012-044. Conservation measures included in the NTT based alternative focus 

primarily on greater sage-grouse PPH and include a 3-percent disturbance cap 

in PPH. PPH areas have the highest conservation value to maintaining or 

increasing greater sage-grouse populations. 

DRMTDK-BL13-0440-3

NEPA

The DRMP/EIS acknowledges that climate change poses a challenge to 

resource management (3-26 -“ 3- 29) and notes that "sensitive species in the 

planning area, such as the greater sage-grouse, which are already stressed by 

declining habitat, increased development, and other factors, could experience 

additional pressures due to climate change" (3-28; 4-39) (effects of climate 

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 
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change could have "very serious impacts" on sage-grouse, 4-39). These 

additional stressors may include reduced soil moisture, increased drought, 

diminished water quantity, and increased wildfire (3-25, 3-27, 3-28). However, 

rather than planning for the anticipated and cumulative effects of climate change 

on sage-grouse and sagebrush habitats in the DRMP/EIS, the plan instead 

defers to an adaptive management strategy to be applied, as appropriate, to 

future management activities in the planning area (2-52, 2-57). Leaving climate 

adaptation to future project-level decision making could make it difficult to 

implement needed prescriptions that are not already analyzed and approved in 

the RMP. For example, livestock grazing is known to reduce ecosystem 

resilience to climate change (Beschta et al. 2012), and the DRMP/EIS appears 

to acknowledge that new grazing strategies could improve resilience (4-43), but 

the plan does not specifically approve taking definitive action to modify grazing 

systems to achieve this goal. The DRMP/EIS should support future decision 

making by land managers by identifying and analyzing specific measures that 

can be implemented across the planning area to address the negative impacts of 

climate change on sage-grouse and sagebrush steppe.

RMP/EIS. Please see Appendix AA. 

DRMTDK-BL13-0440-4

Wildlife

The DRMP/EIS declined to separately analyze the Sage-Grouse Recovery 

Alternative (www.sagebrushsea.org/land_recovery_alternative.htm), a 

management alternative submitted by conservation organizations to conserve 

and recover sage-grouse populations. The DRMP/EIS contends that 

components of the "conservation groups alternative" were substantially 

considered in the range of other alternatives analyzed in the plan (2-16)-

”although it is unclear whether the DRMP/EIS is referring specifically to the 

Recovery Alternative, since different conservation organizations submitted at 

least three different conservation alternatives to BLM during the scoping process 

for the National Greater Sage-Grouse Planning Strategy. The Sage-Grouse 

Recovery Alternative, though based on the NTT report recommendations, makes 

additional and stronger management prescriptions for a number of land uses 

and related effects in sagegrouse range, including livestock grazing, vegetation 

management, invasive plants, and fire management. These recommendations 

were not analyzed together or individually in the DRMP/EIS. Moreover, given 

that sage-grouse populations may continue to decline under the DRMP/EIS (4-

285), the BLM should analyze the complete Sage-Grouse Recovery Alternative 

as a possible strategy to conserve and restore sage-grouse populations and 

potentially preclude the need to list the species under the ESA.

n

Thank you for your comment. The “Conservation Groups Alternative” on page 

2-16 of the DRMP was described as a “Alternative Considered, but not 

Analyzed in Detail.” The explanation for this is included in this section.

DRMTDK-BL13-0440-5

Wildlife

The DRMP/EIS asserts that expected impacts from land uses and related effects 

on sage-grouse and sagebrush habitat in priority protection areas under the 

preferred alternative (Alternative D) would be similar to impacts under Alternative 

B, the conservation alternative (2-184 -“ 2-185, Table 2-7; 4-281; 4- 567), which 

prescribes more restrictive management than Alternative D (2-165 -“ 2-167, 

N

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the B&PPNM RMP/EIS. 
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Table 2-6.3) and would also designate priority habitat as an ACEC (4-567).2 

Such a contention is illogical and without basis. As the plan notes elsewhere, the 

proposed management of ACECs is the most restrictive for resource uses (2-31) 

and the Greater Sage-grouse Habitat ACEC would offer the greatest protection 

for sage-grouse (4-287). Alternative B would close priority habitat to fluid 

minerals development and exploration, as well as material minerals extraction; 

exclude renewable energy development in priority areas; close the areas to 

locatable mineral extraction, and recommend them for withdrawal; specially 

manage roads to minimize impacts on sage-grouse; restrict the use of 

prescribed fire in priority habitat and protect sage-grouse leks from heavy 

equipment used in fire suppression (2-165 -“ 2-167, Table 2-6.3). Alternative B 

would also limit discrete anthropogenic disturbances to less than 3% in priority 

sage-grouse habitat. In comparison, land use prescriptions under the preferred 

alternative are more flexible and could allow more development in sage-grouse 

priority habitat (see Table 1). While the plan (in apparent contradiction with the 

statements cited above) acknowledges that "[m]management actions would be 

less beneficial to wildlife and special status species [under the preferred 

alternative] than actions provided under Alternative B," a thorough analysis of 

environmental consequences on sage-grouse and sagebrush steppe is lacking. 

The plan should more clearly and more thoroughly analyze the anticipated 

effects of the alternative management regimes on sage-grouse. The Miles City 

and HiLine draft RMPs could be useful examples for how to analyze 

environmental consequences of plan alternatives.

Please see crosswalk table in the sage-grouse Appendices AA and AB to see 

management by alternative for sage-grouse.

DRMTDK-BL13-0440-6

Wildlife

The plan should examine whether management alternatives comply with the 

BLM sensitive species policy. Greater sage-grouse are a candidate species for 

listing under the Endangered Species Act (ESA) and a designated Bureau of 

Land Management "sensitive species" across their range. BLM's policy directs 

that actions authorized, funded or implemented by BLM do not contribute to the 

need to list a candidate species under the ESA (BLM WO IM 97-118; BLM 

Manual 6840). Unfortunately, and even with a liberal reading of the DRMP/EIS, it 

is unclear from the brief, general analysis included in the plan (4-285 -“ 4-287) 

whether and which alternatives might comply with the agency's sensitive species 

policy as applied to sage-grouse. There are also some problems with the current 

plan that may need to be addressed before BLM can proceed with a sound 

examination of this question. First, any assessment of the preferred alternative 

may be compromised by potential implementation of a plethora of waivable and 

discretionary BMPs and MMCAs incorporated in the alternative (see above). It is 

unlikely that future project-level decision making would completely, consistently 

apply these measures throughout the planning area and over the life of the plan. 

In fact, any analysis of Alternative D should assume that the potential benefits of 

conservation measures to sage-grouse would likely be less than if all of these 

n

Thank you for the comment. BLM can only manage resources and habitat on 

public lands. Although Alternative D is the ‘preferred alternative”, any range of 

the alternatives can be selected in the Final Decision Record for the RMP/ EIS 

to comply with the sensitive species policy.

The statement on page 2-184, Table 2.7, will be revised to, “Alternative D will 

provide less protection to wildlife resources than Alternative B due to smaller 

buffers and fewer exclusion areas for potential development.”

The subject of the remaining comments are beyond the scope of the RMP/EIS.
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measures were compulsory. Second, the relatively shallow analysis and 

occasionally schizophrenic comparison of Alternatives B and D in the plan ("[t]he 

impacts to wildlife and [Special Status Species], (sic) would be the same under 

Alternative D as those described under Alternative B, with less protection to 

wildlife resources due to smaller buffers and fewer exclusion areas for potential 

development," 2-184, Table 2.7) must be expanded and clarified in order to 

provide a basis for determining whether these alternatives comply with the BLM 

sensitive species policy (see above).Even accounting for the uncertainties and 

ambiguities in the current analysis, it is likely that management under all 

alternatives would continue to impact sage-grouse (4-285). Existing and 

foreseeable energy development on all land ownerships in the planning area (4-

285 -“ 4-286; 3-164; Map 24); inadequate protections in general habitat areas 

(e.g., 0.6-mile lek buffers, 2-45, Table 2-5); and agricultural conversion on 

private lands (4-287 -“ 4-288) would all likely negatively affect sage-grouse 

populations.

DRMTDK-BL13-0440-7

Wildlife

The plan should incorporate important, new information concerning sage-grouse 

and sagebrush steppe. The following new information related to sage-grouse 

and sagebrush steppe was published during preparation of the Billings-PPNM 

DRMP/EIS and should be considered in the plan, as appropriate.1. Beschta, R. 

L., D. L. Donahue, D. A. DellaSala, J. J. Rhodes, J. R. Karr, M. H. O'Brien, T. L. 

Fleischner, C. Deacon-Williams, Cindy. 2012. Adapting to climate change on 

western public lands: addressing the ecological effects of domestic, wild, and 

feral ungulates. Environmental Management, available at 

http://fes.forestry.oregonstate.edu/sites/fes.forestry.oregonstate.edu/files/PDFs/

Beschta/Beschta_2 012EnvMan.pdf.Â· Domestic livestock and other ungulates 

alter vegetation, soils, hydrology, and wildlife species composition and 

abundances that exacerbate the effects of climate change on western 

landscapes. Removing or reducing livestock grazing across large areas of public 

land would alleviate a widely recognized and long-term stressor and make 

ecosystems less susceptible to the effects of climate change.2. Knick, S. T., S. 

E. Hanser, K. L. Preston. 2013. Modeling ecological minimum requirements for 

distribution of greater sage-grouse leks: implications for population connectivity 

across their western range, U.S.A. Ecology and Evolution, available at 

http://onlinelibrary.wiley.com/doi/10.1002/ece3.557/pdf.Â· Sage-grouse require 

sagebrush-dominated landscapes containing minimal levels of anthropogenic 

disturbance. Ninety-nine percent of remaining active sage-grouse leks were in 

landscapes with less than 3 percent disturbance within 5 km of the lek, and 79 

percent of the area within 5 km was in sagebrush cover.3. Patricelli, G. L., J. L. 

Blickley, S. L. Hooper. 2012. The impacts of noise on greater sage-grouse: a 

discussion of current management strategies in Wyoming with recommendations 

for further research and interim protections. Unpublished repot. Prepared for the 

n

Before beginning the B&PPNM RMP/EIS and throughout the planning effort, 

the BLM and the Forest Service considered the availability of data from all 

sources, adequacy of existing data, data gaps, and the type of data necessary 

to support informed management decisions at the land-use plan level. The data 

needed to support broad-scale analysis of the Billings Field Office planning 

area are substantially different than the data needed to support site-specific 

analysis of projects. The RMP/EIS data and information is presented in map 

and table form and is sufficient to support the broad scale analyses required for 

land use planning. 

The BLM and the Forest Service used the most recent and best information 

available that was relevant to a land-use planning-level analysis including the 

Baseline Environmental Report (BER; Manier et al. 2013). The BER assisted 

the BLM and the Forest Service in summarizing the effect of their planning 

efforts at a range-wide scale, particularly in the affected environment and 

cumulative impacts sections. The BER looked at each of the threats to greater 

sage-grouse identified in the Fish and Wildlife Service’s “warranted but 

precluded” finding for the species. For these threats, the report summarized the 

current scientific understanding, as of report publication date (June 2013), of 

various impacts to greater sage-grouse populations and habitats. The report 

also quantitatively measured the location, magnitude, and extent of each threat. 

These data were used in the planning process to describe threats at other 

levels, such as the sub-regional boundary and WAFWA Management Zone 

scale, to facilitate comparison between sub-regions. The BER provided data 

and information to show how management under different alternatives may 

meet specific plans, goals, and objectives. 

Additionally, the BLM and the Forest Service consulted with, collected, and 
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Bureau of Land Management, Lander Field Office and Wyoming State Office, 

Cheyenne and Wyoming Game and Fish Department; available at 

http://www.wy.blm.gov/jio-papo/papo/wildlife/reports/sagegrouse/ 

2012sgNoiseMon.pdf.Â· Maximum noise levels from land use and development 

allowed under the Wyoming state sage-grouse core area policy near sagegrouse leks and other habitat are untested, may be difficult to measure, and may 

be too high to support sage-grouse conservation within and outside core 

areas.4. Reisner, M. D., J. B. Grace, D. A. Pyke, P. S. Doescher. 2013. 

Conditions favoring Bromus tectorum dominance of endangered sagebrush 

steppe ecosystems. Journal of Applied Ecology, available at 

http://onlinelibrary.wiley.com/doi/10.1111/1365-2664.12097/pdf.Â· Cattle grazing 

exacerbates cheatgrass (Bromus tectorum) dominance in sagebrush steppe by 

decreasing bunchgrass abundance, shifting and limiting bunchgrass 

composition, increasing gaps between perennial plants, and trampling biological 

soil crusts. Grazing was also not found to reduce cheatgrass cover, even at the 

highest grazing intensities.5. Copeland, H. E., A. Pocewicz, D. E. Naugle, T. 

Griffiths, D. Keinath, J. Evans, J. Platt. 2013. Measuring the effectiveness of 

conservation: a novel framework to quantify the benefits of sagegrouse 

conservation policy and easements in Wyoming. PLoS ONE 8(6): e67261. 

doi:10.1371/journal.pone.0067261. Available at 

www.plosone.org/article/fetchObject.action?uri=info%3Adoi%2F10.1371%2Fjour

nal.pone.0067 261&representation=PDF.Â· Modeling indicates that the 

Wyoming sage-grouse core area conservation strategy, fully applied, plus $250 

million invested in targeted conservation easements, would slow, but not stop 

projected sage-grouse population declines in the state. The Wyoming core area 

policy prohibits or restricts surface occupancy within 0.6 miles of sage-grouse 

leks, generally limits development to one site per 640 acres, and limits 

cumulative surface disturbance to 5 percent per 640 acres in core habitat.6. 

Manier, D. J., D. J. A. Wood, Z. H. Bowen, R. M. Donovan, M. J. Holloran, L. M. 

Juliusson, K. S. Mayne, S. J. Oyler-McCance, F. R. Quamen, D. J. Saher, A. J. 

Titolo. 2013. Summary of science, activities, programs, and policies that 

influence the rangewide conservation of greater sage-grouse (Centrocercus 

urophasianus). U.S. Geological Survey, Open-File Report 2013-“ 1098; available 

at http://pubs.usgs.gov/of/2013/1098/.

incorporated data from other agencies and sources, including but not limited to 

the U.S. Fish and Wildlife Service and Montana Fish, Wildlife and Parks. 

As a result of these actions, the BLM and the Forest Service gathered the 

necessary data essential to make a reasoned choice among the alternatives 

analyzed in detail in the DRMP/EIS, and provided an adequate analysis that led 

to an adequate disclosure of the potential environmental consequences of the 

alternatives see Chapter 4. As a result, the BLM and the Forest Service have 

taken a “hard look,” as required by the NEPA, at the environmental 

consequences of the alternatives in the DRMP/EIS to enable the decision 

maker to make an informed decision. Finally, the BLM and the Forest Service 

have made a reasonable effort to collect and analyze all available data. 

The requisite level of information necessary to make a reasoned choice among 

the alternatives in an EIS is based on the scope and nature of the proposed

decision. The baseline data provided in Chapter 3 and various appendices 

including in the B&PPNM RMP/EIS is sufficient to support, at the general land 

use planning-level of analysis, the environmental impact analysis resulting from 

management actions presented in the DRMP/EIS. 

A land use planning-level decision is broad in scope and, therefore, does not 

require an exhaustive gathering and monitoring of baseline data. Although the 

BLM and the Forest Service realize that more data could always be gathered, 

the baseline data provides the necessary basis to make informed land use 

plan-level decisions. Land use plan-level analyses are typically broad and 

qualitative rather than quantitative or focused on site-specific actions (BLM 

Land Use Planning Handbook H-1601-1, Chapter II, A-B at 11-13 and Chapter 

IV, B at 29; Forest Service Handbook 1909.12 – Land Management Planning). 

The BLM and the Forest Service will conduct subsequent project-specific NEPA 

analyses for projects proposed for implementation under the land use plan, 

which may include but are not limited to fuels treatment, habitat restoration, 

[etc.; list others as applicable]. The subsequent NEPA analyses for projectspecific actions will tier to the land-use planning analysis and evaluate project 

impacts at the appropriate site-specific level (40 CFR 1502.20, 40 CFR 

1508.28). As required by NEPA, the public will have the opportunity to 

participate in the NEPA process for site-specific actions.

DRMTDK-BL13-0440-8

Wildlife

In addition, the Montana BLM has endorsed and committed to implementing the 

Montana Prairie Dog Conservation Plan (Montana Prairie Dog Working Group 

2002), which envisions at least two "Category 1" prairie dog complexes (suitable 

for establishment of a viable population of black-footed . 10,000 acres (Harris et 

al 1989)) in the state, as well as 20 complexes of 1,000 acres or more to 

accommodate associated species (not necessarily ferrets) and approximately 

44,000 acres statewide in "Category 3" or scattered distribution to maintain 

N

Thank you for the comment. According to the Glossary definition, page 5, 

“Black-footed ferret habitat: a complex of prairie dog towns within 1.5 kilometers 

of each other comprising a total of 1,000 acres.” , there is no Category 1, blackfooted ferret habitat, on public lands within the field office.
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distribution and associated species needs. The distribution of prairie dogs in 

Montana makes it likely that one or a combination of these complexes is sited 

within the Billings planning area (see, e.g., Proctor et al. 2006b; Maxell et al. 

2010; Luce 2008). While it is not BLM's sole responsibility to "designate" such 

complexes pursuant to the plan, it is BLM's duty to identify those lands that 

would qualify for conservation activity (or categorization) under BLM's policy 

guidance and the commitments made pursuant to the Montana statewide prairie 

dog management plan. Nowhere in the documents has the BLM identified 

potential Category 1, 2, or 3 designations, a task that would go far in meeting 

BLM's obligations and commitments. Utilizing the distributions of associate 

species such as mountain plover and burrowing owl (Figures 1, 2 and 3) would 

provide support for such identification.

DRMTDK-BL13-0440-9

Wildlife

Given the opportunities to manage for at least part of the prairie dog distribution 

called for in the state plan, the Draft Billings RMP falls short of addressing the 

need to manage some sufficient quantity of BLM lands for at least associated 

species of black-tailed prairie dogs, and identifying, as a preliminary matter, 

where those colonies are situated. Again, our analysis of associated species 

such as the mountain plover (Figure 2, Montana Natural Heritage database 

combined records) and burrowing owl (Figure 3, Montana Natural Heritage 

database) show a high degree of overlap with prairie dog occupancy, indicating 

the importance of prairie dog habitats for these species. As these habitats prove 

to be less favorable with smaller colony size (

n

Prairie dog towns and acreage are discussed in Chapter 3, pages 3-80 and 81. 

Due to the relatively small acreage of prairie dog towns on public land a map 

was not included. The most recent mapping projects are preliminary and could 

not be published at this time.

DRMTDK-BL13-0441-1

Travel mngt

I am very concerned about the changes that are being proposed as to closing 

roads, and trails on and around the Meeteetse Trail area, including the road I live 

on, Grove Creek rd. There should be no closing of public land.

n

Thank you for your comments.

In regards to your comment, 

While statements of opinion (including agreement or opposition) do not require 

specific responses or text revisions under NEPA regulations, they have been 

considered by the Billings Field Office and Montana State Office and 

documented in the administrative record associated with the Billings and 

Pompeys Pillar National Monument RMP/EIS.

In regards to the vehicle route which you have identified, Grove Creek, BLM 

staff have reviewed the route designations and determined that the route is 

designated as “open” in the RMP and is not closed.

DRMTDK-BL13-0442-1

NEPA

plan, under other alternatives defers decisions on further coal leasing to a later 

time, relying on project specific analyses for future coal leasing but potentially 

necessitating changes to the RMP at some point in the future. This approach is 

short sighted and is not sufficient for the purpose of a management plan that will 

guide agency actions for many years. BLM should expand the purpose, and the 

alternatives analyzed, to address continuing coal exploration, leasing, and 

development within the Resource Management Area

N Thank your for your comment. 

DRMTDK-BLCoal The BLM states that "Surface owners of land overlying federal coal from both the 

Mammoth-Rehder and McCleary beds were consulted to determine their N

The date when the surface owner consultation was conducted was added to the 

text. The coal screening process would be applied to future lease application 
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13-0442-

10

preference for or against leasing of their land for surface mining. The results of 

the consultation are shown in Table 2.3. Federal coal was found unacceptable 

for further consideration where the surface owners responded negatively to 

surface mining." BLM did not mention that this consultation occurred in 1984 or 

earlier. Furthermore there has been no updated surface-owner consultation to 

support this draft RMP. Table 2.3 does not exist in Appendix M. SPE requests 

that coal screening be conducted in response to specific proposals using current 

data for future coal leasing actions

areas.

DRMTDK-BL13-0442-2

Coal

Signal Peak Energy recommends that all coal resources within the RMP be 

specifically included in the environmental analysis for future leasing potential. 

The Montana Bureau of Mines and Geology produces maps showing coal 

resources that should be unilaterally evaluated in this EIS for future exploration 

and leasing

N The coal screening process will be applied to future lease application areas.

DRMTDK-BL13-0442-3

Coal

In its analysis of RMP alternatives, the BLM underestimates the potential for 

future development of coal by narrowly defining the reasonably foreseeable 

future as the continuing mining at the Signal Peak operations under current 

conditions. The analysis should be expanded to include considerations for 

expanded operation at the existing mine, additional exploration and potential 

leasing within a reasonable distance to the existing mine infrastructure and 

additional underground and surface mining new leases in all of the known areas 

of coal deposits. Signal Peak Energy currently operates at a permitted rate of 15 

million tons of coal produced per year - a rate that is used for the environmental 

analyses in this EIS. However, the infrastructure in place at the operation could 

accommodate a throughput of 60 million tons of coal per year without major 

construction at the coal load out. It is reasonable to expect that market 

conditions may sustain such a production increase within the life of the RMP. 

State permits e.g. air permits, would require demonstrations of compliance with 

appropriate environmental standards if production rates increase. Site specific 

environmental evaluation of expansion at the site would be done by the state 

and, in the case of development of federal coal leases, by the BLM as well. 

These reasonably foreseeable conditions should be included in the Chapter 4 

analysis

n

Thank you for your comment.

Text has been added to reflect the role that SPE’s existing coal processing and 

rail infrastructure may have regarding future coal development in the Bull 

Mountain coalfield. 

DRMTDK-BL13-0442-4

Social/econ

, Coal

Economic evaluations should also take into account future development of 

federal coal and expansion of Signal Peak operations. Currently, Signal Peak 

has 325 employees with an annual payroll of 539 million. Federal, state and local 

extractive taxes contribute an additional 540 million to the economy each year. 

With the addition of coal from Federal leases, additional employees may be 

added, and Federal lease payments will further contribute to the economy

N

Chapter 4 currently states the following: The average annual federal coal 

leasing, production, tax, and royalty revenues related to BLM federal minerals 

are unknown at this time and would be determined based on whether the 

proposed Montana Federal Mineral Conveyance Act (HR 1158) passes in 

Congress. For analysis purposes, under all Alternatives, it is assumed that all 

federal coal is retained in federal ownership, and a coal lease sale covering 

2,680 acres of federal coal are leased, an annual average of 2.8 million tons of 

federal coal are produced over the life of the lease, and price per ton of coal in 

Montana is $18.11 (Energy Information Administration, 2012). Future coal 
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leasing is uncertain due to lack of infrastructure (e.g., rail lines) near potential 

coal reserves and low international coal prices.

DRMTDK-BL13-0442-5

Edits

Appendix B BMPs for mineral exploration and development should be clarified to 

reflect that these relate to oil and gas exploration and development. Not all of the 

recommendations are appropriate for coal exploration or development

n Thank you for your comment. Text has been changed to reflect your comment.

DRMTDK-BL13-0442-6

Wildlife

The BLM proposes Mitigation Measures and Conservation Actions for Greater 

Sage Grouse Habitat. The recommended measures for solid minerals clearly do 

not reflect mining practices and appear to be more consistent with BLM's 

approach to development of fluid minerals. In describing its recommended 

practices for solid minerals, BLM appropriately recognizes the need to develop 

mitigation measures during activity level planning. Many of the recommendations 

for solid minerals are not appropriate, for a variety of reasons. First, coal is 

located where naturally deposited and recovery of coal must be done in an 

economically viable fashion where the coal is located. Location of surface 

disturbance and surface facilities may not be optional, particularly in the case of 

surface mining, and should only be evaluated on a site specific basis, not 

specified in a general BMP. While seasonal restrictions may be possible when 

using certain types of technologies e.g. coal gasification, it is inappropriate to 

unilaterally apply seasonal restrictions to solid mineral development without a 

clear recognition that the BLM is effectively withdrawing coal resources without 

the proper findings

n

Text has been modified in Chapter to specific to coal leasing. The BLM and the 

Forest Service complied with the NEPA by including a discussion of measures 

that may mitigate adverse environmental impacts of the alternatives in the 

DRMP/EIS. See 40 CFR 1502.14(f), 1502.16(h). Potential forms of mitigation 

include: (1) avoiding the impact altogether by not taking a certain action or parts 

of an action; (2) minimizing impacts by limiting the degree or magnitude of the 

action and its implementation; (3) rectifying the impact by repairing, 

rehabilitating, or restoring the affected environment; (4) reducing or eliminating 

the impact over time by preservation and maintenance operations during the life 

of the action; or (5) compensating for the impact by replacing or providing 

substitute resources or environments. 40 CFR 1508.20. Taking certain is only 

one of many potential forms of mitigation. The BLM and the Forest Service 

must include mitigation measures in an EIS pursuant to the NEPA; yet the BLM 

and the Forest Service have full discretion in selecting which mitigation 

measures are most appropriate, including which forms of mitigation are 

inappropriate. 

DRMTDK-BL13-0442-7

Coal

Secondly, the BLM has erroneously attempted to apply strict BMP requirements 

proposed for fluid minerals development to solid minerals development without 

consideration of the nature of solid minerals extraction. Appendix AB includes 

BMPs for location of pipelines, roads and holding tanks - facilities that are 

connected with fluid minerals management but are generally only incidental to 

mining. Surface mining is often the most economic means of recovery of solid 

minerals, including coal, and by nature does not lend itself to seasonal 

restrictions as proposed in Appendix AB. If implemented as proposed, 

restrictions of activities to certain times and dates would have significant 

socioeconomic impact within the resource management area, potentially 

necessitating long furloughs for workers, reduction of production capacity and 

rendering certain mineral resources uneconomic

n Text in Appendix B has been clarified to reflect your concerns .

DRMTDK-BL13-0442-8

Wildlife

Thirdly, the BLM has not provided sufficient rationale or basis for some of the 

restrictions. For example, BLM suggests that roads should not be designed to 

standards any higher than necessary to accommodate their intended purpose. 

While we are sure that the BLM does not intend for any road to be unsafe for 

travel, this restriction implies that only minimum safety standards can be used as 

a basis of design. SPE specifically objects to this requirement as safety 

(personnel and public) is the highest priority in our operations and we are 

unwilling to accept minimum standards. The restriction on ROW designations for 

n

The BLM’s FLPMA (Section 103(c)) defines "multiple use" as the management 

of the public lands and their various resource values so that they are utilized in 

the combination that will best meet the present and future needs of the 

American people. Accordingly, the BLM is responsible for the complicated task 

of striking a balance among the many competing uses to which public lands can 

be put. The BLM’s multiple-use mandate does not require that all uses be 

allowed on all areas of the public lands. The purpose of the mandate is to 

require the BLM to evaluate and choose an appropriate balance of resource 
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counties on mining development roads is not justified or supported by any 

rationale that show greater protection for sage grouse habitat. County 

maintenance of mine access roads is often the most safe, efficient and economic 

means to support transport of personnel, equipment and supplies to mine related 

activities such as exploration and operations and should not be precluded by 

some unsupported BMP

uses which involves tradeoffs between competing uses. The FLPMA also 

directs the United States (US) Department of the Interior, Bureau of Land 

Management (BLM) to develop and periodically revise or amend its Resource 

Management Plans (RMPs), which guide management of BLM-administered 

lands, and provides an arena for making decisions regarding how public lands 

would be managed and used.

Consistent with the Multiple-Use Sustained-Yield Act of 1960 (16 U.S.C. 528–

531) (MUSYA), the Forest Service manages National Forest System land to 

sustain the multiple use of its renewable resources in perpetuity while 

maintaining the long-term health and productivity of the land. Resources are 

managed through a combination of approaches and concepts for the benefit of 

human communities and natural resources. Land management plans guide 

sustainable, integrated resource management of the resources within the plan 

area in the context of the broader landscape, giving due consideration to the 

relative values of the various resources in particular areas. The Forest Service 

is required by statute to have a national planning rule: the Forest and 

Rangeland Renewable Resources Planning Act of 1974, as amended by the 

National Forest Management Act of 1976, requires the Secretary of Agriculture 

to issue regulations under the principles of the Multiple-Use Sustained-Yield Act 

of 1960 for the development and revision of land management plans.

The B&PPNM RMP/EIS is a targeted amendment specifically addressing goals, 

objectives, and conservation measures to conserve greater sage-grouse and to 

respond to the potential of its being listed (Chapter 1 - Purpose and Need). 

Both, the Forest Service’s and BLM’s planning processes allow for analysis and 

consideration of a range of alternatives in the DRMP/EIS that identified and 

incorporated appropriate regulatory mechanisms to conserve, enhance, and 

restore greater sage-grouse habitat and to eliminate, reduce, or minimize 

threats to this habitat to ensure that a balanced management approach was 

recommended. The DRMP/EIS includes alternatives that provide a greater and 

lesser degree of restrictions in various use programs, but would not eliminate or 

invalidate any valid existing development rights. 

DRMTDK-BL13-0442-9

Wildlife

Fourthly, the operations restrictions, in addition to the misapplication of fluid 

mineral restricted actions to solid minerals, do not necessarily provide the best 

environmental balance when evaluated on a project or site specific basis. For 

example, there are many requirements in this appendix referring to pit and 

impoundment construction that is not applicable to mining operations and 

include extraneous requirements not directly applicable to the greater sage 

grouse (e.g.: equip tanks and other above ground facilities with structures or 

devices that discourage nesting of raptors and corvids; eliminate threats from 

West Nile virus). Man camps are rarely used in solid minerals operations and 

sage grouse mitigation measures should be specifically designed for mining or 

n

Thank you for your comment. The type of issues raised in your comment will 

be considered by the Billings Field Office during implementation of the 

Approved RMP when project-specific plans are prepared or evaluated
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exploration activities that use them. The ROW siting requirement to reduce 

disturbance to sagebrush habitats may not be the best overall environmental 

option for a solid mineral project, when considering other resources and habitat 

types. Reclamation requirements for access roads and well pads is not 

appropriate for this section

DRMTDK-BL13-0443-1

Locatable 

Minerals

Internal inconsistencies found throughout the DRMP/DEIS must be addressed. 

For example the amount of "sub-surface" or mineral acreage described is 

inconsistent. Chapter 3: Affected Environment quantifies 979,000 sub-surface 

acres under the BLM's jurisdiction (DRMP/DEIS Ch.3 at 3-241), while Chapters 

1 and 2 quantify 1,839,782mineral acres under BLM's jurisdiction, which is a 

significant difference of 860,782 acres. The above inconsistency needs to be 

revised before the Final EIS documents are published.

n Thank you for your comment. The acreage numbers have been corrected.

DRMTDK-BL13-0443-

10

Wildlife

Â However, the information provided to us by BLM did not specify what 

requirements, direction, measures, or guidance has been included in the newly 

revised RMPs to address threats to sage-grouse and sagebrush habitat. 

Therefore, we cannot assess their value or rely on them as regulatory 

mechanisms for the conservation of sage-grouse "Although RMPs, AMPs, and 

the permit renewal process provide an adequate regulatory framework, whether 

or not these regulatory mechanisms are being implemented in a manner that 

conserves sage-grouse is unclear (75 Fed. Reg. 13910 at 13975-77, emphasis 

added).

n

Lessons or improved management indicated by ongoing monitoring of 

implemented regulatory mechanisms effects on sage grouse populations will be 

implemented through “Adaptive Management” described in Section 2.3.4. This 

guidance will be supplemented with a Monitoring appendix in the RMP.

During scoping for the B&PPNM RMP/EIS, individuals and conservation groups 

submitted management direction recommendations for protection and 

conservation of greater sage-grouse and their habitat. The recommendations, 

in conjunction with resource allocation opportunities and internal sub-regional 

BLM and the Forest Service input, were reviewed to develop the management 

direction for greater sage-grouse under Alternatives B and D. Conservation 

measures in the alternative are focused on PPH, PGH, and linkage/connectivity 

habitat. These areas have been identified by MTFWP in coordination with 

respective BLM and Forest Service offices.

DRMTDK-BL13-0443-

12

Wildlife

Using this as a premise, BLM maintains the NTT Report conservation measures 

are required to respond to the WBP determination. The NTT Report does not 

use Manual 6840 or ESA as a foundation upon which to build. In fact, the NTT 

Report never references Manual 6840, nor does it explain the need for an 

entirely new regulatory approach. As such, it inappropriately discards an existing 

agency policy without ever justifying the radical change advanced in the NTT 

Report, and is thus arbitrary and capricious.11 Moreover, BLM identifies in the 

DRMP/DEIS that "[c]hanging existing laws, policies, and regulations" is out of 

scope for the RMP process (Ch. 1 at 17). To that end, the Final EIS documents 

should not be published until a full and detailed analysis of an additional 

alternative, that incorporates and analyzes full implementation of existing BMPs, 

Manual 6840, 2004 Strategy, and Fundamentals for Standards for Rangeland 

Health (43 CFR 4180.1) is included. NWMA contends that this additional 

alternative would fit the Purpose, Need, and Objectives of the DRMP/DEIS and 

would be consistent with FLPMA, the Mining Law of 1872, the Mining, Minerals 

n

Thank you for your comment. 

The BLM and the Forest Service considered a reasonable range of alternatives 

during the greater sage-grouse planning process in full compliance with the 

NEPA. The CEQ regulations (40 CFR 1502.1) require that the BLM and the 

Forest Service consider reasonable alternatives that would avoid or minimize 

adverse impacts or enhance the quality of the human environment. While there 

are many possible alternatives or actions to manage public lands and greater 

sage-grouse in the planning area, the BLM and the Forest Service fully 

considered the management opportunities presented in the Analysis of the 

Management Situation (AMS) and the planning issues and criteria developed 

during the scoping process to determine a reasonable range of alternatives. As 

a result, four alternatives were analyzed in detail in the DRMP/EIS that best 

addressed the issues and concerns identified by the affected public. The range 

of alternatives in the DRMP/EIS represented a full spectrum of options including 

a no action alternative (current management, Alternative A).
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and Policy Act, and BLM's sage-grouse conservation goals and objectives.

DRMTDK-BL13-0443-

13

NEPA

None of the alternatives give proper analysis to the existing conservation 

measures or authorities the BLM has to protect sage-grouse and its habitat. The 

DRMP/DEIS fails to include or even reference Manual 6840 in the Alternatives 

and Impact analyses. BLM must not ignore Manual 6840. NWMA recognizes 

that BLM generally describes Manual 6840 (DRMP/DEIS Ch. 3 at 3-75, 3-76), 

but then fails to provide discussion within the context of impacts of how any of 

the specific provisions of Manual 6840 meet, or fail to meet the objectives and 

goals set for the planning area. The DRMP/DEIS documents should evaluate the 

numerous directives in BLM Manual 6840 in the context of each Alternative 

Considered in Detail.

N Thank your for your comment. 

DRMTDK-BL13-0443-

14

Wildlife

BLM fails to fully explain or adequately analyze how these measures 

(DRMP/DEIS Appendix B at B14, B35-39) are either adequate to conserve sagegrouse or inadequate to conserve sage-grouse, and therefore provides no useful 

baseline against which each of the proposed alternatives would be compared. 

The continuation of existing management and conservation measures and 

existing regulatory policies including the directives in BLM Manual 6840 must 

define the No Action Alternative. As is the case for all NEPA documents, the No 

Action Alternative provides the baseline against which all other alternatives must 

be compared and measured

n

The intent of the BMP’s referenced on these pages is described on page B-1. 

In summary, BMPs are voluntary measures for reducing environmental impacts 

associated with certain classes of activity. BLM typically uses these measures 

as guidelines or “project design features” during implementation planning at the 

activity and/or project-specific levels. 

The No Action Alternative includes outdated resource management guidelines 

from the 1983 plan. BLM intends to rely on the latest research and best 

available science by utilizing existing research and incorporating other future 

research through the “Adaptive Management” approach described in Section 

2.3.4, page 2-7.

DRMTDK-BL13-0443-

15

Wildlife

DRMP/DEIS Ch. 4 at 4-246).BLM maintains this conclusion throughout the 

impact analysis specific to locatable minerals. NWMA agrees with these findings; 

however BLM fails to include other management actions or conservation 

measures currently in effect in the planning area that would have a positive 

effect on wildlife, such as habitat conservation improvements.

N

Thank you for your comment. Habitat improvement plans are implementation 

level documents and are therefore out of scope of this document. See the 

proposed actions (Chapter 2 and Appendix) for sage-grouse habitat 

management, including establishment of PHMAs, RA, and GHAs. 

DRMTDK-BL13-0443-

16

Locatable 

Minerals, 

wildlife

NWMA Recommendation No. 4: The Alternatives Described in Detail Should 

Consider Other Conservation Measures Besides those in the NTT Report- At 

least one additional alternative should be included that analyzes conservation 

measures that are not described in the NTT Report. Analysis of existing 

regulatory authorities including but not limited to BLM's Surface Management 

Regulations for locatable minerals at 43 CFR 3809 that allows for hardrock 

mineral development with mitigation to prevent unnecessary or undue 

degradation needs to be included.

n

Thank you for expressing your concerns. 

The BLM and the Forest Service considered a reasonable range of alternatives 

during the greater sage-grouse planning process in full compliance with the 

NEPA. The CEQ regulations (40 CFR 1502.1) require that the BLM and the 

Forest Service consider reasonable alternatives that would avoid or minimize 

adverse impacts or enhance the quality of the human environment. While there 

are many possible alternatives or actions to manage public lands and greater 

sage-grouse in the planning area, the BLM and the Forest Service fully 

considered the management opportunities presented in the Analysis of the 

Management Situation (AMS) and the planning issues and criteria developed 

during the scoping process to determine a reasonable range of alternatives. As 

a result, four alternatives were analyzed in detail in the DRMP/EIS that best 

addressed the issues and concerns identified by the affected public. The range 

of alternatives in the DRMP/EIS represented a full spectrum of options including 

a no action alternative (current management, Alternative A). 
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43 CFR 3809 require the submittal of a Plan of Operations for any activities 

above Casual Use level in “proposed or listed threatened or endangered 

species or their proposed or designated critical habitat” (unless BLM allows for 

other action under a formal land-use plan or threatened or endangered species 

recovery plan;). Submittal of a Plan of Operations requires completion of an 

Environmental Assessment or Environmental Impact Statement to comply with 

NEPA. Mitigations to protect T and E species and their habitat would be 

developed through the NEPA process. Mitigation measures not protective of T 

and E species and their habitat would not meet the U or U criteria identified in 

the 43 CFR 3809 regulations. 

DRMTDK-BL13-0443-

17

Locatable 

Minerals

NWMA recognizes that BLM appropriately identified locatable mineral 

development as a primary issue in the DRMP/DEIS (Ch. 1 at 1-12, 1-13). 

However, BLM fails to provide for environmentally responsible mineral 

exploration and development, or recognize the Nation's need for domestic 

mineral sources, under Alternatives, B and D, the Preferred Alternative. BLM 

must acknowledge that it is required to fully consider the need for future mineral 

development along side with the need for conservation of resources.

n

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS.

The BLM is developing conservation measures which would allow mineral 

development to occur. 

DRMTDK-BL13-0443-

18

NEPA

NWMA Recommendation No. 5: Demonstrate Compliance with FLPMA- The 

DRMP/DEIS should discuss how the proposed land withdrawals and surface 

disturbing restrictions in sage-grouse priority and general habitat areas 

contained in each Alternative Considered in Detail, and the Agency Preferred 

Alternative comply with the FLPMA mandate to balance a wide range of 

resource values and uses of public lands including the directive in the Mining 

and Minerals Policy Act at 43 U.S.C. §1701(a)(12) and 30 U.S.C. §21(a) to 

recognize the Nation's need for domestic sources of minerals.

N

Thank you for your comment. The BLM must comply with all the applicable 

laws, regulations, policies, and acts. 

DRMTDK-BL13-0443-

19

Locatable 

Minerals

30 U.S.C.§22 ensures pre-discovery access, use, and occupancy rights to enter 

lands open to location for mineral exploration and development. Prohibiting 

mineral exploration and development on lands co-located with priority sagegrouse habitat, is contrary to the provisions under Section 22 of the General 

Mining Law, and therefore must be revised.

n

Thank you for expressing your concerns. While statements of opinion 

(including agreement or opposition) do not require specific responses or text 

revisions under NEPA regulations, they have been considered by the Billings 

Field Office and Montana State Office and documented in the administrative 

record associated with the Billings and Pompeys Pillar National Monument 

RMP/EIS. Please see updated text in Chapter 4.

DRMTDK-BL13-0443-2

NEPA

The format of Chapter 4: Environmental Consequences is very difficult to use 

and is generally confusing due to convoluted numbering and internal references 

which require the reader/reviewer to flip through hundreds of pages of text. The 

format needs to be revised to allow for easy reference and clear headings or 

titles. For example, do not use numbering like " 4.6.5.6.15" instead simply title it 

"Impacts to Water Resources from Renewable Energy Development," this will 

eliminate any question as to what resource is being discussed. Further do not 

use internal references like "Impacts are the same as Alternative B;" instead 

n Thank you for your comment. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

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describe the impacts, after all this section is supposed to be a complete 

description -“ not a summary of the impacts. In addition, throughout the 

DRMP/DEIS, BLM uses broad generalizations to describe activities. For 

example, "PPA's would be closed to future oil and gas leasing, exploration, and 

development, and grazing allotments would be designated"" (DRMP/DEIS Ch. 4 

at 287). Does this mean all exploration and development, or only oil and gas 

exploration and development? The vague language, like that highlighted in the 

above example must be revised to eliminate any confusion as to what resource 

may be affected by a proposed management action.

DRMTDK-BL13-0443-

20

Locatable 

Minerals

Alternative B describes "closing exploration and development" in sage-grouse 

protection priority areas. Alternative D is described as "similar" to the surface 

disturbance and disruptive activities described under Alternative B (Table 2-7 at 

2-185). Describing the management action as merely "similar" is inadequate; 

does this apply to the closure of locatable mineral exploration and development 

in protection priority areas? If so, the proposed "closure" is contrary to §22 of the 

General Mining Law. Moreover, exploration and development of locatable 

minerals cannot simply be "closed" without first being withdrawn. BLM does not 

have the authority to withdraw large areas of land; that power resides solely with 

Congress. As such the proposed "closures" are far outside BLM's authority and 

will not withstand legal scrutiny.

n

In response to your comment, [Table 2-7 at 2-191 in the DRMP] in the 

Proposed RMP and Final EIS has been modified to more clearly present that 

the implementation of the Alternatives would result in some public lands being 

recommended for withdrawal from locatable mineral entry under the mining 

laws.

Please see page 2-191 table 2-7 2nd box 

DRMTDK-BL13-0443-

21

Locatable 

Minerals, 

wildlife

In addition, the impact analysis lacks any useful discussion regarding locatable 

mineral development and surface use restrictions within priority sage-grouse 

habitat, claiming that current and future bentonite development would not be 

affected because the claims are valid (DRMP/DEIS Ch. 4 at 4-445), which is 

particularly perplexing because almost all locatable mineral potential and present 

activity is located within Carbon County, which is co-located within priority 

habitat for sage-grouse. However, there is no meaningful discussion of how the 

proposed land withdrawals, prohibitions, and surface use restrictions will affect 

individuals attempting to assert their pre-discovery rights, as discussed above.

n

Thanks you for the comment. The statement on page 4-445, will be revised to 

read, “Although, the mining claims are valid, existing rights, current and future 

bentonite surface mining operations could be affected through the approval 

process and subject to additional mitigation. Areas recommended for 

withdrawal do not coincide with areas having development potential.” Site 

specific impacts would be analyzed on a site specific basis. 

DRMTDK-BL13-0443-

22

Locatable 

Minerals

NWMA maintains that the cumulative impact to locatable minerals from the 

combined land withdrawals currently in place, as well as the future land 

withdrawals proposed in dozens of RMP revisions will have an inadequately 

defined and significant adverse effect on the hardrock mining industry, and this 

must be given thorough analysis in the DRMP/DEIS; otherwise it represents a 

significant flaw that renders the DRMP/DEIS incomplete. NWMA further 

contends that the direct, indirect, and cumulative impact analysis is inadequate 

and lacks convincing data as well as rationale that the impacts to mineral 

development are insignificant (See DRMP/DEIS Ch. 4).

n

Thank you for your comment. We believe the DRMP/DEIS accurately 

represents the effects on locatable mineral development. Cumulative impacts to 

locatable minerals must be evaluated in the context of potential for locatable 

minerals.

DRMTDK-BL13-0443-

Social/econ

The Regulatory Flexibility Act (RFA), as amended by the Small Business 

Regulatory Enforcement Fairness Act (SBREFA) requires BLM to analyze 

adequately the impacts of its proposal on small entities. The DRMP/DEIS does 

n

Thank you for your comment. The economic analysis included in the RMP/EIS 

examines the potential impacts of withdrawing lands from mineral leasing by 

measuring the economic contributions associated with current foreseeable 
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23 not consider the adverse impact on small businesses of requiring validity exams 

in withdrawn or segregated lands, and is devoid of any analysis or discussion of 

the impact of sweeping and cumulative land withdrawals in priority sage-grouse. 

This is a significant omission and must be included in the socioeconomic 

analysis, especially because the proposed land withdrawals are co-located in 

areas with moderate to high mineral development (DRMP/DEIS Ch. 4 at 592, 

593, 594). As BLM discovered in Northwest Mining Association v. Babbitt, 5 

F.Supp.2d 9 (D.D.C. 1998), failure to comply with the RFA and SBREFA will 

invalidate a rulemaking. Therefore the Final EIS/RMP risks being invalidated if 

this issue is not addressed.

development alongside those associated with development anticipated under 

alternatives which propose land withdrawals. Although land withdrawals may 

hamper future economic activity in sectors specializing or supporting mineral 

development, it cannot be determined how these withdrawals would affect 

individual firms within these industries.

DRMTDK-BL13-0443-

24

Locatable 

Minerals

NWMA Recommendation No. 8: Include a Detailed Socioeconomic Analysis of 

the Impacts Related to Locatable Minerals -“ For each alternative, the 

DRMP/DEIS must re-evaluate the socioeconomic benefit or harm each 

alternative will have and disclose and quantify any adverse effects to job 

creation and local economies in light of BLM's own assertion that implementation 

of the Agency Preferred Alternative and Alternative B will have adverse impacts 

to locatable mineral development (DRMP DEIS Ch. 4 at 4-444).

n

Thank you for your comment. Levels would not change under any alternative. 

The analysis assumes they are valid claims and would be developed. 

DRMTDK-BL13-0443-

25

NEPA 

Wildlife, 

NWMA Recommendation No. 9: The EIS Must Evaluate Ways to Minimize 

Adversely Affecting Private Property Rights- The land use restrictions, 

prohibitions, and withdrawals proposed pursuant IM 2012-044 and the NTT 

Report have significant potential to diminish landowners' rights to develop their 

private property if their lands have priority sage-grouse habitat or are located 

near priority sage-grouse habitat. The EIS must evaluate ways to minimize 

interfering with private property rights, including the rights associated with 

owning patented mining claims and fee mineral estates located in, adjacent to or 

near priority sage-grouse habitat.

n

Thank you for your comment. Per requirements of NEPA as noted above, the 

DRMP/EIS provided analysis of the effects of each alternative’s actions on 

locatable mineral extraction. Socioeconomic impacts and the method of 

analysis are described in Section 4.3.1 of the DRMP/EIS. For each alternative, 

the DRMP/EIS describes the impacts on the region’s locatable mineral 

extraction, regional housing, regional income, tax revenues, local government 

expenditures, population, housing, community stability and connectiveness, 

quality of life, and other social and community services. Under Alternative D, 

the pace of locatable mineral development and production and, therefore, the 

socioeconomic impacts, are expected to be very similar to Alternative A, the 

current management situation.

DRMTDK-BL13-0443-3

NEPA

As described below, NWMA does not support any of the Alternatives as they are 

drafted, Alternative B and Alternative C and D, the Preferred Alternative, do not 

recognize rights provided to individuals under the Mining Law of 1872 (General 

Mining Law, 43 U.S.C. 21a et seq), and are not consistent with provisions under 

the Federal Land Policy and Management Act of 1976 (FLPMA, 43 U.S.C 1701 

et seq). In addition to being inconsistent with FLPMA and the General Mining 

Law Alternatives B, C, and D, the Preferred Alternative, are subject to Appendix 

AB, which proposes surface-disturbing restrictions that are not scientifically 

supported as required by the regulations that implement the National 

Environmental Policy Act (NEPA) at 40 C.F.R §1502.24

N Thank you for your comment. (non substantive)

DRMTDK-BL13-0443-4

Wildlife

We also believe that IM 2012-044 and the NTT Report inappropriately jettison 

BLM's existing policies to protect candidate species, including the policies 

contained in BLM Manual 6840, "Special Status Species Management" (Manual 

n

The NTT report (or BER, or COT) is not the sole source of management 

decisions for the range of alternatives. A National Technical Team (NTT) was 

formed as an independent, science-based team to ensure that the best 
Billings and Pompeys Pillar National Monument

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6840). Instead, the DRMP/DEIS arbitrarily imposes a completely new regulatory 

framework without providing a reasonable explanation for doing so, and is 

therefore arbitrary and capricious.

information about how to manage the greater sage-grouse is reviewed, 

evaluated, and provided to the BLM and the Forest Service in the planning 

process. The group produced a report in December 2011 that identified 

science-based management considerations to promote sustainable greater 

sage-grouse populations. The NTT is staying involved as the BLM and the 

Forest Service work through the Strategy to make sure that relevant science is 

considered, reasonably interpreted, and accurately presented; and that 

uncertainties and risks are acknowledged and documented. 

A baseline environmental report, titled Summary of Science, Activities, 

Programs, and Policies That Influence the Rangewide Conservation of Greater 

Sage-grouse (Centrocercus urophasianus) (referred to as the BER), was 

released on June 3, 2013, by the U.S. Geological Survey. The peer-reviewed 

report summarizes the current scientific understanding about the various 

impacts to greater sage-grouse populations and habitats and addresses the 

location, magnitude, and extent of each threat. The BER does not provide 

management options. The report is being used by the BLM and the Forest 

Service in our efforts to develop regulatory mechanisms and improve our 

conservation efforts of the greater sage-grouse and its habitat to reduce the 

potential for listing it under the Endangered Species Act. The data for this report 

were gathered from BLM, Forest Service, and other sources and were the "best 

available" at the range-wide scale at the time collected. The report provides a 

framework for considering potential implications and management options, and 

demonstrates a regional context and perspective needed for local planning and 

decision-making.

In March 2012, the FWS initiated a collaborative approach to develop rangewide conservation objectives for the greater sage-grouse to inform the 2015 

decision about the need to list the species and to inform the collective 

conservation efforts of the many partners working to conserve the species. In 

March 2013, this team of State and FWS representatives, released the 

Conservation Objectives Team (COT) report based upon the best scientific and 

commercial data available at the time that identifies key areas for greater sagegrouse conservation, key threats in those areas, and the extent to which they 

need to be reduced for the species to be conserved. The report serves as 

guidance to Federal land management agencies, State greater sage-grouse 

teams, and others in focusing efforts to achieve effective conservation for this 

species.

The range of alternatives is based upon analysis of public scoping comments 

as well as information provided in the NTT report, the BER, the COT report, and 

State management plans. The alternatives represent different degrees of and 

approaches to balancing resources and resource use among competing human 

interests, land uses, and the conservation of natural and cultural resource 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

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values, while sustaining and enhancing ecological integrity across the 

landscape, including plant, wildlife, and fish habitat. 

DRMTDK-BL13-0443-5

NEPA

The NEPA process requires an agency to rigorously explore and objectively 

evaluate all reasonable alternatives so that decision-makers and the public are 

fully informed. NEPA documents are intended to be used as a tool during the 

planning and decision-making process (40 C.F.R.§§1502.14(a), 1502.14(b),(d)). 

Substantial case law exists regarding the range of alternatives that need to be 

included in an Environmental Impact Statement (EIS), and "[t]he existence of a 

viable but unexamined alternative renders an environmental impact statement 

inadequate" (Resources Ltd. v. Robertson, 35 F.3d 1300, 1307 (9th Cir. 1993)). 

To that end, failing to analyze full and consistent implementation of Manual 

6840, IM-2005-024: National Sage-Grouse Habitat Conservation Strategy (2004 

Strategy), Fundamentals for Standards for Rangeland Health (43 C.F.R 

§4180.1), and existing Best Management Practices (BMPs) as an alternative (a 

"Manual 6840 Alternative") in the EIS documents is arbitrary and capricious and 

does not comply with NEPA requirements. Consequently, the Final EIS 

documents should not be published for public review until a detailed analysis of 

the Manual 6840 Alternative is included. Additionally, the failure to provide a 

detailed evaluation of Manual 6840 and other BLM policies pertaining to sagegrouse conservation is inconsistent with the guidance in Section 6.6 of BLM's 

NEPA Handbook (H-1790-1):

N

Thank your for your comment. 

This topic is discussed in Chapter 2 of the RMP/EIS. Four alternatives are 

presented for managing public lands within the Billings Field Office Planning 

Area to meet the purpose and need and to address the issues presented in 

Chapter 1. 

DRMTDK-BL13-0443-6

NEPA

The analysis also contains broad generalization that the level of disturbance 

directly correlates to the level of adverse impact to species generally 

(DRMP/DEIS Ch. 4 at 4-236, 4-237, 4-238), but does not provide data to support 

that assertion.

N Thank you for your comment. 

DRMTDK-BL13-0443-7

NEPA

NWMA believes BLM's Preferred Alternative does not satisfy statutory 

requirements, does not balance BLM goals, objectives and policies, and is not 

the best solution to the purpose and need. BLM must provide detailed analysis 

that supports why the Preferred Alternative is in the best interest of the agency 

as well as the public. BLM's Land Use Planning Manual and Land Use Planning 

Handbook, II.A.7, pg. 22 (Rel. 1-1693 03/11/05), provides that BLM must identify 

how the Preferred Alternative best meets the multiple use and sustained yield 

requirements of FLPMA. The lack of meaningful analysis contained in the 

DRMP/DEIS constitutes a serious shortcoming that must be addressed. 

Consequently, the DRMP/DEIS is "inadequate as to preclude meaningful 

analysis" (40 CFR 1502.0(a)); and therefore the BLM must prepare and re-issue 

a revised draft which provides the analysis necessary to support each of the 

management alternatives, including the Preferred Alternative.

N

Thank your for your comment. 

Please see Chapter 4 for impact analysis of each of the alternatives. 

DRMTDK-BL13-0443-8

Wildlife

However, precluding mineral development by way of validity exams and land 

withdrawals (See DRMP/DEIS Ch. 4 at 4-265, 4-444) does not accomplish the 

DRMP/DEIS' stated goal, or provide consistency with the mandate under 

n

Thank you for your comment. Text in Chapter 4 had been edited for 

clarification. Please see 4.3.1.6.2. 

The BLM’s FLPMA (Section 103(c)) defines "multiple use" as the management 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-342 Chapter 5: Consultation and Coordination

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Number Topic Comment Text

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Document 

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BLM Response to Comment

FLPMA or the Mining and Mineral Policy Act to recognize the Nation's need for 

domestic mineral sources. NWMA contends that full implementation of existing 

regulatory tools -“ including required conservation and mitigation measures -“ are 

adequate to ensure environmentally sound mineral development that is 

compatible with sage-grouse conservation.

of the public lands and their various resource values so that they are utilized in 

the combination that will best meet the present and future needs of the 

American people. Accordingly, the BLM is responsible for the complicated task 

of striking a balance among the many competing uses to which public lands can 

be put. The BLM’s multiple-use mandate does not require that all uses be 

allowed on all areas of the public lands. The purpose of the mandate is to 

require the BLM to evaluate and choose an appropriate balance of resource 

uses which involves tradeoffs between competing uses. The FLPMA also 

directs the United States (US) Department of the Interior, Bureau of Land 

Management (BLM) to develop and periodically revise or amend its Resource 

Management Plans (RMPs), which guide management of BLM-administered 

lands, and provides an arena for making decisions regarding how public lands 

would be managed and used.

Consistent with the Multiple-Use Sustained-Yield Act of 1960 (16 U.S.C. 528–

531) (MUSYA), the Forest Service manages National Forest System land to 

sustain the multiple use of its renewable resources in perpetuity while 

maintaining the long-term health and productivity of the land. Resources are 

managed through a combination of approaches and concepts for the benefit of 

human communities and natural resources. Land management plans guide 

sustainable, integrated resource management of the resources within the plan 

area in the context of the broader landscape, giving due consideration to the 

relative values of the various resources in particular areas. The Forest Service 

is required by statute to have a national planning rule: the Forest and 

Rangeland Renewable Resources Planning Act of 1974, as amended by the 

National Forest Management Act of 1976, requires the Secretary of Agriculture 

to issue regulations under the principles of the Multiple-Use Sustained-Yield Act 

of 1960 for the development and revision of land management plans.

The B&PPNM RMP/EIS is a targeted amendment specifically addressing goals, 

objectives, and conservation measures to conserve greater sage-grouse and to 

respond to the potential of its being listed. Both, the Forest Service’s and BLM’s 

planning processes allow for analysis and consideration of a range of 

alternatives in the DRMP/EIS that identified and incorporated appropriate 

regulatory mechanisms to conserve, enhance, and restore greater sage-grouse 

habitat and to eliminate, reduce, or minimize threats to this habitat to ensure 

that a balanced management approach was recommended. The DRMP/EIS 

includes alternatives that provide a greater and lesser degree of restrictions in 

various use programs, but would not eliminate or invalidate any valid existing 

development rights.

DRMTDK-BL13-0443-9

NEPA

To that end, BLM's failure to examine this viable alternative in the Draft 

RMP/DEIS will not withstand legal scrutiny pursuant to NEPA case law. 

Moreover, the alternatives analysis in the DRMP/DEIS does not satisfy BLM's 

N

Thank your for your comment. 

Please see Chapter 2 for a discussion of alternative formation.
Billings and Pompeys Pillar National Monument

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Chapter 5: Consultation and Coordination 5-343

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BLM Response to Comment

own requirements for analyzing alternatives as set forth in its NEPA Handbook, 

H-1790-1, or the above-noted Purpose of the document because it fails to 

recognize the Nation's need for domestic sources of minerals, violates FLPMA, 

does not balance BLM's goals and objectives, and fails to incorporate 

appropriate management actions by opting for a one-size fits-all approach to 

conservation. The Final RMP/EIS must include a revised and expanded 

alternatives analysis.

DRMTDK-BL13-0444-1

NEPA

Each Alternative in the DRMP/EIS includes a variation on a proposal to bury 

power lines that are <69kV voltage when feasible where wildlife conflicts exist 

without due consideration of what those conflicts may be. 

n Thank you for your comment.

DRMTDK-BL13-0444-2

Wildlife

A proposal common to all Alternatives is a requirement where wildlife conflicts 

exist, tall structures or power lines would be designed to include bird flight 

diverters to prevent bird strikes and perching by birds of prey. NWE wishes to 

point out that bird flight diverters are not designed to prevent perching by birds of 

prey on power lines nor would they be effective in this regard. The BLM may 

wish to revise this to avoid confusion

n thank you for your comment. 

DRMTDK-BL13-0444-3

NEPA

A topic very important to NWE is how the BLM intends to manage existing and 

future rights of way (ROW). Significant acreage is designated as "ROW 

avoidance" without adequate discussion, documentation or justification for the 

proposed prohibitions of ROW. Additionally, the DRMP/EIS indicates, that 

proposed ROW must be 'compatible with the purpose for which the area was 

designated" and "not otherwise feasible on lands outside the avoidance area." 

However, these statements do not specify any standards by which such 

determinations will be made. NWE recommends that BLM provide more 

definition to these statements that take into account the short-term nature of 

construction disturbance and the minimal residual impacts associated with 

power line and pipeline ROWs

n See the Glossary. The definition of "Avoidance Areas" has been changed.

DRMTDK-BL13-0444-4

Wildlife

We caution the BLM, however, to not make land management decisions that 

benefit one use and unduly impact another. According to the BLM's Land Use

Planning Manual and Land Use Planning Handbook, II.A.7, pg. 22 (Rel. 

1Â¬1693 03/11/05), BLM must identify how the Preferred Alternative best meets 

the multiple use requirements of the Federal Land Policy Management Act. The 

DRMP/EIS includes several examples of where protection of sage grouse 

habitat results in added restrictions on existing or potential energy operations 

including wind power, overhead electric lines and natural gas production, 

operation, and distribution

n

The BLM’s FLPMA (Section 103(c)) defines "multiple use" as the management 

of the public lands and their various resource values so that they are utilized in 

the combination that will best meet the present and future needs of the 

American people. Accordingly, the BLM is responsible for the complicated task 

of striking a balance among the many competing uses to which public lands can 

be put. The BLM’s multiple-use mandate does not require that all uses be 

allowed on all areas of the public lands. The purpose of the mandate is to 

require the BLM to evaluate and choose an appropriate balance of resource 

uses which involves tradeoffs between competing uses. The FLPMA also 

directs the United States (US) Department of the Interior, Bureau of Land 

Management (BLM) to develop and periodically revise or amend its Resource 

Management Plans (RMPs), which guide management of BLM-administered 

lands, and provides an arena for making decisions regarding how public lands 

would be managed and used.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-344 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

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Document 

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BLM Response to Comment

Consistent with the Multiple-Use Sustained-Yield Act of 1960 (16 U.S.C. 528–

531) (MUSYA), the Forest Service manages National Forest System land to 

sustain the multiple use of its renewable resources in perpetuity while 

maintaining the long-term health and productivity of the land. Resources are 

managed through a combination of approaches and concepts for the benefit of 

human communities and natural resources. Land management plans guide 

sustainable, integrated resource management of the resources within the plan 

area in the context of the broader landscape, giving due consideration to the 

relative values of the various resources in particular areas. The Forest Service 

is required by statute to have a national planning rule: the Forest and 

Rangeland Renewable Resources Planning Act of 1974, as amended by the 

National Forest Management Act of 1976, requires the Secretary of Agriculture 

to issue regulations under the principles of the Multiple-Use Sustained-Yield Act 

of 1960 for the development and revision of land management plans.

The B&PPNM RMP/EIS is a targeted amendment specifically addressing goals, 

objectives, and conservation measures to conserve greater sage-grouse and to 

respond to the potential of its being listed. Both, the Forest Service’s and BLM’s 

planning processes allow for analysis and consideration of a range of 

alternatives in the DRMP/EIS that identified and incorporated appropriate 

regulatory mechanisms to conserve, enhance, and restore greater sage-grouse 

habitat and to eliminate, reduce, or minimize threats to this habitat to ensure 

that a balanced management approach was recommended. The DRMP/EIS 

includes alternatives that provide a greater and lesser degree of restrictions in 

various use programs, but would not eliminate or invalidate any valid existing 

development rights. For example, [insert one or more examples of the range of 

actions considered, include references to sections/table where they can be 

found].

Additionally, the BLM and the Forest Service developed the B&PPNM RMP/EIS 

with involvement from cooperating agencies, including Montana Fish Wildlife 

and Parks, USFWS, Montana Governor’s Office, including several Montana 

counties within the planning area, etc. to ensure that a balanced multiple-use 

management strategy to address the protection of greater sage-grouse while 

allowing for utilization of renewable and nonrenewable resources on the public 

lands.

DRMTDK-BL13-0444-5

Wildlife

NWE encourages the BLM to consider mitigation banks and offsite mitigation as 

mechanisms to pool habitat conservation resources and target conservation 

efforts in highest priority areas. In the development of such mitigation banks, the 

potential for future energy delivery corridors should be considered. For unknown 

impacts of operating and maintaining power lines, NWE recommends that the 

BLM provide opportunities and incentives to conduct additional studies using the 

research protocols developed by Utah Wildlife in Need in 2012 and endorsed by 

n

The BLM and the Forest Service complied with the NEPA by including a 

discussion of measures that may mitigate adverse environmental impacts of the 

alternatives in the DRMP/EIS. See 40 CFR 1502.14(f), 1502.16(h). Potential 

forms of mitigation include: (1) avoiding the impact altogether by not taking a 

certain action or parts of an action; (2) minimizing impacts by limiting the 

degree or magnitude of the action and its implementation; (3) rectifying the 

impact by repairing, rehabilitating, or restoring the affected environment; (4) 
Billings and Pompeys Pillar National Monument

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the Western Association of Fish and Wildlife Agencies (WAFWA). As indicated 

by WAFWA, such research should be acceptable as a component of a mitigation 

package for unknown project impacts. In addition, NWE encourages the BLM to 

jointly identify potential sage-grouse incentives and partnerships with the electric 

and gas utility industry

reducing or eliminating the impact over time by preservation and maintenance 

operations during the life of the action; or (5) compensating for the impact by 

replacing or providing substitute resources or environments. 40 CFR 1508.20. 

Taking certain is only one of many potential forms of mitigation. The BLM and 

the Forest Service must include mitigation measures in an EIS pursuant to the 

NEPA; yet the BLM and the Forest Service have full discretion in selecting 

which mitigation measures are most appropriate, including which forms of 

mitigation are inappropriate.

DRMTDK-BL13-0447-1

Realty, 

Cadastral 

Survey, and 

Lands

The BLM include a stipulation to prevent impacts to split estate conservation 

easement properties. This could be facilitated via a no surface occupancy 

stipulation that precludes development on easement properties, similar to the 

protections provided in the draft RMP on split estate ownership with state-owned 

surface. Finally, the BLM could implement a controlled surface use stipulation 

that requires development to be compatible with the terms of the conservation 

easement. Under this stipulation the lessee and the land trust must develop and 

sign off on a mutually agreeable surface use plan before development may 

occur

n Thank you for your comment. It will be taken under consideration.

DRMTDK-BL13-0447-2

NEPA

The BLM conduct an impacts analysis on split estate conservation easement 

properties. This analysis should identify where these lands are located and what 

the effects of BLM authorized activities would be to these lands. MLR would be 

happy to provide maps of all easements in the area that could potentially be 

impacted

n Thank you for your comment.

DRMTDK-BL13-0448-1Travel 

mngt, 

recreation

we offer these suggestions in lieu of seasonal closures:1. Erect additional 

signage in strategic places warning people that off road use is illegal and will 

result in a fine. This past week I noticed that there is a new narrow sign saying 

something like wilderness study behind this point. The inconspicuous sign is 

above the cirque on upper Burnt Timber Road. It is barely noticeable and is not 

explicit enough regarding what behavior it hopes to illicit. We are proposing 

harder to miss signs that make it clear that there are consequences of driving off 

the roads. These signs should be placed at all the entrances to the horse range 

and in places where off road use has occurred or is likely to occur.2. Create 

natural barriers (rocks, limbs, and logs), which prevent off road use in key areas 

of concern in all areas of the PMWHR. This falls in the "making the right thing 

easy and the wrong thing hard" category. Both BLM and TCF have done this 

and it has been effective in deterring people from creating new roads that others 

then follow, not even realizing they are driving illegally. We will continue to offer 

our help in creating these types of deterrents to going off road and we are open 

to suggestions on what type of deterrent might be most needed.3. Obviously, 

road improvements need to be made in strategic areas of concern (the rock pile 

on Sykes, wash outs in the making on both Burnt Timber and Sykes) as well as 

areas where drivers are veering off road. Most of these are not in the seasonal 

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS

Many of these comments are actually implementation-level actions which can 

be conducted without a RMP decision as part of existing regulation or policy 

and which are being done.

Specifically: 

1. All main access routes into the Pryors (both FS and BLM) already have 

regulatory signage on Kiosks at entrances and at a number of existing problem 

sites. 

2. BLM already uses natural barriers to prevent illegal OHV use. 

3. BLM already does road maintenance on vehicle routes, funding levels 

permitting.

4. Contact numbers are posted on entrance Kiosks, web pages, telephone 

books, agency offices, etc. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

5-346 Chapter 5: Consultation and Coordination

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

closure areas by the way. We appreciated the work of the Conservation Core the 

other day in putting poles along the road near the snow-fed waterhole atop the 

mountain. I believe these will be effective.4. TCF will report any downed trees 

that are blocking roads as quickly as we see them and will alert those "friends of 

the Pryors" to do the same. It would be good to know who in BLM to alert about 

this and the appropriate number to call or text. Texting is sometimes the only 

way to communicate, so a cell phone number would be a good thing for us to 

have. We believe that the four suggestions above will mitigate habitat 

degradation without preventing public access on the only roads open (other than 

snow mobile routes) during the April15-June 15 time frame

DRMTDK-BL13-0448-2

Recreation, 

Travel mngt 

Even more so than in summer when many people camp, tourists in the nonsummer months tend to stay at local motels in Lovell, WY. They buy gas, 

supplies, and food at local stores. We believe that these factors should be 

considered in any decision to close off the roads as this could have a negative 

economic impact on the area

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

Please see the socio- economics section of the RMP. 

DRMTDK-BL13-0448-3

Travel mngt

The other reason mentioned for seasonal road closure relates to the negative 

impact of vehicle use at this time on the viability of the herd during foaling 

season. In my 19 years of documenting the Pryor herd, I cannot recall a single 

case in which vehicle use resulted in the loss of a foal or deterred a stallion from 

breeding a mare. The herd is obviously a viable population or else there would 

be no need for population suppression through the use of PZP. Additionally, 

closure of Sykes Ridge above the old trap site will do little to help or hinder 

viability/foaling in April-June as foals are rarely born in this area, which would be 

closed

n

Thank you for expressing your concerns. While statements of opinion (including 

agreement or opposition) do not require specific responses or text revisions 

under NEPA regulations, they have been considered by the Billings Field Office 

and Montana State Office and documented in the administrative record 

associated with the Billings and Pompeys Pillar National Monument RMP/EIS. 

As mentioned in the RMP, the seasonal closure is for a number of reasons, not 

just for wild horse protection. 

DRMTDK-BL13-0448-4WILD 

HORSES, 

PMWHR

While it was dismissed from analysis, TCF believes that the expansion of the 

PMWHR on the North side of the PMWHR including Tony Island and Tony 

Island Spring area to the existing fence line beyond the Dryhead Overlook is 

critical to the long term survival of the herd and provides the public with viewing 

opportunities denied to those who do not have four wheel drive or high clearance 

vehicles. Expansion of the range into the highest elevations, where there is high 

quality forage, is more essential based on the projected temperature increases. 

The RMP indicates a 2-3 degree rise in temperature between 2010 and 2029. 

TCF strongly encourages BiFO to work with the CNF to accomplish this 

expansion

N

Thank you for your comment. BLM can only make land allocations on BLM 

administered lands. 

DRMTDK-BL13-0448-5WILD 

HORSES, 

PMWHR

The PMWHR 2009 Herd Management Area Plan (HMAP) prioritizes the 

important of maintaining rare colors and bloodlines. TCF recommends that the 

words rare colors be added to the RMP as well as no sex skewing and a review 

of AML based on the addition of the Administrative Pastures will be conducted 

with a revision to the high AML.

N

Thank you for your comments, but specific objectives for the herd would be part 

of a HMAP which is an implementation level planning document for the day to 

day management of the horses and the range.

DR- WILD The draft RMP does not discuss the lease situation between BiFO and Krueger n Thank you for your comment, but this is not a Land Use Planning Decision. 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Chapter 5: Consultation and Coordination 5-347

Comment 

Number Topic Comment Text

Changes 

Document 

(Y/N)

BLM Response to Comment

MTDK-BL13-0448-6HORSES, 

PMWHR

Land & Livestock Inc. Krueger L&L owns a parcel of land within the PMWHR, 

which includes all or a portion of the only permanent water source atop the 

mountain within the designated PMWHR. The Krueger land also contains vital 

summer grazing which takes on added importance as the horses are now 

restricted by a 2 mile-long fence from accessing their mid to late summer and 

fall, high elevation grazing in the Custer National Forest which includes the 

permanent water source on Tony Island. According to the BiFO, the lease is 

valid through September 30, 2017. Will BLM actively work with Krueger L&L to 

renew this lease? The land is currently for sale through a real estate company in 

Salt Lake City. We strongly encourage BiFO to include a discussion in the RMP 

about the future of this critical acreage

The situation where this property was for sale no longer exists. 

DRMTDK-BL13-0455-1

lands with 

wilderness 

characteristi

cs

The draft RMP states in at least two sections that LWCs is a high priority for 

BLM (p. 3-141 and K-1). In light of this priority, BLM should interpret liberally the 

qualifications for designation. The following areas should be reconsidered for 

LWC status: Much of Weatherman Draw meets the LWC qualifications, it is of 

high cultural significance, and former roads are rehabilitating. Bad Canyon has a 

stable population of native Yellowstone Cutthroat trout, is an important grizzly 

bear corridor, and there is no motorized access. While Tract 4 of the Pryor 

Mountain Unit is surrounded by roads, the two roads are redundant. If one was 

closed and the land rehabilitated, the area would qualify for LWC designation 

and would be an important addition to the adjoining WSA.

n

Thank you for your concerns and comments. BLM follows Manual 6301 in 

conducting its wilderness inventories and Manual 6302 when considering lands 

with wilderness characteristics during planning. These Manuals implement 

Secretarial Order 3310 and incorporates principles from BLM guidance 

(Organic Act directives) and legal rules developed as part of BLM’s original 

wilderness inventories. 

Two of the units you mentioned (Bad Canyon, Weatherman Draw) do possess 

wilderness characteristics. Tract 4 of the Pryor Mountain Unit does not currently 

meet the size criteria. Please see Appendix K for details. You are correct to 

note that should one of the two mentioned vehicle routes be closed and-or 

become unusable for motorized use, that Tract 4 would then be adjacent to a 

WSA. Please note that the Billings Field Office has chosen a management 

direction in the chosen Alternative which do not specifically manage for lands 

with wilderness characteristics resource values but which have management 

actions which provide for protection of those resources, as in the case of 

Weatherman Draw and Bad Canyon. 

DRMTDK-BL13-0455-2

Travel mngt

Consider closing the current road that bisects Demijohn Flat. It leads to the 

sensitive cultural area and does not have a clear ending point, which 

encourages people in motorized vehicles to drive further.

n

Thank you for your comments and your concern. We appreciate the interest in 

management of public lands. 

In regards to the Demijohn Flat route, the RMP has a range of possible 

decisions. In this case, due to the conditions you mentioned the Alternative D 

has been modified to reflect the current conditions. The route will be designated 

as “closed” for motorized use with the exception of administrative access. 

Refer to map 146
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REFERENCES

2004 fuels reduction treatment in the Horsethief area.

REFERENCES
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

References

Aldridge, C. L., and M. S. Boyce. 2007. Linking occurrence and fitness to persistence: 

Habitat‐based approach for endangered greater sage‐grouse. Ecological Applications 

17:508–26. 

Aldridge, C. L., and R. M. Brigham. 2002. Sage‐grouse nesting and brood habitat use in 

southern Canada. Journal of Wildlife Management 66:433‐444.

Aldridge, C. L., and R. M. Brigham. 2003. Distribution, abundance, and status of the greater 

sage‐grouse, Centrocercus urophasianus, in Canada. Canadian Field‐Naturalist 

117:25‐34.

Aldridge, C. L., S. E. Nielsen, H. L. Beyer, M. S. Boyce, J. W. Connelly, S. T. Knick, and M. 

A. Schroeder. 2008. Range‐wide patterns of greater sage‐grouse persistence. Diversity 

and Distributions 17:983‐994.

Aldridge, C.L., and M.S. Boyce. 2007. Linking occurrence and fitness to persistence: a habitatbased approach for endangered greater sage grouse. Ecological Applications 17:508-

526.

Alley, W.M., Reilly, T.E., and Franke, O.L. 1999. Sustainability of ground-water resources. 

U.S. Geological Survey Circular 1186, 79 p.

Alt, David and Hyndman, Donald. 1986. Roadside Geology of Montana. Mountain Press 

Publishing Company, Missoula, MT.

American Fisheries Society. 2008. [Online] 

http://www.fisheries.org/units/AFSmontana/ssc.html. Last accessed 6/14/2009.

American Geological Institute (AGI). 1997. Dictionary of Mining, Mineral, and Related Terms. 

AGI, 4220 King Street, Alexandria, Virginia, 646 p. 

Anderson, Michelle D. 2003. Pinus contorta var. latifolia. In: Fire Effects Information System, 

[Online]. U.S. Department of Agriculture, Forest Service, Rocky Mountain Research 

Station, Fire Sciences Laboratory (Producer). [Online]

http://www.fs.fed.us/database/feis/ Accessed: October 10, 2008.

Anonymous. 1999. Yellowstone Cutthroat Trout: Current Status and Recommendations Within 

the State of Montana. Gallatin and Custer National Forests, Regions 3 and 5. Montana 

Department of Fish, Wildlife and Parks, and U.S. Fish and Wildlife Service Montana 

Technical Assistance Office.

Armstrong, J. C. 2007. Improving sustainable seed yield in Wyoming big sagebrush. Provo, 

UT: Brigham Young University. 29 p. Thesis.

References Ref-1
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Arno, Stephen F. 1979. Forest Regions of Montana. Res. Pap. INT-218. Ogden, UT. U.S. 

Department of Agriculture, Forest Service, Intermountain Forest and Range Experiment 

Station. 39 pp. (340).

Arkle R. S., D. S. Pilliod, S. E. Hanser, M. L. Brooks, J. C. Chambers, J. B. Grace, K. C. 

Knutson, D. A. Pyke, J. L. Welty, T. A. Wirth. 2014. Quantifying restoration 

effectiveness using multi-scale habitat models: implications for sage-grouse in the Great 

Basin. Ecosphere 5 (3): p.1-32.

Ashley, P. and S. Stoval. 2004. Brewer’s Sparrow (Spizella breweri). Southeast Washington 

Ecoregional Assessment. [Online] 

http://www.nwcouncil.org/fw/subbasinplanning/wallawalla/plan/AppF_WildilfeAssess

ment_sm_Part1.pdf

Atamian, M. T., M. S. Sedinger, J. S. Heaton, and E. J. Blomberg. 2010. Landscape‐level 

assessment of brood rearing habitat for greater sage‐grouse in Nevada. Journal of 

Wildlife Management ‐74:1533‐1543.

Autenrieth, R. E. 1981. Sage grouse management in Idaho. Idaho Department of Fish and 

Game, Wildlife Bulletin 9, Boise, Idaho, USA.

Baker, W. L., 2011, Pre- Euro-American and recent fire in sagebrush ecosystems, in Knick, S. 

T. and Connelly, J. W., eds., Greater sage-grouse: ecology and conservation of a 

landscape species: Berkeley, Calif., University of California Press, p. 185–202.

Baruch-Mordo, S., J. S. Evans, J. P. Severson, D. E. Naugle, J. D. Maestas, J. M. Kiesaecker, 

M. J. Falkowski, C. A. Hagan, and K. P. Reese. 2013. Saving sage-grouse from the 

trees: a proactive solution to reducing a key threat to a candidate species. Biological 

Conservation 167:233-241.

Bates Hole/Shirley Basin Sage-grouse Working Group. 2007. Bates Hole/Shirley Basin Sagegrouse Conservation Plan. Internet website: 

https://wgfd.wyo.gov/web2011/Departments/Wildlife/pdfs/SG_BATESSHIRLEYBASI

N_CONSVPLAN0000679.pdf. Accessed July 2, 2014.

Baxter, R.J., K.D. Bunnell, J.T. Flinders, and D.L. Mitchell. 2007. Impacts of predation on 

greater sage-grouse in Strawberry Valley, Utah. Transactions of the 72nd North 

American Wildlife and Natural Resources Conference 72:258-269.

Beck, J.L., and D. L. Mitchell. 2000. Influences of livestock grazing on sage‐grouse habitat. 

Wildlife Society Bulletin 28:993‐1002.

Beck, J.L. K. P. Reese, J. W. Connelly, and M. B. Lucia. 2006. Movements and survival of 

juvenile greater sage‐grouse in southeastern Idaho. Wildlife Society Bulletin 

34:1070‐1078.

Ref-2 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Beck, J.L., J.W. Connelly, and K.P. Reese. 2009. Recovery of greater sage‐grouse habitat 

features in Wyoming big sagebrush following prescribed fire. Restoration Ecology 

17:393‐403.

Beck, T.D.I., and C.E. Braun. 1980. The strutting ground count: variation, traditionalism, 

management needs. Proceedings of the Western Association of Fish and Wildlife 

Agencies 60:558‐566.

Beever, E.A., and C. L. Aldridge. 2011. Influences of free‐roaming equids on sagebrush 

ecosystems, with a focus on greater sage‐grouse. Pp. 273‐290 in S. T. Knick and J. W. 

Connelly (editors). Greater sage-grouse: ecology and conservation of a landscape 

species and its habitats. Studies in Avian Biology 38.University of California Press. 

Berkeley, CA.

Berg, R.B., Lopez, D.A. 2000. Geologic map of the Livingston 30' x 60' quadrangle, southcentral Montana, Montana Bureau of Mines and Geology: Open-File Report 406, 21 p., 

1 sheet(s), 1:100,000. 

Bergquist, E., P. Evangelista, T.J. Stohlgren, and N. Alley. 2007. Invasive species and coal bed 

methane development in the Powder River Basin, Wyoming. Environmental Monitoring 

and Assessment 128:381‐394.

Biggens, D.E.,et al., 2006d. Evaluating habitat for black-footed ferrets: revision of an existing 

model. Pages 143–150 in J.E. Roelle, B.J. Miller, J.L. Godbey, and D.E. Biggins, 

editors, Recovery of the black-footed ferret—progress and Continuing challenges. U.S. 

Geological Survey Scientific Investigations Report 2005-5293. Available from:

http://www.fort.usgs.gov/Products/Publications/21570/21570.pdf 

Blackstone, D.L. 1975. Geology of the East Pryor Mountain Quadrangle. Carbon County, 

Montana. Montana Bureau of Mines and Geology, Special Publication 69.

Bendel, Peter R., and Glenn Therres, Proximity of Waterbird Colonies to Development in 

Maryland, Maryland Dept. of Natural Resources, Proc. Annu. Conf. Southeast. Assoc. 

Fish and Wildl. Agencies 53:425-433, 1999.

Blickely, J.L. and G.L. Patricelli. In press. Potential acoustical masking of greater sage‐grouse 

display components by chronic industrial noise. Ornithological Monographs.

Blickley, J.L., D. Blackwood, and G.L. Patricelli. In press. Experimental evidence for the 

effects of chronic anthropogenic noise on abundance of greater sage‐grouse at leks. 

Conservation Biology.

BLM (US Department of the Interior, Bureau of Land Management). 1991. Record of Decision 

Environmental Impact Statement for Vegetation Treatment on BLM Lands in Thirteen 

Western States. BLM, Wyoming State Office. Cheyenne. 

References Ref-3
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

. 2005. Final Programmatic Environmental Impact Statement on Wind Energy 

Development on BLM-Administered Lands in the Western United States. FES 05-11. 

Washington, DC. June 2005.

. 2007. Final Vegetation Treatments on Bureau of Land Management Lands in 17 

Western States Programmatic Environmental Report. June 2007, FES 07-21. BLM. 

Reno, NV and Washington, D.C. Internet website: 

http://www.blm.gov/wo/st/en/prog/more/veg_eis.html. Accessed July 2, 2014. 

. 2012. Northwestern Plains Rapid Ecological Assessment. Final Memorandum. Internet 

website: www.blm.gov/wo/st/en/prog/more/Landscape_Approach/reas/

nwplains.html. Accessed July 2, 2014.

. 2013. Interagency Standards for Fire and Fire Aviation Operations. US Department of 

the Interior, Bureau of Land Management. Washington, DC.

. 2014. Bureau of Land Management, Powder River Basin Restoration Program fact 

sheet. Internet website: www.blm.gov/wy/st/en/field_offices/Buffalo/PRB

restoration.html. Accessed on January 21, 2014.

. 2015. Geographic Information Systems Data. National Operations Center, Denver, 

Colorado.

Bock, C. E., J. H. Bock, and H. M. Smith. 1993. Proposal for a system of federal livestock 

exclosures on public rangelands in the western United States. Conservation 

Biology7:731–733.

Bradley, B. A. 2009. Regional analysis of the impacts of climate change on cheatgrass invasion 

shows potential risk and opportunity. Global Change Biology 15.1 (2009): 196-208.

Bradley, B. A. 2010. Assessing ecosystem threats from global and regional change: hierarchical 

modeling of risk to sagebrush ecosystems from climate change, land use and invasive 

species in Nevada, U.S.A. Ecography, v. 33, Pp. 198-208.

Braun, C. E., O. O. Oedekoven, and C. L. Aldridge. 2002. Oil and gas developments in western 

North America: effects on sagebrush steppe avifauna with particular emphasis on sagegrouse. Transactions of the North American Wildlife and Natural Resources 

Conference, 67: 337

Braun, C.E. 1998. Sage grouse declines in western North America: What are the problems? 

Proceedings of the Western Association of State Fish and Wildlife Agencies 78:139–

56.Braun, C. E., T. Britt, and R. O. Wallestad. 1977. Guidelines for maintenance of 

sage grouse habitats. Wildlife Society Bulletin 5:99‐106.

Braun, C. E. 1998. Sage Grouse declines in western North America: what are the problems? 

Proceedings of the Western Association of State Fish and Wildlife Agencies 78: 139-

156.

Ref-4 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Braun, C.E., T. Britt, and R.O. Wallestad. 1977. Guidelines for maintenance of sage grouse 

habitats. Wildlife Society Bulletin 5:99‐106.

Brimson, M.M. [Chair]. 2001. Riparian Areas: Functions and Strategies for Management. 

National Academics Press, 2001 Constitution Avenue N.W. Washington D.C. 20418. 

424.

Briske, D.D., J.D. Derner, D.G. Milchunas, and K.W. Tate. 2011. An evidence‐based 

assessment of prescribed grazing practices. Pp. 23‐74 in D.D. Briske. Conservation 

benefits of rangeland resources: assessment, recommendations, and knowledge gaps. 

USDA, National Resources Conservation Service, Washington D.C.

Brown, J.K. 1982. Fuel and fire behavior prediction in big sagebrush. US Department of 

Agriculture, Forest Service, Intermountain Forest and Range Experiment Station. 

Research Paper INT‐290. Ogden, UT.

Bui, T.D. 2009. The effects of nest and brood predation by Common Ravens (Corvus corax) on 

Greater Sage-grouse (Centrocercus urophasianus) in relation to land use in western 

Wyoming. M.S. Thesis, University of Washington, Seattle. 

Bui, T.D., J.M. Marzluff, and B. Bedrosian. 2010. Common raven activity in relation to land 

use in western Wyoming: implications for greater sage‐grouse reproductive success. 

Condor 112:65‐78.

Burgman, M.A., D.B. Lindenmayer, and J. Elith. 2005. Managing landscapes for conservation 

under uncertainty. Ecology 86:2007‐2017.

Burkett, Virginia and Jon Kusler. “Climate Change: Potential Impacts and Interactions in 

Wetlands of the United States.” Journal of the American Water Resources Association

36.2 (2000): 313-320.

Cagney, J., E. Bainter, B. Budd, T. Christiansen, V. Herren, M. Holloran, B. Rashford, M. 

Smith and J.Williams. 2010. Grazing Influence, Objective Development, and 

Management in Wyoming’s Greater Sage‐Grouse Habitat. Cooperative Extension 

Service Bulletin B‐1203, University of Wyoming, Laramie, WY.

Campbell, N. P. 1978. Caves of Montana, Montana College of Mineral Science and 

Technology, Butte, MT. pp. 70 – 91.

Canfield, J.E. etal. 1999. Ungulates. in G. Joslin and H. Youmans, coordinators. Effects of 

Recreation on Rocky Mountain Wildlife: A Review for Montana. Committee on Effects 

of Recreation on Wildlife, MT. Chapter of the Wildlife Society. Pg. 6.12).

Carpenter, J., C. Aldridge, and M.S. Boyce. 2010. Sage‐grouse habitat selection during winter 

in Alberta. Journal of Wildlife Management ‐74:1806‐1814.

References Ref-5
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Casey, D. 2000. Partners in Flight bird conservation plan Montana [Computer database ver 1.0] 

Montana Partners in Flight, Kalispell, Montana. [Online] 

http://www.partnersinflight.org/bcps/pl_mt_10.pdf.

CEQ 1997 CEQ (Council on Environmental Quality), 1997. Environmental Justice: Guidance 

Under the National Environmental Policy Act. Washington D.C., 40 p.

Census of Agriculture. 2002 – Section 3.6.2 – Economic Conditions

Centmont Bioconsultants. 2005. A Survey for Raptors on Lands Managed by the Billings Field 

Office of the BLM.

Cerovski et al. 2004. Section 3.3.6 Fish & Wildlife

Chalfoun, Anna D. 2006. Demographic and Behavioral Responses of Breeding Birds to 

Variation in Food, Nest Predation, and Habitat Structure Across Multiple Spatial 

Scales, 2006, University of Montana, PhD Dissertation.

Christiansen, T. 2013. Wyoming Sage-Grouse Population Trend Data – 1995-2013. 

Unpublished data, Wyoming Game and Fish. August 24, 2013.

Christiansen, T. 2009. Fence marking to reduce greater sage‐grouse collisions and mortality 

near Farson, Wyoming – summary of interim results. Wyoming Game and Fish 

Department unpublished interim report.

Clark, L., J. Hall, R. McLean, M. Dunbar, K. Klenk, R. Bowen, and C.A. Smeraski. 2006. 

Susceptibility of greater sage‐grouse to experimental infection with West Nile virus. 

Journal of Wildlife Diseases 42:14‐42

Climate Change Supplementary Information Report Montana North Dakota and South Dakota 

Bureau of Land Management. 2010 URS Corporation, 8181 Tufts Avenue, Denver , CO 

80237, (URS Project 22241790).

Coates- Markle, L. 2003. Stategic Research Plan, Wild Horse and Burro Management. BLM, 

Wild Horse and Burro Program, U.S. Department of Interior. [Online] 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Planning_and_Renewable_Resources/

wild_horses_and_burros.Par.91906.File.dat/Strategic%20Research%20Plan.pdf

Coates, P.S. 2007. Greater sage-grouse (Centrocercus urophasianus) nest predation and 

incubation behavior. PhD Dissertation. Idaho State University, Pocatello.

Coates, P.S. and D.J. Delehanty. 2010. Nest predation of greater sage-grouse in relation to 

microhabitat factors and predators. Journal of Wildlife Management 74:240-248. 

Coates, P. S. 2007. Greater sage-grouse (Centrocercus urophasianus) nest predation and 

incubation behavior. Ph.D. dissertation, Idaho State University, Pocatello, ID. 

Ref-6 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Connelly, J.W., A. D. Apa, R. B. Smith, and K. P. Reese. 2000a. Effects of predation and 

hunting on adult sage grouse Centrocercus urophasianus in Idaho. Wildlife Biology 

6:227–32.

Connelly, J.W., C.A. Hagen, and M.A. Schroeder. 2011b. Characteristics and dynamics of 

greater sage grouse populations. Pp. 53‐67 in S.T. Knick and J.W. Connelly. Greater 

Sage‐Grouse: ecology and conservation of a landscape species and its habitat. Studies in 

Avian Biology 38. University of California Press, Berkeley, CA.

Connelly, J.W., S.T. Knick, C.E. Braun, W.L. Baker, E.A. Beever, T. Christiansen, K.E. 

Doherty, E.O. Garton, S.E. Hanser, D.H. Johnson, M. Leu, R.F. Miller, D.E. Naugle, 

S.J. Oyler‐McCance, D.A. Pyke, K.P. Reese, M.A. Schroeder, S.J. Stiver, B.L. Walker, 

and M.J. Wisdom. 2011. Conservation of Greater Sage‐Grouse: a synthesis of current 

trends and future management. Pp. 549–563 in S. T. Knick and J. W. Connelly 

(editors). Greater Sage‐Grouse: ecology and conservation of a landscape species and 

habitats. Studies in Avian Biology (vol. 38), University of California Press, Berkeley, 

CA.

Connelly, J.W., E.T. Rinkes, and C.E. Braun. 2011. Characteristics of greater sage‐grouse 

habitats: a landscape species at micro‐ and macroscales. Pp. 69‐83 in S.T. Knick and 

J.W. Connelly. Greater Sage‐ Grouse: ecology and conservation of a landscape species 

and its habitat. Studies in Avian Biology 38. University of California Press, Berkeley, 

CA.

Connelly, J.W., K.P. Reese, and M.A. Schroeder. 2003. Monitoring sage‐grouse habitats and 

populations. University of Idaho, College of Natural Resources Experiment Station 

Bulletin 80 Moscow, Idaho, USA.

Connelly, J.W., S.T. Knick, M.A. Schroeder and S.J. Stiver. 2004. Conservation assessment of 

greater sagegrouse and sagebrush habitats. Western Association of Fish and Wildlife 

Agencies. Unpublished Report. Cheyenne, Wyoming, USA. (available at 

http://sagemap.wr.usgs.gov)

Connelly, J. W., W. L. Wakkinen, A. D. Apa, and K. P. Reese. 1991. Sage Grouse Use of Nest 

Sites in Southeastern Idaho. Journal of Wildlife Management. 55:521-524.

Connelly, J.W., Schroeder, M.A., Sands, A.R. and C.E. Braun ,2000. Guidelines to Manage 

Sage Grouse Populations and Their Habitats. Wildl. Soc. Bull., 28, 967-985.

Copeland H. E., A. Pocewicz, D. E. Naugle, T. Griffiths, D. Keinath, J. Evans, J. Platt. 2013. 

Measuring the Effectiveness of Conservation: A Novel Framework to Quantify the 

Benefits of Sage-Grouse Conservation Policy and Easements in Wyoming. PLoS ONE 

8(6): e67261. Doi:10.1371/journal.pone.0067261. 

Crawford, J. A., R. A. Olson, N. E. West, J. C. Mosley, M. A. Schroeder, T. D. Whitson, R. F. 

Miller, M. A. Gregg, And C. S. Boyd. 2004. Ecology and Management of Sage-Grouse 

and Sage-Grouse Habitat. Journal of Range Management. 57:2-19.

References Ref-7
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Crawford, J.A., R.A. Olson, N.E. West, J.C. Mosley, M.A. Schroeder, T.D. Whitson, R.F. 

Miller, M.A. Gregg, and C.S. Boyd. 2004. Ecology and management of sage‐grouse and 

sage‐grouse habitat. Journal of Range Management 57: 2‐19.

Council of Environmental Quality. 1997. Considering Cumulative Impacts under the National 

Environmental Policy Act. January 1997.

Dannenberg, Mike. 2004. Communities at Risk; Briefing Paper. Unpublished assessment of 

Montana communities and fire risk compiled by USDOI Bureau of Land Management 

Billings Field office, with contributions from various state and federal firefighting 

agencies.

Davies, K.W., C.S. Boyde, J.L. Beck, J.D. Bates, T.J. Svejcar, and J.G. Gregg. 2011. Saving 

the sagebrush ocean ecosystem conservation plan for big sagebrush. Biological 

Conservation 144:2573‐2584. 

Dechant, J. A., M. L. Sondreal, D. H. Johnson, L. D. Igl, C.M. Goldade, M. P. Nenneman, A. 

L. Zimmerman, and B. R. Euliss. 1998 (revised 2003). Effects of management practices 

on grassland birds: Loggerhead Shrike. Northern Prairie Wildlife Research Center, 

Jamestown, ND. 19 pages.

De Szalay, F.A. and V.H. Resh. 2000. Factors influencing macroinvertebrate colonization of 

seasonal wetlands: responses to emergent plant cover. Freshwater Biology. 45: 295‐308. 

Diamond, J.M., C.A. Call, and N. Devoe. 2009. Effects of targeted cattle grazing on fire 

behavior of cheatgrass‐dominated rangeland in the northern Great Basin, USA. 

International Journal of Wildland Fire 18:944–950.

Dieni, J.S., and S.L. Jones. 2003. Grassland songbird nest site selection patterns in 

northcentral Montana. Wilson Bulletin 115:32–40.

DeVelice, R.L. and P. Lesica. 1993. Plant Community Classification for Vegetation on BLM 

Land, Pryor Mountains. Carbon County, Montana. Montana Natural Heritage Program, 

Helena, MT. 78 pp.

Doherty, M.K. 2007. Mosquito populations in the Powder River Basin, Wyoming: a 

comparison of natural, agricultural, and effluent coal‐bed natural gas aquatic habitats. 

Thesis. Montana State University, Bozeman, Montanna, USA.

Doherty, K.E., D.E. Naugle, and B.L. Walker. 2010. Greater sage‐grouse nesting habitat: The 

importance of managing at multiple scales. Journal of Wildlife Management 

74:1544‐1553.

Doherty, K.E., D.E. Naugle, B.L. Walker, and J.M. Graham. 2008. Greater sage‐grouse winter 

habitat selection and energy development. Journal of Wildlife Management 72:187‐195.

Doherty, K. E., D. E. Naugle, B.L. Walker, and J.M. Graham. 2008. Greater Sage-Grouse 

Winter Habitat Selection and Energy Development. University of Montana.

Ref-8 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Doherty K. E. Naugle, D.E., H.E. Copeland A. A. Pocewicz, and J.M. Kiesecker. Energy 

Development and Conservation Trade-offs: Systematic Planning for Greater SageGrouse in their Eastern Range in S.T. Knick and J.W. Connelly (editors). Greater SageGrouse: ecology and conservation of a landscape species and its habitats. Studies in 

Avian Biology (vol 38), University of California Press, Berkeley, CA.

Doherty, K.E., D.E. Naugle, and J.S. Evans. 2010. A currency for offsetting energy 

development impacts: Horse‐trading sage‐grouse on the open market. PLoS One 

5:e10339. Accessed 19 September 2011 

http://www.plosone.org/article/info%3Adoi%2F10.1371%2Fjournal.pone0010339

Doherty, K.E., J.L. Beck, and D.E. Naugle. 2011b. Comparing ecological site descriptions to 

habitat characteristics influencing greater sage‐grouse nest site occurrence and success. 

Rangeland Ecology & Management 64: 344‐351.

Ehrlich, Paul R.; Dobkin, David S.; Wheye, Darryl. Effects of Roads on Terrestrial Vertebrates, 

1988. The birder’s handbook. New York, NY: Simon and Schuster Inc. 785 pp.

Ecosystem Management Inc., April 2009 – Section 3.5.4 Wild and Scenic Rivers - The Final 

Wild and Scenic River Eligibility Report - The study was completed in April 2009 and 

is available online at http://www.blm.gov/mt/st/en/fo/billings_field_office.html or in 

Appendix D – Final Wild and Scenic River Eligibility Report. 

Ehle, D.S. & Keinath, D.A. 2002. Habitat Mapping of Lynx Analysis Units on Bureau of Land 

Management Lands and Surrounding Areas in Wyoming. Wyoming Natural Diversity 

Database. Laramie, Wyoming.

Eiswerth, M.E. and J.S.Shonkwiler. 2006. Examining post‐wildfire reseeding on arid arid 

rangeland: a multivariate to bit modeling approach. Ecological Modeling 192:286‐298.

Ellingson, A.R., and P.M. Lukacs. 2003. Improving methods for regional landbird monitoring: 

a reply to Hutto and Young. Wildlife Society Bulletin 31:896‐902.

Elliot, Jerald K. 1963. Cave Occurrences in the Mississippian Madison Limestone of the Pryor 

Mountains. Billings, MT, Geological Society. Miscellaneous Paper No. 2, 16 pp.

Ellis, K.L. 1984. Behavior of lekking sage grouse in response to a perched golden eagle. 

Western Birds 15:37–8.

Ernest Orlando Lawrence Berkeley National Laboratory, Environmental Technologies 

Division, The Impact of Wind Power Projects on Residential Property Values in the 

United States: A Multi-Site Hedonic Analysis, December 2009.

Evangelista, P.H., A.W. Crall, and E. Bergquist. 2011. Invasive plants and their response to 

energy development. Pages 115‐129 in D.E. Naugle, editor. Energy development and 

wildlife conservation in western North America. Island Press, Washington, D.C., USA.

References Ref-9
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Farmland Protection Policy Act (FPPA). Agriculture and Food Act of 1981 (Public Law 97-98) 

containing the Farmland Protection Policy Act (FPPA)—Subtitle I of Title XV, Section 

1539-1549. The final rules and regulations were published in the Federal Register on 

June 17, 1994. [Online] http://www.nrcs.usda.gov/programs/fppa/.

FaunaWest Wildlife Consultants. 2006. Results of a Mountain Plover Survey at Selected 

Locations within the Area Managed by the BLM, Billings Field Office, Unpublished 

Report. 16 p.

Federal Land Policy and Management Act of 1976 (FLPMA) Public Law 94-579, October 21, 

1976. Geo-Heat Center. 2008. [Online] http://geoheat.oit.edu/.

Fiedler, Carl E., Keegan, Charles E., Woodall, Christopher W., and Morgan, Todd A. 2004. A 

Strategic Assessment of Crown Fire Hazard in Montana: Potential Effectiveness and 

Costs of Hazard Reduction Treatments. USDA Forest Service, Technical Report # 

PNW-GTR-622.

Fellows, S. D., and S. L. Jones. 2009. Status Assessment and Conservation Action Plan for the 

Long-billed Curlew (Numenius americanus). U.S. Department of Interior,Fish and 

Wildlife Service, Biological Technical Publication, FWS/BTP-R6012-2009, 

Washington, D.C.

Fiedler, Carl E., Charles E. Keegan III, Charistopher W. Woodall, and Todd A Morgan, A 

Strategic Assessment of Crown Fire Hazard in Montana: Potential Effectiveness and 

Costs of Hazard Reduction Treatments, United States Department of Agriculture Pacific 

Northwest Research Station, November 2004.

Fire Effects Information System. USDA, FS, Rocky Mountain Research Station, Fire Sciences 

Laboratory. [Online] http://www.fs.fed.us/database/feis/

Fire Reports. 2009. [Computer database] [Online] http://dnrc.mt.gov/FireReports. Last 

accessed September 14, 2009.

Foresman, Kerry R. 2001. The Wild Mammals of Montana, Special Publication #12, The 

American Society of Mammalogists, p.167.

Forman, R T.T., and L.E. Alexander. 1998. Roads and their major ecological effects. Annual 

Review of Ecology and Systematics 1998. 29:207‐231.

Forrest, S.C., T.W. Clark, L. Richardson, and T.M. Campbell III. 1985. Black-footed ferret 

habitat: some management and reintroduction considerations. Wyoming Bureau of 

Land Management, Wildlife Technical Bulletin, No. 2. 49 pages.

Fox, D.G., A.M. Bartuska, J.G. Byrne, E. Cowling, R. Fisher, G. E. Likens, S. E. Lindberg, R. 

A. Linthurst, J. Messer, and D.S. Nichols. 1989. A Screening Procedure to Evaluate Air 

Pollution Effects on Class I Wilderness Areas (General Technical Report RM-168). 

USFS, Rocky Mountain Forest and Range Experiment Station. Fort Collins, CO. 36 pp. 

[Online]. http://www.fs.fed.us/rm/pubs_rm/rm_gtr168.pdf.

Ref-10 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Freilich, J.E., J.M. Emlen, J.J. Duda, D.C. Freeman, and P.J. Cafaro. 2003. Ecological effects 

of ranching: a six‐point critique. BioScience 53:759‐765.

Garton, E.O., J.W. Connelly, J.S. Horne, C.A. Hagen, A. Moser, and M.A. Schroeder. 2011. 

Greater sage-grouse population dynamics and probability of persistence. Pp. 293-381 in 

S.T. Knick and J.W. Connelly (eds.), Greater Sage-grouse: ecology and conservation on 

a landscape species and its habitats. Studies in Avian Biology, vol. 38, University of 

California Press, Berkeley. 

Garton, E.O., A. G. Wells, J.A. Baumgardt and J.W. Connelly. 2015. Greater Sage-Grouse 

Population Dynamics and Probability of Persistence. Final Report to Pew Charitable 

Trusts. 18 March.

George, M. R., R. D. Jackson, C. S. Boyd, K. W. Tate. 2011. A scientific assessment of the 

effectiveness of riparian management practices. In: D.D. Briske [ed.]. Conservation 

Benefits of Rangeland Practices: assessment, recommendations, and knowledge gaps. 

Washington, DC: US Department of Agriculture, Natural Resources Conservation 

Service. P. 213-252.

GEO-Heat Center: Oregon Institute of Technology, 3201 Campus Dr., Klamath Falls, OR 

97601. [Online] http://geoheat.oit.edu/.

Gelbard, J.L., and J. Belnap. 2003. Roads as conduits for exotic plant invasions in a semiarid 

landscape. Conservation Biology 17:420‐432.

German Advisory Council on Global Change. 1998. The accounting of biological sinks and 

sources under the Kyoto Protocol: a step forwards or backwards for global 

environmental protection? German Advisory Council on Global Change (WBGU), 

Bremerhaven, Germany.

Giesen, K.M. 1995. Upland bird research: evaluation of livestock grazing and residual 

herbaceous cover on sage grouse nest success. Job final report, project number 

COW‐167‐R/Job 18/Wk.Pl. 3. Colorado Division of Wildlife, Colorado, USA.

Gillen, R. L., W. C. Krueger, and R. F. Miller. 1984. Cattle distribution on mountain rangeland 

in northeastern Oregon. Journal of Range Management 37:549-553.

Goddard Institute for Space Studies (GISS) and M. Sato. 2010. Annual Mean Temperature 

Change for Three Latitude Bands, GISS Surface Temperature Analysis, National 

Aeronautics and Space Administration, Goddard Institute for Space Studies [Website]. 

Accessed on July 30, 2010. [Online] http://data.giss.nasa.gov/gistemp/graphs/.

Goulder, Lawrence H. and William A Pizer, The Economics of Climate Change, Resources for 

the Future, 2006.

Graham, L., and B. Jones. 2005. Northern Eagle/Southern Routt Greater Sage‐Grouse 

Summary Report. Colorado Division of Wildlife, Steamboat Springs, Colorado, USA.

References Ref-11
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Graham, L., and C. McConnell. 2004. Radio‐collared greater sage‐grouse summary report: 

Southern Routt and Northern Eagle Counties, Colorado. Colorado Division of Wildlife, 

Steamboat Springs, Colorado, USA.

Grizzly Bear Management Plan for Southwestern Montana. 2002. Montana Fish, Wildlife, and 

Parks, Final Programmatic EIS, page 29, October, 2002.

Gude, Patricia H., J. Anthony Cookson, Mark C. Greenwood, Mark Haggerty, April 2009. 

Homes in Wildfire-Prone Areas: An Empirical Analysis of Wildfire Suppression Costs 

and Climate Change, Headwaters Economics.

Gude, Patricia, Ray Rasker, and Jeff van den Noort, June 2008. Potential for Future 

Development on Fire-Prone Lands, Journal of Forestry, June 2008.

Haferkamp, Marshall R. 2001. Annual Bromes – Good or Bad? A question and answer on the 

impact annual bromes have on rangelands. Rangelands 23: 32-35.

Hagen, C. 2011. Greater sage‐grouse conservation assessment and strategy for Oregon: a plan 

to maintain and enhance populations and habitats. Oregon Department of Fish and 

Wildlife, Portland, Oregon, USA.

Hagen, C.A. 2011. Predation on greater sage-grouse. Pp. 95-100 in S.T. Knick and J.W. 

Connelly (eds.), Greater Sage-grouse: ecology and conservation on a landscape species 

and its habitats. Studies in Avian Biology, vol. 38, University of California Press,

Berkeley. 

Hagen, C.A., J.W. Connelly, and M.A. Schroeder. 2007. A meta‐analysis for greater 

sage‐grouse nesting and brood rearing habitats. Wildlife Biology 13 (Supplement 

1):42‐50.

Hanna, Rebecca H. 2009. Class I Overview of the BLM Billings Resource Management Plan 

Area: Including portions of Big Horn, Carbon, Golden Valley, Musselshell, Stillwater, 

Sweet Grass, Wheatland, and Yellowstone Counties, Montana and portions of Big Horn 

county, Wyoming. Volume II: Paleontological Resources, parts I and II. Terra Paleo 

Research, November 23, 2009.

Hansen, A.J., R.L. Knight, J.M. Marzluff, S. Powell, K. Brown, P. H. Gude, K. Jones. 2005. 

Effects of Exurban Development on Biodiversity: Patterns, Mechanisms, and Research 

Needs. Ecological Applications, 15 (6): 1893-1905.

Hanser, Steve E. and Steven T. Knick, 2011.Greater Sage-Grouse as an umbrella species for 

shrubland passerine birds: a multi-scale assessment. Pp. 473-487 in S.T. Knick and J. 

W. Connelly (editors). Greater sage grouse ecology and conservation of a landscape 

species and it habitats. Studies in Avian Biology (vol. 38), University of California 

Press, Berkeley, California.

Hardy, Lynn. Recreation Specialist. Billings Field Office, BLM, Billings Montana. 2008.

Ref-12 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Harju, S.M., M.R. Dzialak, R.C. Taylor, L.D. Hayden-Wing, and J.B. Winstead. 2010. 

Thresholds and time lags in effects of energy development on greater sage grouse 

populations. Journal of Wildlife Management 74:437-48.

Harris, N., K. Wright and G. Hayden. 2009. Class I Overview of the BLM Billings Resource 

Management Plan Area: Including portions of Big Horn, Carbon, Golden Valley, 

Musselshell, Stillwater, Sweet Grass, Wheatland, and Yellowstone Counties, Montana 

and portions of Big Horn County, Wyoming. Volume I: Cultural Resources, parts I and 

II. Ecosystems Management, Inc., Field Research Services, and Terra Paleo Research. 

EMI Report Number 54730. November 28, 2009.

Headwaters Economics, Economic Profile System-Human Dimensions Toolkit, A Profile of 

Demographics for the Billings RMP, March 2011.

Heidel, B. 2001. Conservation status of Rorippa calycina (persistent-sepal yellowcress) in 

Montana. Report to the U.S. Fish and Wildlife Service. Montana Natural Heritage 

Program, Helena. 10 pp.

Heidel, B. 2001. Monitoring Shoshonea pulvinata in the Pryor and Beartooth Mountains, 

Carbon County, Montana. 1999 trend report to Bureau of Land Management, MT. 

Montana Natural Heritage Program, Helena. 11 pp. plus appendices.

Heidinga, L., and S. D. Wilson. 2002. The Impact of an Invading Alien Grass (Agropyron 

cristatum) on Species Turnover in Native Prairie. Diversity and Distributions. 8:249-

258.

Henderson, F.R., P.F. Springer, and R.Adrian. 1969. The black-footed ferret in South Dakota.

South DakotaVerDate 11<MAY>2000 15:58 Jul 17, 2000 Federal Register/Vol. 65, 

No. 138 /Tuesday, July 18, 2000 / Proposed Rules 44517 Department of Game, Fish 

and Parks, Technical Bulletin 4:1–36.

Hendricks, P., C. Currier, and J. Carlson, 2004. Bats of the Bureau of Land Management, 

Billings Field Office in South-central Montana, with Emphasis on the Pryor Mountains. 

Report to the BLM, Billings Field Office. Montana Natural Heritage Program, Helena, 

MT. 19 pp. + Appendices.

Herd Management Plan (HMAP), BLM-MT-PT-84-019-4321/June 1984). [Online} 

http://www.blm.gov/pgdata/etc/medialib/blm/mt/field_offices/billings/horseeas/2009.Pa

r.65280 File.dat/DRFONSIPMWHRHMAP.pdf

Herd Management Plan (HMAP), BLM-MT-PT-84-019-4321/June 1984). Section 3.3.8

Holdren, John P., Science and Technology for Sustainable Well-Being, Science, January 25, 

2008.

Holloran, M.J. 2005. Greater sage‐grouse (Centrocercus urophasianus) population response to 

natural gas field development in western Wyoming. Dissertation, Department of 

Zoology and Physiology, University of Wyoming, Laramie, Wyoming.

References Ref-13
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Holloran, M.J., and S.H. Anderson. 2005. Spatial distribution of greater sage grouse nests in 

relatively contiguous sagebrush habitats. Condor 107:742-752.

Holloran, M.J., R.C. Kaiser, and W.A. Hubert. 2010. Yearling greater sage‐grouse response to 

energy development in Wyoming. Journal of Wildlife Management 74:65–72.

Holloran, M.J., R.C. Kaiser, and W.A. Hubert. 2007 Population response of yearling greater 

sage grouse to the infrastructure of natural gas fields in southwestern Wyoming. 

Completion report. Wyoming Cooperative Fish and Wildlife Research Unit, Laramie, 

WY.

Holloran, M. J. and S. H. Anderson. 2005. Greater sage-grouse populations response to natural 

gas development in western Wyoming: Are regional populations affected by relatively 

localized disturbances? In wildlife Management Institute (Ed.), Transactions from the 

70th North American Wildlife and Natural Resources Conference (March 16-19, 2005, 

Arlington, VA). Wildlife Management Institute. 

Howard, Janet L. 1996. Populus tremuloides. Fire Effects Information System. U.S. 

Department of Agriculture, Forest Service, Rocky Mountain Research Station, Fire

Sciences Laboratory (Producer). [Online] http://www.fs.fed.us/database/feis/. Accessed 

October 10, 2008.

Hunt, Charles B. 1967. Physiography of the United States. W.H. Freeman and Company, San 

Francisco, CA.

Idaho Sage-grouse Advisory Committee. 2006. Conservation Plan for the Greater Sage-grouse 

in Idaho. 

IMPLAN Professional (ver 2.0). 2006. [Social Accounting and impact analysis software.] 

Minnesota IMPLAN Group, Inc. Stillwater, Minnesota.

IMPLAN. 2009 Dataset, MIG, Inc. (Minnesota IMPLAN Group), 2010.

Independent Petroleum Association of America, IPAA Oil & Gas Producing Industry in Your 

State, 2009-2010, August 2010.

Inter-agency Standards for Fire and Fire Aviation Operations. Redbook, 2008. National 

Interagency Fire Center, Boise, Idaho. http://www.nifc.gov/policies/red_book.htm.

Intergovernmental Panel on Climate Change (IPCC). 2001. IPCC Third Assessment Report: 

Climate Change 2001. [Online]. http://www.grida.no/publications/other/ipcc_tar/.

Intergovernmental Panel on Climate Change (IPCC). 2007. IPCC Fourth Assessment Report: 

Climate Change 2007. [Online] 

http://www.ipcc.ch/publications_and_data/publications_and_data_reports.shtml.

Ref-14 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Inventory of Onshore Federal Oil and Gas Resources and Restrictions to Their Development. 

2008. U.S. Departments of the Interior, Agriculture, and Energy.[Online] 

http://www.blm.gov/wo/st/en/prog/energy/oil_and_gas/EPCA_III.html.

Jackson, S.D. 2000. Overview of Transportation Impacts on Wildlife Movement and 

Populations. Pp. 7‐20 In Messmer, T.A. and B. West, (editors) Wildlife and Highways: 

Seeking Solutions to an Ecological and Socio‐economic Dilemma. The Wildlife 

Society.

Johnsgard, P. 1990. Hawks, Eagles and Falcons of North America. Washington DC: 

Smithsonian Institution. 

Johnson, C.J., and Martin‐Hughes St‐Laurent. 2011. Unifying framework for understanding 

impacts of human developments on wildlife. Pages 27‐54 in D.E. Naugle, editor. 

Energy development and wildlife conservation in western North America. Island Press, 

Washington, D.C., USA.

Johnson, D.H., M.J. Holloran, J.W. Connelly, S.E. Hanser, C.L. Amundson, and S.T. Knick. 

2011. Influences of environmental and anthropogenic features on greater sage‐grouse 

populations. Pages 407‐450 in S.T. Knick and J.W. Connelly, editors. Greater 

sage‐grouse: ecology and conservation of a landscape species and its habitats. Studies in 

Avian Biology 38. University of California Press, Berkeley, California, USA.

Johnson, Kathleen A. 2001. Pinus flexilis. Fire Effects Information System. USDA, FS, Rocky 

Mountain Research Station, Fire Sciences laboratory (Producer).

Kaiser, R.C. 2006. Recruitment by greater sage‐grouse in association with natural gas 

development inwestern Wyoming. Thesis, University of Wyoming, Laramie.

Keegan, Charles E. III, Fiedler, Carl E., and Morgan, Todd A. 2002. Wildfire in Montana 

Potential Hazard Reduction and Economic Effects of a Strategic Treatment Program. 

Montana Business Quarterly, Autumn 2002.

Kirschbaum, M.A. 2008. Assessment of Undiscovered Oil and Gas Resources of the Bighorn 

Basin Province, Wyoming and Montana. U.S. Geological Survey Fact Sheet. 2008–

3050, 2 pp.

Klement, K.D., R.K. Heitschmidt, and C.E. Kay. 2001. Eighty Years of Vegetation 

andLandscape. Changes in the Northern Great Plains: A Photographic Record. U.S. 

Department of Agriculture, Agricultural Research Service, Conservation Research 

Report. 45 pp.

Knapp, N. C. 1956. Devil’s Basin Oil Field, Musselshell County, Montana. Billings Geological 

Society Seventh Annual Field Conference.

Knick, S. T. 2011. Historical development, principal federal legislation and current 

management of sagebrush habitats: implications for conservation. Pages 13-32 in S. T. 

Knick and C. J. W., editors. Greater Sage-Grouse: ecology of a landscape species and 

References Ref-15
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

its habitats. Cooper Ornithological Union, University of California Press, Berkeley, 

California.

Knick, S.T. Historical Development, Principal Federal Legislation, and Current Management of 

Sagebrush Habitats: Implications for Conservation in S.T. Knick and J.W. Connelly 

(editors). Greater Sage-Grouse: ecology and conservation of a landscape species and its 

habitats. Studies in Avian Biology (vol 38), University of California Press, Berkeley, 

CA. 

Knick, S. T. and J. W. Connelly. An introduction to the Landscape. in S.T. Knick and J.W. 

Connelly (editors). Greater Sage-Grouse: ecology and conservation of a landscape 

species and its habitats. Studies in Avian Biology (vol 38), University of California 

Press, Berkeley, CA. 

Knick, S.T., S. E. Hanser, R. F.Miller, D. A. Pyke, M. J. Wisdom, S. P. Finn, E. T. Rinkes, and 

C. J. Henny. Ecological Influence and Pathways of Land Use in Sagebrush in S.T. 

Knick and J.W. Connelly (editors). Greater Sage-Grouse: ecology and conservation of a 

landscape species and its habitats. Studies in Avian Biology (vol 38: 203-251), 

University of California Press, Berkeley, CA. 

Knick, S.T., D.S. Dobkin, J.T. Rotenberry, M.A. Schroeder, W.M. Vander Haegen, and C. van 

Riper III. 2003. Teetering on the edge or too late? Conservation and research issues for 

avifauna of sagebrush habitats. Condor 105:611‐634.

Knick, S.T. and S.E. Hanser. 2011. Connecting pattern and process in greater sage‐grouse 

populations and sagebrush landscapes. Pages 383‐406 in S.T. Knick and J.W. Connelly, 

editors. Greater sage‐grouse:ecology and conservation of a landscape species and its 

habitats. Studies in Avian Biology 38. Cooper Ornithological Union, University of 

California Press, Berkeley, California, USA.

Knick S.T., S.E. Hanser, R.F. Miller, D.A. Pyke, M.J. Wisdom, S.P. Finn, E.T. Rinkes and C.J. 

Henny. 2011.Ecological Influence and Pathways of Land Use in Sagebrush. Pp. 

203‐251 in S.T. Knick and J.C. Connelly (editors), Greater Sage‐Grouse: ecology and 

conservation of a landscape species and itshabitats. Studies in Avian Biology (vol. 38), 

University of California Press, Berkley, CA.

Knight, R.L., W.E. Walton, G.F. Meara, W.K. Riesen and R. Wass. 2003. Strategies for 

effective mosquito control in constructed treatment wetlands. Ecological Engineering. 

21: 211‐232.

Kolada, E.J., M.L. Casazza, and J.S. Sedinger. 2009. Ecological factors influencing nest 

survival of greater sage‐grouse in Mono County, California. Journal of Wildlife 

Management 73:1341‐1347.

Kramer, A.T. and K. Havens. 2009. Plant conservation genetics in a changing world. Trends in 

Plant Science 14:599‐607.

Ref-16 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Krieger, Douglas J. 2001. Economic Value of Forest Ecosystem Services: a Review. Prepared 

for the Wilderness Society. 

Lammers, W.M., and M.W. Collopy. 2007. Effectiveness of avian predator perch deterrents on 

electric transmission lines. Journal of Wildlife Management 1:2752‐2758.Launchbaugh, 

K., B. Brammer, M.L. Brooks, S. Bunting, P. Clark, J. Davison, M. Fleming, R. Kay, 

M. Pellant, D.

Lane, V. R. 2005. Sage-grouse (Centrocercus urophasianus) Nest and Brood-Rearing 

Sagebrush Habitat Characteristics in Montana and Wyoming [thesis]. Bozeman, MT: 

Montana State University. 63 p.

LANDFIRE National Existing Vegetation Type layer 2006. Performance Requirements. 2006. 

The National Map LANDFIRE: LANDFIRE National Existing Vegetation Type layer. 

Last update: [Computer gis/database]. U.S. Department of Interior, Geological Survey, 

(Online). [Online] http://gisdata.usgs.net/website/landfire/. Accessed: February 8, 

2007.

Lands & Realty Database (LR2000) – Section 3.6.2

Lawler, Joshua J., Sarah L. Shafer, Denis White, Peter Kareiva, Edwin P. Maurer, Andrew R. 

Blaustein, and Patrick J. Bartlein. 2009. Projected climate-induced faunal change in the 

Western Hemisphere, Ecology. 90(3): 588-597.

Lenard S., J. Carlson, J. Ellis, C. Jones, and C. Tilly, P.D. Skaar’s Montana Bird Distribution, 

6th Edition, 2003. 

Lesica, P. and P.L. Achuff. 1992. Distribution of Vascular Plant Species of Special Concern 

and Limited Distribution in the Pryor Mountain Desert. Carbon County, Montana. 

Montana. Natural Heritage Program for BLM, Montana State Office. Helena, MT.

Leu, M. and S.E. Hanser. 2011. Influences of the Human Footprint on Sagebrush Landscape 

Patterns: Implications for Sage-Grouse Conservation in S.T. Knick and J.W. Connelly 

(editors). Greater Sage-Grouse: ecology and conservation of a landscape species and its 

habitats. Studies in Avian Biology (vol 38), University of California Press, Berkeley, 

CA

Leu, M., S.E. Hanser, and S.T. Knick. 2008. The human footprint in the West: a large-scale 

analysis of anthropogenic impacts. Ecological Applications 18:1119-1139.

Liebig, M.A., J. R. Gross, S. L. Kronberg, R. L. Phillips, and J. D. Hanson (2010). Grazing 

Management Contributions to Net Global Warming Potential: A Long-term Evaluation 

in the Northern Great Plains, U.S. Department of Agriculture, American Society of 

Agronomy, Crop Science Society of America, and Soil Science Society of America.

Loehman, R., and G. Anderson. 2009. Understanding the science of climate change: talking 

points – impacts to Western Mountains and Forests. Natural Resource Report 

NPS/NRPC/NRR-2009/090. National park Service, Fort Collins, Colorado. 

References Ref-17
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Loomis, J. B. 2005. Updated Outdoor Recreation Use Values on National Forests and Other 

Public Lands. Colorado State University, Fort Collins, CO. Performed under PNW-03-

JV11261955-265 USDA.

Loomis, J. B. and R. B. Richardson. 2000. Economic values of protecting roadless areas in the 

United States. Prepared for The Wilderness Society and Heritage Forests Campaign.

Loomis, J. B. and R. B. Richardson. 2001. Economic Values of Protecting Wilderness Areas in 

the United States. International Journal of Wilderness, v7, n1.

Loomis, John. Updated Outdoor Recreation Use Values on National Forests and Other Public 

Lands, Forest Service General Technical Report, FNW-GRT-658, October 2005.

Lopez, D.A., 2000, Geologic map of the Big Timber 30' x 60' quadrangle, south-central 

Montana, Montana Bureau of Mines and Geology: Open-File Report 405, 1 sheet(s), 

1:100,000.

Lopez, D.A., 2000, Geologic map of the Billings 30' x 60' quadrangle, Montana, Montana 

Bureau of Mines and Geology: Geologic Map 59, 1 sheet(s), 1:100,000.

Lopez, D.A., 2000, Geologic map of the Bridger 30' x 60' quadrangle, Montana, Montana 

Bureau of Mines and Geology: Geologic Map 58, 1 sheet(s), 1:100,000.

Lopez, D.A., 2001, Preliminary geologic map of the Red Lodge 30' x 60' quadrangle, southcentral Montana, Montana Bureau of Mines and Geology: Open-File Report 423, 17 p., 

1 sheet(s).

Lutgens, F. D., & Tarbuck, E. J. 1989. Essentials of geology (3rd ed.). Columbus, OH: Merrill 

Publishing Company.

Lyon, A.G. and S.H. Anderson. 2003. Potential gas development impacts on sage grouse nest 

initiation and movement. Wildlife Society Bulletin 31: 486‐491.

Lyon, L. J., Lonner, T. N., Weigand, J. P., Marcum, C. L., Edge, W. D., Jones, J. D., 

McCleerey, D. W. and Hicks, L. L. 1985. Coordinating Elk and Timber Management: 

Final Report of the Montana Cooperative Elk-Logging Study, 1970-1985. Montana 

Department of Fish, Wildlife and Parks, Bozeman, MT. Appendix S, pages 309-314.

Lyons, J.E., M.C. Runge, H.P. Laskowski, and W.L. Kendall. 2008. Monitoring in the context 

of structure decision‐making and adaptive management.

McArthur, E.D.; Stevens, R. 2004. Composite shrubs. In Monsen, S.B.; Stevens, R.; Shaw, N.L., 

comps. Restoring western ranges and wildlands. Gen. Tech. Rep. RMRS-GTR-136-vol2. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain 

Research Station: 493-537.

Ref-18 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Madson, M., and G. Hanson, 1992. Bat Hibernaculum Search in the Pryor Mountains of SouthCentral Montana. February and March 1992. Montana Natural Heritage Program. 

Helena, MT.

Malainey, Mary E. and B.L. Sherriff. 1996. Adjusting our perceptions: historical and 

archaeological evidence of winter on the plains of Western Canada. Plains 

Anthropologist 41(158): 333-357.

Manier, D. J., D. J. A. Wood, Z. H. Bowen, R. M. Donovan, M. J. Holloran, L. M. Juliusson, 

K. S. Mayne,, S. J. Oyler-McCance, F. R. Quamen, D. J. Saher, and A. J. Titolo. 2013. 

Summary of Science, Activities, Programs and Policies that Influence the Rangewide 

Conservation of Greater Sage-Grouse (Centrocercus urophasianus). U.S. Geological 

Survey Open-File Report 2013-1098, Fort Collins, Colorado.

Manville, A.M., II. 2004. Prairie grouse leks and wind turbines: U.S. Fish and Wildlife Service 

justification for a 5-mile buffer from leks; additional grassland songbird 

recommendations. Division of Migratory Bird Management, USFWS, Arlington, VA, 

peer-reviewed briefing paper. 17 pp.

Maser, C., and J.S. Gashwiler. 1977. Inter-relationships of Wildlife and Western Juniper. 

General Technical Bulletin PNWGTR-4, USDA Forest Service, Pacific Northwest 

Experiment Station, Portland, OR.

May, B. E. 1998. Yellowstone Cutthroat trout: Current Status and Conservation 

Recommendations with the State of Montana. U.S. Forest Service, Gallatin National

Forest, Bozeman, Montana.

McDonald, C., Lopez, D.A., Berg, R.B., Gibson, R.I., 2005, Preliminary geologic map of the 

Ringling 30' x 60' quadrangle, central Montana, Montana Bureau of Mines and 

Geology: Open-File Report 511, 27 p., 1 sheet(s), 1:100,000.

Meinke, C.W., S.T. Knick, and D.A. Pyke. 2009. A spatial model to prioritize sagebrush 

landscapes in the intermountain west (U.S.A.) for restoration. Restoration Ecology 

17:652‐659.

Messmer, T.A., M.W. Brunson, D. Reiter, and D.G. Hewitt. 1999. United States public 

attitudes regarding predators and their management to enhance avian recruitment. 

Wildlife Society Bulletin 27:75-85. 

Mezquida, E.T., S.J. Slater, and C. Benkman. 2006. Sage-grouse and indirect interactions: 

potential implications of coyote control on sage-grouse populations. Condor 108:747-

759. 

MFISH, 2008. Montana Fisheries Information System (MFISH). [Computer database] [Online] 

http://fwp.mt.gov/fishing/mfish/. 

Miller, Christina. Montana State Lead, Outdoor Recreation Planner. Montana State Office, 

BLM, Billings Montana, 2008.

References Ref-19
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Miller, R. G., Knick, S. T., Pyke, D. A., Meinke, C. W., Hanser, S. E., Wisdom, M. J. and Hild, 

A. L. 2011. Characteristics of sagebrush habitats and limitations to long-term 

conservation, in Knick, S. T., and Connelly, J. W., eds., Greater Sage-Grouse: ecology 

of a landscape species and its habitats: Berkeley, Calif., University of California Press, 

Cooper Ornithological Union, Pp. 145-184.

Miller, R.F., S.T. Knick, D.A. Pyke, C.W. Meinke, S.E. Hanser, M.J. Wisdom, and A.L. Hild. 

2011. Characteristics of sagebrush habitats and limitations to long‐term conservation. 

Pp. 145‐184 in S.T.Knick and J.W. Connelly (editors). Greater sage‐grouse: ecology 

and conservation of a landscape species and its habitats. Studies in Avian Biology 38. 

University of California Press, Berkeley, CA.

Mincemoyer, S. 2006. Surveys of Significant Plant Resources in Southeast and South-central 

Montana on the Billings and Miles City Field Offices of the Bureau of Land 

Management. Report to the USDI Bureau of Land Management, Millings and Miles 

City Field Offices. Montana Natural Heritage Program, Helena, MT. 22 pp. + 

appendices.

Minnesota IMPLAN Group, Inc. Economic Information Technology. 2007. [IMPLAN Data 

and Software for economic impact analysis]. Stillwater, Minnesota.

Montana Aquatic Nuisance Species (ANS) Management Plan-Final. 2002. Aquatic Nuisance 

Species (ANS) Task Force. [Online] www.anstaskforce.gov/MontanaFINAL_PLAN.pdf\

Montana Bald Eagle Working Group. 2009. Montana Bald Eagle Management Guidelines: An 

Addendum to Montana Bald Eagle Management Plan, 1994. 

Montana Board of Oil and Gas. 2007. 2007 Annual Review, available at 

http://bogc.dnrc.state.mt.us/annualreviews.asp. Accessed December 11, 2009.

Montana Board of O&G Conservation. 2008. [Online] http://bogc.dnrc.state.mt.us/jdpintro.asp. 

[Online] http://bogc.dnrc.state.mt.us/JDPloginWeb.htm.

Montana Climate Change Action Plan, Final Report of the Governor’s Climate Change 

Advisory Committee, November 2007.

Montana Coal Council, Montana Coal 2010.

Montana Code Annotated, Title 17-3-240, Federal Mineral Leasing Funds, 2009.

Montana Code Annotated, Title 15-39-101, Production Tax Rates Imposed on Bentonite 

Production, 2011.

Montana Comprehensive Fish and Wildlife Conservation Strategy, Executive Summary, 2005. 

Montana Fish Wildlife and parks 1420 East 6th Ave, Helena. Montana, 59620.

Ref-20 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Montana/Dakotas Bureau of Land Management. 2010. Reasonable Foreseeable Development 

Scenario for the Billings and Pompeys Pillar National Monument Resource 

Management Plan, Billings Field Office, Montana/Dakotas Bureau of Land 

Management, February 2010, unpublished BLM report

http://www.blm.gov/style/medialib/blm/mt/field_offices/billings/rmp.Par.22975.File.dat

/RFD.pdf

Montana Department of Agriculture. 2008. Montana Noxious Weed List. 

http://agr.mt.gov/weedpest/noxiousweedlist.asp. Website updated on April 15, 2008

Montana Department of Environmental Quality. 2007. Montana Geothermal Energy Sites. 

http://www.deq.state.mt.us/energy/geothermal/sites.asp. Site updated May 3, 2007. 

Accessed December 10, 2009. 

Montana Department of Environmental Quality, Department of Air Quality. 2009. Air Quality 

Control Implementation Plan. [Online] http://www.deq.mt.gov/AirQuality/. Last 

Accessed 9/14/2009.

Montana Department of Environmental Quality (MDEQ). 2009. Air Quality Permit #3179-04 

issued to Signal Peak Energy LLC. February 9, 2009.

Montana Department of Environmental Quality. 2011. Montana Commercial Wind Projects. 

http://www.deq.mt.gov/Energy/Renewable/WindWeb/WindProjectsMT.mcpx.

Accessed 2011.

Montana Department of Environmental Quality (MDEQ). 2013. Montana Department of 

Environmental Quality Air Resources Management Bureau. State of Montana Air 

Quality Monitoring Network Plan. May. Available at 

http://deq.mt.gov/AirQuality/AQInfo/PDF/MT_2013_NETWORK_PLAN.pdf.

Montana Department of Natural Resources and Conservation, 2007. Oil and Gas Conservation 

Division. Annual Review 2007. [Online] http://bogc.dnrc.mt.gov/AR_2007.pdf . Last 

accessed 9/14/2009.

Montana Department of Revenue, FY 2006 – Section 3.6.2.

Montana Field Guide. 2009. Montana Natural Heritage, State of Montana. [Online] 

http://fieldguide.mt.gov/. Last accessed 9/14/2009.

Montana Field Guide. 2011. Baird’s Sparro. Montana Natural Heritage Program and Montana 

Fish, Wildlife and Parks. Retrieved on February 4, 2010, from 

http://FieldGuide.mt.gov/detail_ABPBXA0010.aspx

Montana Field Guide. 2011. Blue-gray Gnatcatcher — Polioptila caerulea. Montana Natural 

Heritage Program and Montana Fish, Wildlife and Parks. Retrieved on September 20, 

2011, from http://FieldGuide.mt.gov/detail_ABPBJ08010.aspx

References Ref-21
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Montana Field Guide. 2011. Swainson's Hawk — Buteo swainsoni. Montana Natural Heritage 

Program and Montana Fish, Wildlife and Parks. [Online] Retrieved on June 16, 2011, 

from http://FieldGuide.mt.gov/detail_ABNKC19070.aspx.

Montana Field Guide. 2011. Red-headed Woodpecker — Melanerpes erythrocephalus. 

Montana Natural Heritage Program and Montana Fish, Wildlife and Parks. [Online] 

Retrieved on June 16, 2011, from http://FieldGuide.mt.gov/detail_ABNYF04040.aspx.

Montana Field Guide. 2011. Spotted Bat — Euderma maculatum. Montana Natural Heritage 

Program and Montana Fish, Wildlife and Parks. Retrieved on September 20, 2011, from 

http://FieldGuide.mt.gov/detail_AMACC07010.aspx

Montana Field Guide. 2012. Big Sagebrush Steppe — Inter-Mountain Basins Big Sagebrush 

Steppe. [Online] Retrieved on February 14, 2012, from 

http://FieldGuide.mt.gov/displayES_Detail.aspx?ES=5454

Montana Fish Wildlife and Parks. 2005. Management Plan and Conservation Strategies for 

Sage Grouse in Montana, Final. Montana Sage Grouse Work Group. 2005. 

Montana Fish Wildlife and Parks, Progress Report, MFWP, Internal Document, 7/2009-6/2010.

Montana Fish, Wildlife, and Parks, Crucial Areas Planning System (CAPS) website, 2011. 

[Online] http://fwp.mt.gov/gis/maps/caps/.

Montana Fish, Wildlife, and Parks. 2011. Greater Sage-grouse Core Areas. Retrieved on 

February 15, 2012, from http://fwp.mt.gov/gisData/imageFiles/sgcore.jpg

Montana Geothermal, The. 2008. Montana Department of Environmental Quality. [Online] 

http://www.deq.mt.gov/energy/geothermal/. Accessed October 6, 2008.

Montana GHG Inventory and Reference Case Projection. CCS, September 2007. Montana 

Greenhouse Gas Inventory and Reference Case Projections 1990-2020. 

www.mtclimatechange.us/ewebeditpro/items/O127F13145.pdf

Montana Non-Point Management Plan. Montana DEQ, Department of Water Quality. 2007. 

[Online] 

http://www.deq.state.mt.us/wqinfo/nonpoint/2007NONPOINTPLAN/Final/NPSPlan.pdf.

Montana Natural Heritage Program, Natural Heritage Tracker, Pallid Bat, 2011

Montana Prairie Dog Working Group. 2002. Conservation Plan for Black-tailed and Whitetailed Prairie Dogs in Montana. Montana Prairie Dog Working Group. [Online] 

http://fieldguide.mt.gov/.

Montana Sage Grouse Working Group. 2005. Management Plan and Conservation Strategies 

for Sage Grouse in Montana, Final. Montana Sage Grouse Work Group. Helena, 

Montana. Montana Fish, Wildlife, and Parks. [Online] www.fwp.mt.gov.

Ref-22 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Montana Sage Grouse Working Group 2005. Management Plan and Conservation Strategies for 

Sage Grouse in Montana-Final. Revised February 1, 2005.

Montana’s Greater Sage-grouse Habitat Conservation Advisory Council. 2014. Greater SageGrouse Habitat Conservation Strategy.

Montana , Oil and Gas Information System. [Computer database]. Board of Oil & Gas, 

Montana Department of Natural Resources and Conservation. [Online] 

http://bogc.dnrc.state.mt.us/jdpintro.asp.

Morgan, T.A., Fiedler, C.E., and Woodall, C, W. 2002. Characteristics of Dry Site Old-growth 

Ponderosa Pine in the Bull Mountains of Montana, USA. Natural Areas Journal 22.

Mosely, J.C., P.S.Cook, A.J Grifiis, and J. O’Laughlin. 1997. Guidelines for Managing Cattle 

in Riparian Areas to Protect Water Quality: Review of Research and Best Management 

Practices Policy. For., Wildl., Range Policy Analysis Group, Rep. 15 College For., 

Wildl. and Range Sci., Univ. Idaho, Moscow, ID.

Mosier, A., D. Schimel, D. Valentine, K. Bronson, and W. Parton. 1991. Methane and nitrous 

oxide fluxes in native, fertilized and cultivated grasslands. Nature 350:330–332.

Moynahan, B.J. 2004. Landscape-scale factors affecting population dynamic of greater sage 

grouse in northcentral Montana, 2001-2004. Dissertation, The University of Montana, 

Missoula, MT.

Moynahan, B.J. and M.S. Lindberg. 2006. Nest locations of greater sage‐grouse in relationship 

to leks in north‐central Montana. Unpublished report.

Moynahan, B.J., M.S. Lindberg, and J.W. Thomas. 2006. Factors contributing to process 

variance in annual survival of female greater sage-grouse in Montana. Ecological 

Applications 16:1529-2538.

Moynahan, B.J., M.S. Lindberg, J.J. Rotella, and J.W. Thomas. 2007. Factors affecting nest 

survival of greater sage-grouse in northcentral Montana. Journal of Wildlife 

Management 71:1773-1783. 

Mueller, Julie M., John Loomis, and Armando Gonzales-Caban. 2008. Do Repeated Wildfires 

Change Homebuyers’ Demand for Homes in High Risk Areas? A Hedonic Analysis of 

the Short- and Long-Term Effects of Repeated Wildfires on House prices in Southern 

California.

Multi-Hazard Mitigation Plan and Statewide Hazard Assessment. 2004. State of Montana. 

October, 2004. [Online] http://dma.mt.gov/des/Library/PDM/PDM Final 

Draft/WildlandandRangelandFireHazard/Profile.pdf

National Atmospheric Deposition Program (NADP). 2010a. Illinois State Water Survey, 

University of Illinois at Urbana-Champaign, National Atmospheric Deposition Program 

(NRSP-3) [Database]. Accessed on July 30, 2010. [Online] http://nadp.sws.uiuc.edu/.

References Ref-23
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

National Atmospheric Deposition Program. 2010b. Illinois State Water Survey, University of 

Illinois at Urbana-Champaign, National Atmospheric Deposition Program (NRSP-3), 

Inorganic nitrogen wet deposition from nitrate and ammonium, 2008. Accessed on July 

30, 2010. [Online] http://nadp.sws.uiuc.edu/maps/?n=1&m=2&a=11&y=15.

National Atmospheric Deposition Program. 2010c. Illinois State Water Survey, University of 

Illinois at Urbana-Champaign, National Atmospheric Deposition Program (NRSP-3), 

Hydrogen ion concentration as pH from measurements made at the Central Analytical 

Laboratory, 2008. Accessed on July 30, 2010. [Online] 

http://nadp.sws.uiuc.edu/maps/?n=1&m=1&a=1&y=15.

National Atmospheric Deposition Program. 2010d. Illinois State Water Survey, University of 

Illinois at Urbana-Champaign, National Atmospheric Deposition Program (NRSP-3), 

Nitrate ion concentration, 2008. Accessed on July 30, 2010. [Online] 

http://nadp.sws.uiuc.edu/maps/?n=1&m=1&a=4&y=15.

National Atmospheric Deposition Program. 2010e. Illinois State Water Survey, University of 

Illinois at Urbana-Champaign, National Atmospheric Deposition Program (NRSP-3), 

Ammonium ion concentration, 2008. Accessed on July 30, 2010. [Online] 

http://nadp.sws.uiuc.edu/maps/?n=1&m=1&a=5&y=15.

National Atmospheric Deposition Program. 2010f. Illinois State Water Survey, University of 

Illinois at Urbana-Champaign, National Atmospheric Deposition Program (NRSP-3), 

Total mercury concentration, 2008. Accessed on July 30, 2010. [Online] 

http://nadp.sws.uiuc.edu/maps/?n=2&m=1&a=12&y=15.

National Audubon Society 2011. Important Bird Areas in the U.S. [Online] 

http://www.audubon.org/bird/iba.

National Mitigation Center. 2008. The Draught Monitor. University of Nebraska, Lincoln, NE. 

[Online] http://drought.unl.edu/dm/monitor.html.

National Park Service (NPS). 2010. Observed and Projected Ecological Response to Climate 

Change in the Rocky Mountains and Upper Columbia Basin: A Synthesis of Current 

Scientific Literature. U.S. Department of the Interior, National Park Service. Natural 

Resource Report NPS/ROMN/NRR-2010/220.

Natural Resource Information Service (NRIS), 2011a. Montana NRIS. Accessed July 13, 2011.

http://nris.mt.gov/gis/gisdatalib/downloads/precip71_00.gif

Natural Resources Conservation Service. 2015. Greater Sage-Grouse Habitat Conservation 

Strategy. USDA. February.

NatureServe. 2008. NatureServe Explorer. [Computer databased (vers 7.0)]. Arlington, 

Virginia. [Online] http://www.natureserve.org/explorer. Accessed: December 3, 2008.

Naugle, D.E. and B.L. Walker. 2007. A collaborative vision for integrated monitoring of 

greater sage‐grouse populations. Pp. 57‐62 in K.P. Reese and R.T. Bowyer (editors). 

Ref-24 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Monitoring populations of sage‐grouse: proceedings of a symposium at Idaho State 

University. University of Idaho College of Natural Resources Station Bulletin 88. 

University of Idaho, Moscow, ID.

Naugle, D.E., K.E. Doherty, B.L. Walker, H.E. Copeland, M.J. Holloran, and J.D. Tack. 2011a. 

Sage‐grouse and cumulative impacts of energy development. Pages 55‐70 in D.E. 

Naugle, editor. Energy development and wildlife conservation in western North 

America. Island Press, Washington, D.C., USA.

Naugle, D.E., K. E. Doherty, B. L. Walker, M. J. Holloran, and H.E. Copeland. Energy 

Development and Greater Sage-Grouse in S.T. Knick and J.W. Connelly (editors). 

Greater Sage-Grouse: ecology and conservation of a landscape species and its habitats. 

Studies in Avian Biology (vol 38), University of California Press, Berkeley, CA.

Newell, J., Personal Communication, Montana Fish, Wildlife, and Parks, Wildlife Biologist, 

Roundup, MT. 2010. 

Northeast Wyoming Sage-Grouse Working Group. 2014. Northeast Wyoming Sage-Grouse 

Conservation Plan. August 15th 2006.

Northern Cheyenne Tribe. 2002. The Northern Cheyenne Tribe and Its Reservation. Prepared 

by the Northern Cheyenne Tribe. 

http://www.blm.gov/pgdata/etc/medialib/blm/mt/field_offices/miles_city/og_eis/cheyen

ne.Par.87075.File.dat/Cover.pdf&sa=U&ei=QITiTtfTNKW2QWkoI24BA&ved=0CA8QFjAA&usg=AFQjCNFLE9CxAEusMw1Wo4zEJ3Cq

17CWbQ

Northwest Colorado Greater Sage-Grouse Working Group. 2008. Northwest Colorado Greater 

Sage-Grouse Conservation Plan. Internet website: 

http://cpw.state.co.us/learn/Pages/SagegrouseLocalGroupPlans.aspx. Accessed July 2, 

2014.

Numeric Water Quality Standards. 2008. Circular DEQ-7, Montana DEQ. [Online] 

http://www.deq.mt.gov/wqinfo/. Last accessed 9/14/2009. 

NWCG Memo #024‐2010 April 30, 2010. www.nwcg.gov

Oenema, O., G.L. Velthof, S. Yamulki, and S.C. Jarvis. 1997. Nitrous oxide emissions from 

grazed grassland. Soil Use Manage. 13:288–295.

Omni, Philip N. 2008. Reflections on Fuel Treatment Effectiveness.

Passes, Melissa. Natural Resource Specialist. Billings Field Office, BLM, Billings, Montana, 

2008.

Patricelli, G.L., J.L. Blickley, and S. Hooper. 2010. Incorporating the impacts of noise 

pollution into greater sage‐grouse conservation planning. 27th Meeting of the Western 

References Ref-25
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Agencies Sage and Columbian Sharp‐tailed Grouse Technical Committee Workshop. 

Twin Falls, Idaho, USA.

Patterson, Robert L. 1952. The sage grouse in Wyoming. Federal Aid to Wildlife Restoration 

Project 28-R. Denver, CO: Sage Books, Inc.

Performance Requirements. 2006. The National Map LANDFIRE: LANDFIRE National 

Existing Vegetation Type layer. Last update: [Computer gis/database]. U.S. 

Department of Interior, Geological Survey, (Online). [Online] 

http://gisdata.usgs.net/website/landfire/. Accessed: February 8, 2007.

Perry, Eugene S. 1962. Montana in the Geologic Past. Montana Bureau of Mines and Geology, 

Bulletin 26.

Personal conversation with Van Charlton, Natural Resources Evaluation Section, and Montana 

Department of Revenue Section 3.6.2

Perry, Eugene S. 1962. Montana in the Geologic Past. Montana Bureau of Mines and Geology, 

Bulletin 26.

Petersen, B.E. 1980. Breeding and nesting ecology of female sage grouse in North Park, 

Colorado. Thesis. Colorado State University, Fort Collins, USA.

Petroleum Systems and Geologic Assessment of Oil and Gas in the Southwestern Wyoming 

Province, Wyoming, Colorado, and Utah. U.S.. 2005. Southwestern Wyoming Province 

Assessment Team. Geological Survey Digital Data Series DDS-69-D.

Prichard, Don (Work Group Leader). 1998. Riparian Area Management; A User Guide to 

Assessing Proper Functioning Condition and the Supporting Science for Lotic Areas. 

Technical Reference TR # BLM-RS-98-15-1737. USDI, BLM, National Applied 

Resource Sciences Center. Denver, CO.

Prichard, Don (Work Group Leader). 1999. Riparian Area Management; A User Guide to 

Assessing Proper Functioning Condition and the Supporting Science for Lentic Areas. 

Technical Reference TR # BLM-RS-98-16-1737. USDI, BLM, National Applied 

Resource Sciences Center. Denver, CO.

Porter, K.W., Wilde, E.M., Vuke, S.M. 1999. The preliminary geologic map of the Big Snowy 

Mountains 30' x 60' quadrangle, Montana, revised 1999, Montana Bureau of Mines and 

Geology: Open-File Report 341, 16 p., 1 sheet(s), 1:100,000. 

Porter, K.W., Wilde, E.M. 1999. Geologic map of the Musselshell 30' x 60' quadrangle, central 

Montana, Montana Bureau of Mines and Geology: Open-File Report 386, 13 p., 2 

sheet(s), 1:100,000.

Pyke, D.A. 2011. Restoring and rehabilitating sagebrush habitats. Pp. 531‐548 in S. T. Knick 

and J. W. Connelly (editors). Greater sage‐grouse: ecology and conservation of a 

Ref-26 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

landscape species and its habitats. Studies in Avian Biology 38. University of California 

Press. Berkeley, CA. 

Pyke, A. and B. Wylie. 2007. Interactions among livestock grazing, vegetation type, and fire 

behavior inthe Murphy Wildland Fire Complex in Idaho and Nevada, July 2007. U.S. 

Geological Survey Open‐File Report 2008–1214. (http://pubs.usgs.gov/ofr/2008/1214).

Putnam, C., and G. Kennedy. 2005. Montana Birds. Lone Pine Publishing, Edmonton, 

Alberta,Canada.

Rasker Ray, Alexander Ben, vand den Noort, Jeff, and Carter, Rebecca. 2004. Prosperity in the 

21st Century West; the Role of Protected Public Lands. Sonoran Institute. Tucson, 

Arizona.

Range Administration System, 2008 Section 3.6.6.

Rashford, B. S., A. M. Schrag, J. Walker. 2013. Targeting Grassland Conservation: An 

Estimate of Land-Use Conversion Risk in the Northern Great Plains. Internet website: 

www.plainsandprairiepotholeslcc.org/wpcontent/uploads/2013/12/FinalGrantTechnicalReport_small.pdf. Accessed on July 2, 

2014.

Reese, K.P., and R.T. Bowyer (editors). 2007. Monitoring populations of sage‐grouse. College 

of Natural Resources Experiment Station Bulletin 88. University of Idaho, Moscow, ID.

REIS, Regional Economic Information System (REIS). [Computer database]. Bureau of 

Economic Analysis, U.S. Department of Commerce.

Reisner, M. D., J. B. Grace, D. A. Pyke, P. S. Doescher. 2013 Conditions favouring Bromus 

tectorum dominance of endangered sagebrush steppe ecosystems. Journal of Applied 

Ecology 50, pp. 1039-1049.

Remington, T.E., and C.E. Braun. 1991. How surface coal mining affects sage grouse, North 

Park, Colorado. Proceedings, Issues and Technology in the Management of Impacted 

Western Wildlife. Thorne Ecological Institute 5:128‐132.

Reeves, F. 1931. Geology of the Big Snowy Mountain. United States Geological Survey, 

Professional Paper 165-D.

Reynolds, M.W., and Brandt, T.R. 2007. Preliminary geologic map of the White Sulphur 

Springs 30' x 60' quadrangle, Montana: U.S. Geological Survey Open-File Report 

2006-1329, scale 1:100,000.

Rhodes, E.C., J.D. Bates, R.N. Sharp, and K.W. Davies. 2010. Fire effects on cover and dietary 

resources of sage‐grouse habitat. Journal of Wildlife Management 74:755‐764. 

Richards, R.T., J.C. Chambers, and C. Ross. 1998. Use of native plants on federal lands: policy 

and practice. Journal of Range Management 51:625‐632. 

References Ref-27
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Robinson, A. C. 2014. Management Plan and Conservation Strategies for Greater Sage-Grouse 

in North Dakota. North Dakota Game and Fish Department, Bismarck, North Dakota.

Robinson, Aaron, Prairie Grouse Biologist, North Dakota Department of Game and Fish, 

discussion of the effects of Oil and Gas Development on Sharp-tailed Grouse, PhD, 

personal communication, 2013

Rocky Mountain Association of Geologists. 1972. Geologic Atlas of the Rocky Mountain 

Region, United States of America. Denver, CO. 

Rosenberger, Randall S. and Loomis John B. 2001. Benefit Transfer of Outdoor Recreation 

Use Values. Final report for USDA Forest Service, Joint Venture Agreement # -98132-

RJVA.

Rudzitis, Gundars and Rebecca Johnson. 2000. The Impact of Wilderness and Other Wildlands 

on Local Economic s and Regional Development Trends. USDA Forest Service 

Proceedings RMRS-P-15-Volume 2.

Ruedinger, B. et al. 2000. Canada Lynx Conservation Assessment and Strategy. USDA Forest 

Service, USDI Fish and Wildlife Service, USDA Bureau of Land Management.

Samson, Fred B., F. L. Knopf, W. R. Ostlie. 2004. Great Plains Ecosystems: Past, Present, and 

Future. Wildlife Society Bulletin, Vol. 32, No. 1. (Spring, 2004), pp. 6-15.

Sauder, J. D. 2002. Factors Influencing Avian Abundance and Diversity in Sagebrush Steppe, 

Juniper Woodland and Aspen Woodland Communities of Southeast Idaho. Unpubl. 

M.S. thesis, Idaho State University, Pocatello.

Sauer, J. R., J. E. Hines, and J. Fallon. 2008. The North American Breeding Bird Survey, 

Results and Analysis 1966-2008. Version 5.15.2008. U.S. Department of Interior, 

Geological Survey, Patuxent Wildlife Research Center, Laurel, Maryland. [Online] 

http://www.mbr-pwrc.usgs.gov/bbs.

Sauer, J.R., J.E. Hines, J.E. Fallon, K.L. Pardieck, D.J. Ziolkowski, Jr., and W.A. Link. 2012. 

The North American Breeding Bird Survey, Results and Analysis 1966-2011. Version 

12.13.2011. USGS Patuxent Wildlife Research Center, Laurel, MD. 

Saunders, E. J. 2001. Population Estimate and Habitat Associations of the Long-billed Curlew 

(Numenius americanus) in Alberta. Alberta Species at Risk Report No. 25. Edmonton, 

Alberta. [Online] 

http://mountainprairie.fws.gov/species/birds/longbilled_curlew/LONGBILLEDCURLE

WS -Alberta.pdf.

Schmidt K.M. et al. 2002 Section 3.3.9.

Schmidtmann, E.T., R.J. Bobian, R.P. Beldin. 2000. Soil chemistries define aquatic habitats 

with immature populations of the Culicoides variipennis complex (Diptera: 

Ceratopogonidae). Journal of Medical Entomology. 37: 38‐64.

Ref-28 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Schroeder, M.A. and R.K. Baydack. 2001. Predation and the management of prairie grouse. 

Wildlife Society Bulletin 29:24-32.

Schroeder, M.A., C.L. Aldridge, A.D. Apa, J.R. Bohne, C.E. Braun, S.D. Bunnell, J.W. 

Connelly, P.A. Deibert,S.C. Gardner, M.A. Hilliard, G.D. Kobriger, S.M. McAdam, 

C.W. McCarthy, J.J. McCarthy, D.L. Mitchell, E.V. Rickerson, and S.J. Stiver. 2004. 

Distribution of sage grouse in North America. Condor 106:363–76.

Sedinger, J.S. 2007. Improving understanding and assessment of greater sage‐grouse 

populations. Pp. 43‐56 in K.P. Reese and R.T. Bowyer (editors). Monitoring 

populations of sage‐grouse: proceedings of a symposium at Idaho State University. 

University of Idaho College of Natural Resources Station Bulletin 88. University of 

Idaho, Moscow, ID.

Seinfeld, J. H. 1986. Atmospheric Chemistry and Physics of Air Pollution. Wiley Interscience. 

New York.

Sheley, R.L. and J.K. Petroff. 1999. Biology and Management of Noxious Rangeland Weeds, p. 

1. Oregon State University Press, Corvallis, OR.

Sika, J. L. 2006. Breeding Ecology, Survival Rates, and Causes of Mortality of Hunted and 

Nonhunted Greater Sage-grouse in Central Montana. M.S.. Thesis, Montana State 

University, Bozeman.

Slater, S.J. 2003. Sage-grouse (Centrocercus urophasianus) use of different-aged burns and the 

effects of coyote control in southwestern Wyoming. M.S. thesis, University of 

Wyoming, Laramie. WY.

Sonoran Institute, 2003 Section 3.6.2

South Dakota Wildlife Division. 2014. Department of Game, Fish, and Parks, Sage Grouse 

Management Plan 2014-2018.

South, Phil. 1980 rev. Pryor Mountain Ecosystems. USDA Forest Service, Custer National 

Forest, Red Lodge, Montana

Spielman, Jay; Reasonable Foreseeable Development Scenario for the Billings/Pompeys Pillar 

Resource Management Plan, Billings Field Office, Montana/Dakotas Bureau of Land 

Management, February 2010, Unpublished BLM Report.

Stankey, G.H., R.N. Clark, and B.T. Bormann. 2005. Adaptive management of natural 

resources: theory, concepts, and management institutions. Gen. Tech. Rep. 

PNW‐GTR‐654. Portland, OR: U.S. Department of Agriculture, Forest Service, 

Northwest Research Station.

State of Montana. 2014. Executive Order 10-2014. Executive Order Creating the Montana Sage 

Grouse Oversight Team and the Montana Sage Grouse Habitat Conservation Program. 

Internet Website: 

References Ref-29
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

https://governor.mt.gov/Portals/16/docs/2014EOs/EO_10_2014_SageGrouse.pdf. 

Accessed on December 11, 2014.

State of Wyoming. 2011. Wyoming Executive Order 2011-5, June 2, 2011, Greater SageGrouse core area protection: Casper, Wyo., Governor’s Office, State of Wyoming.

Steenhof, K., M.N. Kochert, and J.A. Roppe. 1993. Nesting by raptors and common ravens on 

electrical transmission line towers. Journal of Wildlife Management 57:271‐281.

Steinberg, Peter D. 2002. Pseudotsuga menziesii var. glauca. In: Fire Effects Information 

System, [Online]. U.S. Department of Agriculture, Forest Service, Rocky Mountain 

Research Station, Fire Sciences Laboratory (Producer. [Online] 

http://www.fs.fed.us/database/feis/. Accessed October 10, 2008.

Stevens, B.S. 2011. Impacts of Fences on Greater Sage-Grouse in Idaho: Collision, Mitigation, 

and Spatial Ecology. Unpublished Thesis. University of Idaho, Moscow.

Stevens, B. S., K. P. Reese, and J. W. Connelly. 2011. Survival and Detectability Bias of Avian 

Fence Collision Surveys in Sagebrush Steppe. Journal of Wildlife Management 

75(2):437-449.

Stewart, G. D, Pullin, A.S., and Coles C.F. 2007. Poor Evidence-Base for Assessment of 

Windfarm Impacts on Birds. Environmental Conservation 34:11. 

Stiver, S.J., A.D. Apa, J.R. Bohne, S.D. Bunnell, P.A. Deibert, S.C. Gardner, M.A. Hilliard, 

C.W. McCarthy, and M.A. Schroeder. 2006. Greater Sage-grouse Comprehensive 

Conservation Strategy. Western Association of Fish and Wildlife Agencies. 

Unpublished Report. Cheyenne, Wyoming.

Stiver, S.J., E.T. Rinkes, and D.E. Naugle. 2010. Sage‐Grouse Habitat Assessment Framework. 

Bureau of Land Management Unpublished Report. U.S. Department of Interior, Bureau 

of Land Management, Idaho State Office, Boise, ID.

Strand E. K. and K. L. Launchbaugh 2013. Livestock Grazing Effects on Fuel Loads for 

Wildland Fire in Sagebrush Dominated Ecosystems. Great Basin Fire Science Delivery 

Report, April 2013.

Strawberry Valley Adaptive Resource Management Local Working Group (SVARM). 2006. 

Strawberry Valley Greater Sage-grouse (Centrocercus urophasianus) Local 

Conservation Plan. Utah State University Extension and Jack H. Berryman Institute and 

Utah Division of Wildlife Resources. Salt Lake City, Utah. Unpublished report.

Streamside Management Zone Law. 1991. Montana Department of Natural Resources and 

Conservation (DNRC), Montana.

Stynes, Daniel J., and White, Eric, M. 2005. Spending Profiles of National Forest Visitors, 

NVUM Four Year Report. Morgan State University. East landing, Michigan. Performed 

under Joint Venture Agreement # 01-JV-11130149-203, USDA.

Ref-30 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Stynes, Daniel J. and Eric M. White. 2005. Spending Profiles of National Forest Visitors, 

NVUM Four Year Report. Michigan State University, East Lansing, MI.

Stynes, Daniel J. and Eric M. White. Spending Profiles for National Forest Recreation Visitors 

by Activity, February 2006.

Swenson, J.E., C.A. Simmons, and C.D. Eustace. 1987. Decrease of sage grouse Centrocercus 

urophasianus after ploughing of sagebrush steppe. Biological Conservation 41:125–32.

Tack, J.D. 2009. Sage‐grouse and the human footprint: implications for conservation of small 

and declining populations. Thesis. University of Montana, Missoula, Montana, USA.

Taylor, David. 2010. University of Wyoming, personal conversation.

Taylor, Jennifer L. 2001. Populus deltoides. Fire Effects Information System, [Online]. U.S. 

Department of Agriculture, Forest Service, Rocky Mountain Research Station, Fire 

Sciences Laboratory (Producer). [Online] http://www.fs.fed.us/database/feis/. Accessed 

October 10, 2008.

Taylor, R.L., B.L. Walker, D.E. Naugle. 2012. Managing multiple vital rates to maximize 

greater sage-grouse population growth. Journal of Wildlife Management 76:336 – 347. 

Taylor, R. L., D. E. Naugle, and L. S. Mills. 2012. Viability Analyses for Conservation of 

Sage-Grouse Populations: Buffalo Field Office, Wyoming. Final Report. University of 

Montana, Missoula. February 27, 2012.

Thompson, T.R. 2006. Dispersal ecology of greater sage‐grouse in northwestern Colorado: 

evidence from genetic and demographic data: 2006 Annual Progress Report. Colorado 

Division of Wildlife, Grand Junction, Colorado, USA.

Thompson, T.R., K.P. Reese, and A.D. Apa. 2005. Dispersal ecology of greater sage‐grouse in 

northwestern Colorado: Annual Report 2005. Colorado Division of Wildlife, Grand 

Junction, Colorado, USA. Thurow, T.L., and C.A. Taylor, Jr. 1999. Viewpoint: the role 

of drought in range management. Journal of Range Management 52:413‐419.

Tigner, Joel. 2007. Bat Hibernacula Surveys Gated Mines Pryor Mountains. Carbon County, 

MT.

Toevs, G.R., J.J. Taylor, C.S. Spurrier, W.C. MacKinnon, and M.R. Bobo. 2011. Assessment, 

Inventory, and Monitoring Strategy: For integrated renewable resource management. 

U.S. Department of Interior, Bureau of Land Management, National Operations Center, 

Denver, CO.

Tonneson, John J., Editor. 1985. Montana Oil and Gas Fields Symposium. Montana Geological 

Society, Billings, MT, 1217 pp.

Trombulak, S.C., and C.A. Frissell. 2000. Review of ecological effects of roads on terrestrial 

and aquatic communities. Conservation Biology 14:18‐30.

References Ref-31
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Turner, M.G. 2005. Landscape ecology in North America: Past, present, and future. Ecology 

86:1967‐1974.

Turner, M.G., and R.H. Gardner (editors). 1991. Quantitative methods in landscape ecology. 

Springer‐Verlag, New York, NY.

Uchytil, Ronald J. 1991. Abies lasiocarpa. In: Fire Effects Information System, [Online]. U.S. 

Department of Agriculture, Forest Service, Rocky Mountain Research Station, Fire 

Sciences Laboratory ,Producer. [Online] http://www.fs.fed.us/database/feis / Accessed 

October 10, 2008.

U.S. 2002. Healthy Forests: An Initiative for Wildfire Protection and Stronger Communities. 

[Online] 

http://www.fs.fed.us/projects/documents/HealthyForests_Pres_Policy%20A6_v2.pdf . 

Last accessed: September 14, 2009. 

U.S. 2003. Healthy Forest Restoration Act of 2003. (HFRA) [Online] 

http://www.fs.fed.us/biology/wildecology/HFRA.pdf. Last accessed 9/14/2009.

U.S. Advisory Council on Historic Preservation. [Online] http://www.achp.gov/nhpa.html.

U.S. Army Corps of Engineers (USACE). 1987. Wetlands Delineation Manual. 

http://www.wetlands.com/regs/tlpge02e.htm.

U.S. Census, 2014. U.S. Census, Poverty: Description of Income and Poverty Data Sources. 

http://www.census.gov/hhes/www/poverty/about/datasources/description.html

U.S. Census Bureau, 2008. State and County Quick Facts. 

http://quickfacts.census.gov/qfd/index.html.

U.S. Census Bureau, Population Division, 2014. Annual Estimates of the Resident Population 

by Sex, Race, and Hispanic Origin for the United States, States, and Counties: April 1, 

2010 to July 1, 2013. Release date June 2014.

U.S. Census Bureau, Small Area Income and Poverty Estimates (SAIPE) Program, 2014. 2013 

Poverty and Median Household Income Estimates-Counties, States, and National. 

Release date December 2014.

U.S. Code of Federal Regulations, Title 36: Parks, Forests, and Public Property, Part 222-

Range management. August 23, 2010.

U.S. Code of Federal Regulations, Title 43: Grazing Administration, Part 4110- Qualifications 

and Preference.

U.S. Congressional Budget Office. 2003. The Economics of Climate Change: A Primer, 

Congressional Budget Office.

Ref-32 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

U.S. Department of Agriculture, Forest Service, Southwest Oregon FHP Service Center. Bark 

Beetles and Wood Borers. [Online] http://www.fs.fed.us/r6/nr/fid/widweb/wid-bb.shtml

U.S. Department of Agriculture, Forest Service. 1987. Custer National Forest and Grassland 

Plan for Management.

U.S. Department of Agriculture, Forest Service and U.S. Department of the Interior, BLM 2004 

Section 3.3.7

U.S. Department of Agriculture. Natural Resources Conservation Service. 2006. Land 

Resource Regions and Major Land Resource Areas of the United States. Agriculture 

Handbook 296. U.S. Government Printing Office, Washington, DC.

U.S. Department of Agriculture, Forest Service. 2007. Bark Beetles and Wood Borers. USDA 

FS, SW Oregon FHP Service Center; [Online] 

http://www.fs.fed.us/r6/nr/fid/widweb/wid-bb.shtml. 

U.S. Department of Agriculture, National Agricultural Statistics Service. 2008 Section 3.6.2

U.S. Department of Agriculture .2009. PLANTS database. http://plants.usda.gov/. Website 

updated November 30, 2009. Website accessed on December 7, 2009. 

U.S. Department of Agriculture, National Agricultural Statistics Service (NASS), 2007 Census 

of Agriculture- County Data, Montana, Tables 11, 16, 2007.

U.S. Department of Agriculture, NASS, 2007 Census of Agriculture- County Profiles, 

Montana, 2007.

U.S. Department of Agriculture, NASS, Meat Animals Production, Disposition, and Income 

2009 Summary, April 2010.

U.S. Department of Agriculture, NASS, Montana: Annual Statistical Bulletin, Grazing Fees for 

Cattle, 2010 BLM, Annual Report, 2008.

U.S. Department of Agriculture, U.S.Department of the Interior, and U.S. Environmental 

Protection Agency. 2011. Memorandum of Understanding among the U.S. Department 

of Agriculture, U.S. Department of the Interior, and U.S. Environmental Protection 

Agency, Regarding Air Quality Analysis and Mitigation for Federal Oil and Gas 

Decisions through the National Environmental Policy Act Process. June 23.

U.S. Department of Energy. 2008. US-Wind Resources Map. U.S. Department of Energy 

National Renewable Energy Laboartory, Golden, Colorado. [Online] 

Http://www.windpoweringamerica.gov/wind_maps.asp Last accessed: 9/21/2009.

U.S. Department of Energy. U.S. Energy Information Administration’s (EIA), Frequently asked 

questions. Available online: 

http://www.eia.doe.gov/ask/environment_faqs.asp#CO2_weight. Last accessed 

12/20/2010.

References Ref-33
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

U.S. Department of Energy, 2008. US-Wind Resources Map. U.S. Department of Energy 

National Renewable Energy Laboartory, Golden, Colorado. [Online] 

Http://www.windpoweringamerica.gov/wind_maps.asp . Last accessed September 21, 

2009.

U.S. Department of Energy, National Renewable Energy Laboratory: Energy Analysis- Jobs 

and Economic Development Impact (JEDI) Model, March 2011.

U.S. Department of the Interior. 2010. Endangered and threatened wildlife and plants; 12-

month findings for petitions to list the greater sage-grouse (Centrocercus urophasianus)

as threatened or endangered. Federal Register 73:23173-23175. 

U.S. Department of the Interior, BLM. AFMSS: BLM-Automated Fluid Mineral Support 

System 

U.S. Department of the Interior, BLM and U.S. Forest Service, 1974. Pryor Mountain 

Complex Land Use Decisions.

U.S. Department of the Interior, BLM. September 1984. Resource Management Plan, Final 

EIS, and Record of Decision. United States Department of the Interior, Bureau of Land 

Management. Billings Resource Area. Billings. MT.

U.S. Department of the Interior, BLM. 1991. Riparian-Wetland Initiative for the 1990’s. 

BLM/WO/GI-91/001+4340.

U.S. Department of the Interior, BLM. 1992b - BLM Fish and Wildlife 2000 Raptor Habitat

Management Plan – Section 3.3.6 Fish & Wildlife.

U.S. Department of the Interior, BLM. 1992. Miles City District Oil and Gas RMP/EIS 

Amendment. Montana State Office, Billings, Montana. Available at 

http://www.blm.gov/mt/st/en/fo/miles_city_field_office.html. Accessed December 11, 

2009.

U.S. Department of the Interior, BLM. March 1999. ACEC Amendment. March, 1999. 

http://www.blm.gov/pgdata/etc/medialib/blm/mt/blm_programs/planning/billings_rmp/

amendments.Par.94803.File.dat/acecDR.pdf

U.S. Department of the Interior. BLM. 1994. Miles City District Oil and Gas RMP/EIS 

Amendment and Record of Decision. Montana State Office. Billings, MT. February.

U.S. Department of the Interior. BLM. 1995. Federal Wildland Fire Management Policy. 

National Wildfire Coordinating Group, [Online] 

http://www.nwcg.gov/branches/ppm/fpc/archives/fire_policy/index.htm . Last accessed 

9/15/2009.

U.S. Department of the Interior. BLM. 1996. Pompeys Pillar EA/Amendment for the Billings 

RMP. United States Department of the Interior, Bureau of Land Management. Billings 

Resource Area. Billings. MT.

Ref-34 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

U.S. Department of the Interior. BLM. 1997a. Standards for Rangeland Health and Guidelines 

for Livestock Grazing Management for Montana, North Dakota, and South Dakota, 

Record of Decision. Montana State Office, Billings, Montana. 

U. S. Department of the Interior. BLM. 1997b. Implementation of Requirements for Noxious 

Weed Seed-Free Forage on Public Lands in the Bureau of Land Management, Montana 

and the Dakotas. EA/DR/FONSI MT-001-EA97 Federal Register Notice. Vol. 62, No. 

200. Page number 54123 and 54124. Friday, October 17, 1997. Effective November 17, 

1997.

U.S. Department of the Interior. BLM. 1997c. Montana/Dakotas Standards for Rangeland and 

Guidelines for Livestock Grazing (S&G). Bureau of Land Management, Montana State 

Office. Billings, MT. [Online] 

http://www.blm.gov/pgdata/etc/medialib/blm/mt/blm_programs/grazing.Par.83445.File.

dat/MCSG.pdf. 

U.S. Department of the Interior. BLM. 1997d. White River Resource Area, Resource 

Management Plan/EIS. Colorado. [Online] 

http://www.co.blm.gov/nepa/rmpdocs/wrfodocs/wrformp/.

U.S. Department of the Interior. BLM 1999. Areas of Critical Environmental Concern Decision 

Record and Approved Amendment of the Billings, Powder River, and South Dakota 

Resource Management Plans. 

http://www.blm.gov/pgdata/etc/medialib/blm/mt/blm_programs/planning/billings_rmp/

amendments.Par.94803.File.dat/acecDR.pdf. March 1999. 

U.S. Department of the Interior. BLM. 1999. Off-Highway Vehicle Environmental Impact 

Statement and Proposed Plan Amendment for Montana, North Dakota and South 

Dakota. OHV EIS. Bureau of Land Management (BLM) and the Forest Service (FS). 

U.S. Department of the Interior, BLM. 2000. National Fire Plan. National Interagency Fire 

Center, Boise, Idaho. [Online] http://www.nifc.gov/.

U.S. Department of the Interior, BLM. 2001a. Establishment of the Pompeys Pillar National 

Monument – A Proclamation by the President of the United States of America. January 

17, 2001.

U.S. Department of the Interior, BLM. 2001b. Federal Wildland Fire Management Policy, 

Revised and updated. National Wildfire Coordinating Group, [Online] 

http://www.nwcg.gov/branches/ppm/fpc/archives/fire_policy/index.htm . Last accessed 

9/15/2009.

U.S. Department of the Interior, BLM et. al. 2001c. USDI, Bureau of Land Management 

(BLM)/USDA Forest Service. 2001. Off-Highway Vehicle Environmental Impact 

Statement and Proposed Plan Amendment for Montana, North Dakota and Portions of 

South Dakota. January. BLM Montana State Office, Billings, Montana, [Online}, 

http://www.blm.gov/mt/st/en/fo/billings_field_office/rmp/docs.html

References Ref-35
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

U.S. Department of the Interior, BLM. 2003a. Fire/Fuels Management Plan EA/Plan 

Amendment for Montana and the Dakotas. BLM, Montana State Office. Billings, MT. 

July, 2003.

U.S. Department of the Interior, BLM. 2002. Four Dances Natural Area and Sundance Lodge 

Recreation Area EA/Amendment (DR) EA MT-010-0-39. Billings Resource Area, 

Billings, Montana. 

U.S. Department of the Interior, BLM. 2003. Off-Highway Vehicle EIS and Proposed Plan 

Amendment for Montana, North Dakota, and South Dakota. ROD June, 2003.

U.S. Department of the Interior, BLM. 2003a. Statewide O&G EIS and Proposed Amendment 

of the Powder River, ROD and Billings Resource Management Plans, Final. United 

States Department of the Interior, Bureau of Land Management. Montana State Office. 

Billings. Montana.

U.S. Department of the Interior. BLM et. al. 2003b. Assessing the Potential for Renewable 

Energy on Public Lands. [Online] http://www.nrel.gov/docs/fy03osti/33530.pdf.

U.S. Department of the Interior, BLM. 2003g. Section 3.3.7 Special Status Species

U.S. Department of the Interior. BLM. 2004. Billings Field Office Fire Management Plan 

2004. United States Department of the Interior, Bureau of Land Management. Billings 

Field Office. Billings. MT.

U.S. Department of Interior, Bureau of Land Management. 2004. National Sage‐Grouse Habitat 

Conservation Strategy. WO IM-2005‐024. Washington D.C. Online:

U.S. Department of the Interior, BLM. 2005. Final Programmatic Environmental Impact 

Statement on Wind Energy Development on BLM-Administered Lands in the Western 

United States. [Online] 

http://gc.energy.gov/NEPA/nepa_documents/otheragency/fes0511/index.html

U.S. Department of the Interior, BLM. 2005b. Section 3.4.8 – Renewable Energy - To facilitate

renewable energy production and development of renewable sources, the BLM works 

cooperatively with the DOE, USDA, EPA, Council on Environment Quality (CEQ), and 

members of the Western Governors’ Association.

U.S. Department of the Interior, BLM. 2006. Draft Supplement to the Montana Statewide Oil 

and Gas Environmental Impact Statement and Proposed Amendment of the Powder 

River and Billings Resource Management Plans, December 2006.

U.S. Department of the Interior, BLM. 2007a. Billings Field Office and Pompey’s Pillar 

National Monument Resource Management Plans and Environmental Impact Statement 

Preparation Plan. Prepared by the Billings Field Office, Billings, Montana. August 15, 

2007.

Ref-36 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

U.S. Department of the Interior, BLM. 2007. Vegetation Treatments Using Herbicides on BLM 

in 17 Western States. Programmatic EIS, Final. ROD: September 29, 2007.

U.S. Department of the Interior, BLM. 2008. Geothermal Programmatic EIS, Final. ROD: 

December 2008. USDI, Bureau of Land Management.

U.S. Department of the Interior, BLM. RMIS, 2008 – Section 3.6.2 – Economic Conditions

U.S. Department of the Interior, BLM. 2008. Manual 8380, Cave and Karst Resources 

Management. Rel. 8-80. [Online] 

http://www.blm.gov/style/medialib/blm/wo/Information_Resources_Management/polic

y/blm_manual.Par.51379.file./dat/MS-8380.pdf.

U.S. Department of the Interior, BLM. 2008. Supplement to the Montana Statewide Oil and 

Gas Environmental Impact Statement on Proposed Amendment of the Powder River and 

Billings Resource Management Plans, Final. Montana State Office. Billings, MT. 

Approved October 10, 2008 and ROD in December 2008. [Online] 

http://www.blm.gov/mt/st/en/fo/miles_city_field_office/seis/fseis.html. Last accessed 

December 15, 2010.

U.S. Department of the Interior, BLM. 2014. Billings and Pompeys Pillar National Monument 

Resource Management Plan (RMP) and Environmental Impact Statement (EIS): Air 

Resource Technical Support Document (ARTSD) for Emission Inventories and NearField Modeling.

U.S. Department of the Interior, BLM. Financial Management Information System. 2008 –

Section 3.6.2 – Economic Conditions

U.S. Department of the Interior, BLM. 2008. Manual 6840 - Special Status Species 

Management. December 12, 2008. BLM. Special Status Species Policy. Manual 6840. 

U.S. Department of the Interior, BLM. 2008a. Final Programmatic Environmental Impact 

Statement for Geothermal Leasing in the United States, Volume I: Programmatic 

Analysis; October 2008. 

http://www.blm.gov/wo/st/en/prog/energy/geothermal/geothermal_nationwide/Docume

nts/Final_PEIS.html. Site accessed December 11, 2009.

U.S. Department of the Interior, BLM. 2008b. Inventory of Onshore Federal Oil and Natural 

Gas Resources and Restrictions to Their Development Phase III Inventory – Onshore 

United States in Compliance with the Energy Act of 2000, P.L. 106-469 §604, As 

Amended by the Energy Policy Act of 2005, P.L. 109-58 §364. Prepared by the U.S. 

Departments of the Interior, Agriculture, and Energy. Available at 

http://www.blm.gov/wo/st/en/prog/energy/oil_and_gas/EPCA_III.html. Site accessed 

December 11, 2009.

U.S. Department of the Interior, BLM. 2009. Air Resource Management Program (ARMP), 

BLM Manual Rel. 7-109. January 16, 2009.

References Ref-37
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

U.S. Department of the Interior, BLM. 2009. Pryor Mountain Wild Horse Range 2009 Gather 

Plan and Environmental Assessment. United States Department of the Interior, Bureau 

of Land Management. Prepared by the Billings Field Office, Billings, Montana.

U.S. Department of the Interior (DOI),. 2010. Addressing the Impacts of Climate Change on 

America’s Water, Land, and Other Natural and Cultural Resources. Secretarial Order 

3289. February 2, 2010.

U.S. Department of the Interior, BLM. 2010a. Climate Change Supplementary Information 

Report: Montana, North Dakota, and South Dakota Bureau of Land Management.

Prepared by URS Corporation, October. 

http://www.blm.gov/pgdata/etc/medialib/blm/mt/blm_programs/energy/oil_and_gas/lea

sing/eas.Par.26526.File.dat/SIRupdate.pdf

U.S. Department of the Interior, BLM. Cave Management. Handbook H-1601-1. BLM 

Planning Handbook – Appendix C, I, J.

U.S. Department of the Interior, BLM. Code of Federal Regulations, Part 37, CFR Title 43.

U.S. Department of the Interior, BLM. 2009. Guidance for Implementation of Federal 

Wildland Fire Management Policy. [Online] 

www.nifc.gov/policies/guidance/GIFWFMP.pdf

U.S. Department of the Interior, BLM. 2009. National Integrated Land System. [Computer gis 

database] National Integrated Land System NILS, Partnership with USDI Bureau of 

Land Management and the USDA Forest Service. [Online] 

http://www.geocommunicator.gov/GeoComm/index.shtm

U.S. Department of the Interior, BLM. 2009. Bull Mountain Mine No. 1 Federal Coal Lease 

MTM-97988 Musselshell County, Montana. DOI-BLM-MT-C010-2009-0010-EA.

U.S. Department of the Interior, BLM. Special Status Species Policy. Manual 6840. United 

States department of the Interior, BLM.

U.S. Department of the Interior, BLM. 2009. EPCA. Phase III Inventory. Inventory of Onshore 

Federal Oil and Gas Resources and Restrictions to Their Development. 2009. UDSI, 

Bureau of Land Management [Online] 

http://www.blm.gov/wo/st/en/prog/energy/oil_and_gas/EPCA_III.html.

U.S. Department of the Interior, BLM. 2010. Public Land Statistics. 

http://www.blm.gov/public_land_statistics/pls10/pls10_combined.pdf

U.S. Department of the Interior, BLM, 2010. Reasonable Foreseeable Development Scenario

for the Billings/Pompeys Pillar Resource Management Plan Billings Field Office, 

Montana/Dakotas Bureau of Land Management, February 2010.

Ref-38 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

U.S. Department of the Interior, BLM. 2010. Review of Oil and Gas Lease Sale Parcels in the 

Billings Field Office Planning Area Environmental Assessment DOI-BLM-MT-C010-

2010-0046-EA. August 12, 2010. Page 61, 62.

U.S. Department of the Interior, BLM. Annual Report, 2008.

U.S. Department of the Interior, BLM. 2010. LR2000-Land and Mineral Legacy Rehost 2000 

System, 2010.

U.S. Department of the Interior, BLM. 2010. Rangeland Administration System.

U.S. Department of the Interior, BLM. 2010. Recreation Information Management System.

U.S. Department of the Interior, BLM. 2005. Wind Energy Development on BLMAdministered Lands in the Western United States Environmental Impact Statement, 

June 2005.

U.S. Department of the Interior. Payments in Lieu of Taxes (PILT) County Payments and 

Acres, Montana, Fiscal Year 2010, 2010.

U.S. Department of the Interior, BLM. Financial Business Management System (FBMS), 2010.

U.S. Department of the Interior, BLM. Instruction Memorandum No. 2010-067.

U.S. Department of the Interior, BLM. Legacy Rehost 2000 (LR2000), Acres Leased in 

Montana.

U.S. Department of the Interior, BLM. Legacy Rehost 2000 (LR2000), Revenues received on 

rights-of-way in Montana.

U.S. Department of the Interior, BLM. Manual 1373- Distribution of Receipts, 1980.

U.S. Department of the Interior, BLM. Montana/Dakotas Table of Organization.

U.S. Department of the Interior, BLM. Public Land Statistics.

U.S. Department of the Interior, BLM. Rangeland Administration System (RAS), 2010.

U.S. Department of the Interior, BLM. Recreation Management Information System, 2010.

U.S. Department of the Interior, Office of Natural Resource Revenue (ONRR), State Statistics, 

Montana, FY2005-2010, Accounting Year.

U.S. Department of the Interior. FWS, 1984. American Peregrine Falcon Rocky Mountain 

PopulationRecovery Plan. U.S. Fish and Wildlife Service, Denver, CO. 

U.S. Department of the Interior, FWS 1993. U.S. Fish and Wildlife Service. 1993. Grizzly Bear 

Recovery Plan. Missoula, MT 181 pp.

References Ref-39
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

U.S. Department of the Interior, FWS. 2000. Black-footed ferret; Mustela nigripes. U.S. Fish 

and Wildlife Service. [Online] http://www.fws.gov. 

U.S. Department of the Interior, FWS. 2000. Black-footed ferret; Mustela nigripes. U.S. Fish 

and Wildlife Service. [Online} http://www.fws.gov.

U.S. Department of the Interior, FWS. 2002. Birds of Conservation Concern. U.S. Fish and 

Wildlife Service Division of Migratory Bird Management, Arlington, Virginia. 99 pp. 

[Online] http://migratorybirds.USFWS.gov/reports/bcc2002.pdf. 

U.S. Department of the Interior, FWS. 2002. Birds of Conservation Concern. U.S. Fish and 

Wildlife Service Division of Migratory Bird Management, Arlington, Virginia. 99 pp. 

[Online] http://migratorybirds.USFWS.gov/reports/bcc2002.pdf.

U.S. Department of the Interior, FWS. 2002. Utah Field Office Guidelines for Raptor 

Protection from Human and Land Use Disturbances, Salt Lake City, January 2002 

update, Prepared by Laura A. Romin and James A. Muck.

U.S. Department of the Interior, FWS. 2004a. Finding for the Resubmitted Petition to List the 

Black-tailed Prairie Dog as Threatened. Federal Register /Vol. 69, No. 159 

/Wednesday, August 18, 2004 / Proposed Rules, p. 51217.

U.S. Department of the Interior, FWS. 2005. Endangered and Threatened Wildlife and Plants: 

12-Month Findings for Petitions to list the Greater Sage-Grouse as Threatened or 

Endangered; Proposed Rule. CFR Part 17 Federal Register, January 12, 2005.

U.S. Department of the Interior, FWS. 2005. Avian Protection Plan (APP) Guidelines, A Joint 

Document Prepared by The Edison Electric Institute’s Avian Power Line Interaction 

Committee (APLIC) and U.S. Fish and Wildlife Service (USFWS) April 2005.

U.S. Department of the Interior, FWS. 2005. Endangered and Threatened Wildlife and Plants: 

12-Month Findings for Petitions to list the Greater Sage-Grouse as Threatened or 

Endangered; Proposed Rule. CFR Part 17 Federal Register, January 12, 2005.

U.S. Department of the Interior, FWS. 2006. International Recovery Plan; Whooping Crane 

(Grus Americana), 3rd ed. U.S. Fish and Wildlife Service.

U.S. Department of the Interior, FWS. 2006. International Recovery Plan; Whooping Crane 

(Grus Americana), 3rd ed. U.S. Fish and Wildlife Service.

U.S. Department of the Interior, FWS. 2006b

U.S. Department of the Interior, FWS, May, 2007, National Bald Eagle Management 

Guidelines, U.S. Fish and Wildlife Service.

U.S. Department of the Interior, FWS, 2007. Removing the Bald Eagle in the Lower 48 States 

From the List of Endangered and Threatened Wildlife, Federal Register / Vol. 72, No. 

130 / Monday, July 9, 2007 / Rules and Regulations.

Ref-40 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

U.S. Department of the Interior, FWS. 2007

U.S. Department of the Interior, FWS. 2013. Greater Sage-grouse (Centrocercus urophasianus) 

Conservation Objectives: Final Report. U.S. Fish and Wildlife Service, Denver, CO. 

February, 2013.

U.S. Department of the Interior, USGS. 1995a. 1995 Oil and Gas Assessment. Energy 

Resources Program. United States Geological Survey. [Online]

http://energy.cr.usgs.gov/oilgas/noga/1995.html. 

U.S. Department of the Interior, USGS. 1995b. Overview of the 1995 National Assessment of 

Potential Additions to Technically Recoverable Resources of Oil and Gas-Onshore and 

State Waters of the United States. United States Geological Survey, United States 

Geological Survey Circular 1118.

U.S. Department of the Interior, USGS. 2002. Assessment of Undiscovered Oil and Gas 

Resources of the Powder River Basin Province of Wyoming and Montana. United States 

Geological Survey, USGS Fact Sheet FS-146-02.

U.S. Department of the Interior, USGS. 2004. Northwest Regional Gap Analysis Project (NW

ReGAP) mapping. http://gap.uidaho.edu/index.php/gap-home/Northwest-GAP. 

U.S. Department of the Interior, USGS. 2005. Assessment of Undiscovered Oil and Gas 

Resources of the Southwestern Wyoming Province of Wyoming, Colorado, and Utah, 

2002. USGS Digital Data Series DD-69-D. 

U.S. Department of the Interior, USGS. 2006. Update. Assessment of Undiscovered Oil and 

Gas Resources of the Powder River Basin Province of Wyoming and Montana. United 

States Geological Survey, USGS Fact Sheet 2006-3135, 2 pp.. 

U.S. Department of the Interior, USGS. 2008. Assessment of Undiscovered Biogenic Gas 

Resources, North-central Montana Province. United States Geological Survey, USGS 

Fact Sheet 2008–3036, 2 pp.

U.S. Department of the Interior, USGS. 2008. National Oil and Gas Assessment. United States 

Geological Survey, Energy Resources Program. [Online] 

http://energy.cr.usgs.gov/oilgas/noga/. 

U.S. Department of the Interior, USGS. 2008. GIS Data Finder. [Computer database vers 

1.1.2]. Energy Resources Program, [Online]

http://certmapper.cr.usgs.gov/erp_datafinder_v1.1/explorer.jsp?goTo=search&keyword

=1995&&type=001. 

U.S. Department of the Interior, USGS Fact Sheet 2008-3050, 2008 Section 3.4.1

U.S. Geological Survey (USGS). 2010. Climate Change in Mountain Ecosystems. Accessed on 

July 27, 2010. www.nrmsc.usgs.gov/research/global.htm

References Ref-41
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

U.S. Energy Information Administration. 2011. [Online] 

http://www.eia.doe.gov/cneaf/coal/page/acr/table28.html. 

U.S. Environmental Protection Agency. 1997. Planning and Evaluation. United States 

Environmental Protection Agency, Office of Policy. (2111) EPA 230-F-97-008z. 

[Online] http://www.epa.gov/. 

U.S. Environmental Protection Agency. 1997. Planning and Evaluation United States 

Environmental Protection Agency Office of Policy, (2111) EPA 230-F-97-008z, 

September 1997EPA. [Online] 

http://www.epa.gov/Region8/climatechange/pdf/ClimateChange101FINAL.pdf).

U.S. Environmental Protection Agency. 2007. National Emission Inventory (NEI)). United 

States Environmental Protection Agency (EPA) [Online] 

http://www.epa.gov/air/airtrends/2007/report/particlepollution.pdf. 

http://www.epa.gov/cgi_bin/broker?_service=airdata&_program=progs.webprogs.pltmo

n.scl&_debug=2&geotype=st&geocode=MT&geoname=Montana&epol=CO+NOX+S

O2+PM25+PM10&epolmin=&epolmax=&netyr=2002&sic=&mpols=CO+NO2+SO2+

PM2.5+PM10&mtyps=&myrs=2008+2007+2006+2005+2004+2003+2002&mexc=&e

xc=&mrad=&geofeat=J&mapsize=zsc&reqtype=viewmap. 

U.S. Environmental Protection Agency. 2005a – Section 3.3.4 Water Resources 

U.S. Environmental Protection Agency. 1997. Climate Change and Montana. 

U.S. Environmental Protection Agency. 1997. Office of Policy, Planning and Evaluation (2111) 

EPA 230-F-97-008z, September 1997. 

U.S. Environmental Protection Agency. 2008. [Online] 

http://www.epa.gov/climatechange/science/stateofknowledge.html Accessed on 

November 16, 2008. 

U.S. Environmental Protection Agency. 2008. Accessed on November 16, 2008. [Online] 

http://www.epa.gov/climatechange/science/stateofknowledge.html 

U.S. Environmental Protection Agency. 2010a. Design Values (1-Hour) by County for Sulfur 

Dioxide [Website]. Accessed on July 30, 2010. [Online] 

http://www.epa.gov/air/sulfurdioxide/pdfs/20100602table0709.pdf

U.S. Environmental Protection Agency. 2010b. Green Book, Designations [Website]. Accessed 

on July 30, 2010. [Online] http://www.epa.gov/oar/oaqps/greenbk/define.html 

U.S. Environmental Protection Agency. 2010c. List of 156 Mandatory Class I Federal Areas. 

Accessed on July 30, 2010. [Online] http://www.epa.gov/visibility/class1.html. 

U.S. Environmental Protection Agency. 2010d. An Introduction to Indoor Air Quality, Volatile 

Organic Compounds (VOCs) [Website]. Accessed on July 30, 2010. [Online] 

http://www.epa.gov/iaq/voc.html 

Ref-42 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

U.S. Environmental Protection Agency. 2010e. Climate Change Indicators in the United States. 

EPA 430-R-10-007. April. [Online] 

http://www.epa.gov/climatechange/indicators/pdfs/ClimateIndicators_full.pdf

U.S. Environmental Protection Agency. 2011a. Report on the Environment: Atmospheric 

Concentrations of Greenhouse Gases. [Website]. Accessed on July 15, 2011. [Online] 

http://cfpub.epa.gov/eroe/index.cfm?fuseaction=detail.viewInd&lv=list.listbyalpha&r=2

31323&subtop=342

U.S. Environmental Protection Agency. 2011b. Inventory of U.S. Greenhouse Gas Emissions 

and Sinks: 1990-2009. April 15, 2011 (EPA 430-R-11-005). [Online] 

http://epa.gov/climatechange/emissions/downloads11/US-GHG-Inventory-2011-

Complete_Report.pdf

U.S. Environmental Protection Agency. 2011c. Ground-level Ozone Regulatory Actions 

[Website]. Accessed August 25, 2011.

[Online] http://www.epa.gov/glo/pdfs/20100104maps.pdf

U.S. Environmental Protection Agency. 2011f. [Online] AP 42, Fifth Edition. Compilation of 

Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources. 

http://www.epa.gov/ttnchie1/ap42

U.S. Environmental Protection Agency. 2013a. Inventory of U.S. Greenhouse Gas Emissions 

and Sinks: 1990-2011. Environmental Protection Agency. USEPA 430-R-13-001. 

http://www.epa.gov/climatechange/Downloads/ghgemissions/US-GHG-Inventory2013-Main-Text.pdf. April 2013. 

U.S. Environmental Protection Agency. 2013b. FLIGHT website. U.S. Environmental 

Protection Agency. Accessed December 6, 2013. Available at: 

http://ghgdata.epa.gov/ghgp/main.do,

U.S. Environmental Protection Agency. 2013c. Air Quality Index Data Report [Online]. 

Accessed on December 5, 2013.http://www.epa.gov/airquality/airdata/ad_rep_aqi.html.

U.S. Environmental Protection Agency. 20113d. [Online] National Emission Inventory 

Database website (year 2011 emissions, version 1). December 245, 20131. 

http://neibrowser.epa.gov

USFWS (United States Fish and Wildlife Service). 2010. Endangered and Threatened Wildlife 

and Plants; 12-Month Findings for Petitions to List the Greater Sage-Grouse 

(Centrocercus urophasianus) as Threatened or Endangered. Page 107pp. in F. a. W. S. 

Department of the Interior, editor. FWS R6-ES-2010-0018. Federal Register, 

Washington, D.C.USFWS 2013. 

. 2013. Greater Sage-grouse (Centrocercus urophasianus) Conservation Objectives: 

Final Report. U.S. Fish and Wildlife Service, Denver, CO. February 2013.

References Ref-43
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

U.S. Government Printing Office (GPO). 2011. Final Rule for Oil and Gas Sector: New 

Source Performance Standards and National Emission Standards for Hazardous Air 

Pollutant Reviews. 77 Federal Register 49490. August 16, 2012. 

U.S. Global Change Research Program (USGCRP). 2009. Global Climate Change Impacts in 

the United States. Cambridge University Press. [Online] 

http://downloads.globalchange.gov/usimpacts/pdfs/climate-impacts-report.pdf 

U.S. Government Accountability Office. Hardrock Mining Information on State Royalties and 

the Number of Abandoned Mine Sites and Hazards, July 14, 2009.

U.S. Government Accountability Office. Livestock Grazing Federal Expenditures and Receipts 

Vary, Depending on the Agency and the Purpose of the Fee Charged, September 2005.

Utah Division of Wildlife Resources. 2013. Conservation Plan for Greater Sage-grouse in Utah. 

February 14, 2013. Internet website: http://wildlife.utah.gov/uplandgame/sagegrouse/pdf/greater_sage_grouse_plan.pdf. Accessed July 2, 2014.

Vance, L. K. and D.Stagliano. 2007. Watershed assessment of portions of the Lower 

Musselshell and Fort Peck Reservoir Subbasins. Report to the Bureau of Land 

Management, Billings, MT. Montana Natural Heritage Program, Helena, MT. 

Vermeire, L. T., Crowder, J. L., Wester, D. B. 2011. Plan Community and Soil Environmental 

Response to Summer Fire in the Northern Great Plains. Rangeland Ecology and 

Management 64:37-46. 

Vitt, Laurie J., J.P. Caldwell, and D.B. Shepard. 2006. Inventory of Amphibians and Reptiles in 

the Billings Field Office Region, Montana, Sam Noble Oklahoma Museum of Natural 

History and Dept. of Zoology, Univ. of Oklahoma, Norman, OK 73072, Feb. 2006.

Vuke, S.M., Wilde, E.M., Bergantino, R.N., 2000, Geologic map of the Hardin 30' x 60' 

quadrangle, Montana, Montana Bureau of Mines and Geology: Geologic Map 57, 1 

sheet(s), 1:100,000.

Vuke, S.M., Wilde, E.M., Bergantino, R.N., 2003, Geologic map of the Hysham 30' x 60' 

quadrangle, eastern Montana, Montana Bureau of Mines and Geology: Open-File 

Report 486, 10 p., 1 sheet(s), 1:100,000.

Vuke, S.M., Wilde, E.M., Lopez, D.A., Bergantino, R.N., 2000, Geologic map of the Lodge 

Grass 30' x 60' quadrangle, Montana, Montana Bureau of Mines and Geology: 

Geologic Map 56, 1 sheet(s), 1:100,000.

Vuke, S.M., Wilde, E.M., 2004, Geologic map of the Melstone 30' x 60' quadrangle, eastern 

Montana, Montana Bureau of Mines and Geology: Open-File Report 513, 12 p., 1 

sheet(s), 1:100,000.

WAFWA Sage‐grouse Strategy MOU, 2008

Ref-44 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

WAFWA (Western Association of Fish and Wildlife Agencies). 2014. Fire and Fuels 

Management Contributions to Sage-Grouse Conservation: A Status Report. 

Walker, B.L. and D. E. Naugle. 2011. West Nile Virus Ecology in Sagebrush Habitat and 

Impacts on Greater Sage-Grouse Populations. in S.T. Knick and J.W. Connelly 

(editors). Greater Sage-Grouse: ecology and conservation of a landscape species and its 

habitats. Studies in Avian Biology (vol 38:127-144), University of California Press, 

Berkeley, CA

Walker, B.L., D.E. Naugle, and K.E. Doherty. 2007a. Greater sage‐grouse population response 

to energy development and habitat loss. Journal of Wildlife Management 71:2644‐2654.

Walker, B.L., D.E. Naugle, K.E. Doherty, and T.E. Cornish. 2004. Outbreak of West Nile virus 

in greater sage grouse and guidelines for monitoring, handling, and submitting dead 

birds. Wildlife Society Bulletin 32:1000–6.

Walker, B.L. D.E. Naugle, K.E. Doherty, and T.E. Cornish. 2007b. West Nile Virus and greater 

sage‐grouse: estimating infection rate in a wild bird population. Avian Diseases 

51:691‐696. 

Wallestad, R. and D. Pyrah. 1974. Movement and nesting of sage grouse hens in central 

Montana. Journal of Wildlife Management 38:630-633.

Walton, W.E., and P.D. Workman. 1998. Effect of marsh design on the abundance of 

mosquitoes in experimental constructed wetlands in Southern California. Journal of the 

American mosquito control Association 14:95‐107.

Wambolt, C.L., A.J. Harp, B.L. Welch, N. Shaw, J.W. Connelly, K.P. Reese, C.E. Braun, D.A. 

Klebenow, E.D.McArthur, J.G. Thompson, L.A.Torell, and J.A. Tanaka. 2002. 

Conservation of Greater Sage‐Grouse on Public Lands in the Western U.S.: 

Implications of Recovery and Management Policies. PACWPL Policy Paper SG‐02‐02, 

Caldwell, ID: Policy Analysis Center for Western Public Lands. 41p.

Walsh, D.P., G.C. White, T.E. Remington, and D.C. Bowden. 2004. Evaluation of the lek count 

index for greater sage‐grouse. Wildlife Society Bulletin 32:56‐68.

Walston, L.J., B.L. Cantwell, and J.R. Krummel. 2009. Quantifying spatiotemporal changes in 

a sagebrushecosystem in relation to energy development. Ecography 

32:943‐952.Walters, C.J. 1986. Adaptive Management of Renewable Resources. 

MacMillan, New York, New York. 374pp.

Walters, C.J. 1987. Challenges in adaptive management of riparian and coastal ecosystems. 

Conservation Ecology 1(2):1 [online] http://www.ecologyandsociety.org/vol1/iss2/art1/

Wheatley, M., and C. Johnson. 2009. Factors limiting our understanding of ecological scale. 

Ecological Complexity 6:150‐159.

References Ref-45
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Werner et al., (J. Kerwin Werner, Bryce A. Maxell, Paul Hendricks, and Dennis l. Flath). 2004. 

Amphibians and Reptiles of Montana , Mountain Press Publishing, P.O. Box 2399, 

Missoula, MT, 2004.

Westerling, A.L., H.G. Hidalgo, D.R. Cayan, and T.W. Swetnam. 2006. Warming and earlier 

Spring increase Western U.S. forest wildfire activity. Science. 313:940.

Western Area Power Administration. 2013. Upper Great Plains Wind Energy programmatic 

Environmental impact Statement (Draft). DOE/EIS-0408. March 2013.

Western Region Climate Center. 2009. [Online] http://www.wrcc.dri.edu/cgibin/cliMAIN.pl?mt0807. Accessed on December 7, 2009.

White, Eric M. and Daniel J. Stynes. Spending Profiles of National Forest Visitors, NVUM 

Round 2 Update, March 2009.

White, Eric M and Daniel J. Stynes. Updated Spending Profiles for National Forest Recreation 

Visitors by Activity, August 2010.

Wiedinmyer, Christine and Hurteau, Matthew D. Prescribed Fire As a Means of Reducing 

Forest Carbon Emissions in the Western United States. Environ. Sci. Technol., 2010; 44 

(6): 1926-1932 DOI: 10.1021/es902455e.

Wild and Scenic River (WSR) Eligibility Report for the Billings and Pompeys Pillar RMPs on 

the RMP. [Online] http://www.blm.gov/mt/st/en/fo/billings_field_office.html.

Wilde, E.M., Porter, K.W. 2001. Geologic map of the Harlowton 30' x 60' quadrangle, Eastern 

Montana, Montana Bureau of Mines and Geology: Open-File Report 434, 20 p., 1 

sheet(s), 1:100,000.

Wilde, E.M., Porter, K.W. 2000. Geologic map of the Roundup 30' X 60' quadrangle, Central 

Montana, Montana Bureau of Mines and Geology: Open-File Report 404, 1 sheet(s), 

1:100,000.

Williams, C.F., M.J. Reed, R.H. Mariner, J. DeAngelo, S.P. Galanis, Jr. 2008. Assessment of 

Moderate- and High-Temperature Geothermal Resources of the United States: U.S. 

Geological Survey Fact Sheet 2008-3082, 4 p.

Williams, M.I., G.B. Paige, T.L. Thurow, A.L. Hild, and K.G. Gerow. 2011. Songbird 

relationships to shrubsteppe ecological site characteristics. Rangeland Ecology & 

Management 64:109‐118.

Wisdom, M.J,, and C.W. Meinke, S.T. Knick, and M.A. Schroeder. Factors Associated with 

Extirpation of Sage-Grouse. in S.T. Knick and J.W. Connelly (editors). Greater SageGrouse: ecology and conservation of a landscape species and its habitats. Studies in 

Avian Biology (vol 38), University of California Press, Berkeley, CA

Ref-46 References
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Wisdom, M J., C. W. Meinke, S. T. Knick, and M. A. Schroeder. 2011. “Factors associated 

with extirpation of sage-grouse.” Pp. 451-474. In: S. T. Knick and J.W. Connelly (eds.), 

Greater Sage-Grouse: Ecology of a Landscape Species and Its Habitats. Cooper 

Ornithological Union, University of California Press, Berkeley.

Worthington, David J. 1991. Abundance and Distribution of Bats in the Pryor Mountains of 

South Central Montana and North Eastern Wyoming. Report to the Bureau of Land 

Management Billings Field Office. Beartooth Ranger District, Custer National Forest, 

Montana Natural Heritage Program, Helena, MT. 23 pp.

Woolsey, et. a1. 1917. The Bull Mountain Coal Field. United States Geological Survey. 

Bulletin 647.

World Resources Institute (WRI). 2011. Climate Analysis Indicators Tool (CAIT), Version 4.0. 

Accessed July 15, 2011. [Online] http://cait.wri.org/cait-us.php?page=yearly

Wyoming Game and Fish Department. 2011. Wyoming Game and Fish Department Protocols 

for Treating Sagebrush to Benefit Sage‐Grouse. Unpublished report. 5 pp. 

Wyoming Sage-Grouse Working Group. 2003. Wyoming Greater Sage-grouse Conservation 

Plan. Cheyenne, Wyoming. 

Yellowstone County Air Pollution Control (YCAPC): Yellowstone County, Billings, Montana. 

[Online] http://www.co.yellowstone.mt.gov/airpollution/. 

Young, Michael K., Rocky Mountain Research Station. 2008. Yellowstone Cutthroat Trout. 

Montana Chapter of the American Fisheries Society. [Online] 

http://www.fisheries.org/units/AFSmontana/Yellowstone.html. 

Yoder J.M., D.A. Swanson, and E.A. Marschall. 2004. The cost of dispersal: Predation as a 

function of movement in ruffed grouse. Behavioral Ecology 15:469–76.

Zou, L., S.N. Miller, and E.T. Schmidtmann. 2006. Mosquito larval habitat mapping using 

remote sensing and GIS: Implications of coalbed methane development and West Nile 

virus. Journal of Medical Entomology43:1034–41.

75 FR 13910. 2010. Endangered and Threatened Wildlife and Plants: 12‐month finding for 

petitions to list the greater sage‐grouse as threatened or endangered.

References Ref-47
GLOSSARY

Steamboat Butte petroglyphs
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Glossary 1

1 Glossary

ACCRETED: Accreted lands are those lands that have been deposited by meandering river 

channels. The lands are effectively added to federal ownership and management. As a 

river channel changes lands are avulsed from one bank and accreted to the opposite 

bank, adding to acreage ownership on the opposite bank. 

ACQUISITION: The Bureau of Land Management (BLM) acquires land, easements, and other 

real property rights when it is in the public interest and consistent with approved land 

use plans (LUPs). The BLM’s land acquisition program is designed to: (1) improve 

management of natural resources through consolidation of federal, state, and private 

lands; (2) increase recreational opportunities, preserve open space, and/or ensure 

accessibility of public land; (3) secure key property necessary to protect endangered 

species and promote biological diversity; (4) preserve archaeological and historical 

resources; and (5) implement specific acquisitions authorized by Acts of Congress.

ACTIVE USE: Livestock grazing term meaning the current authorized use. Active use may 

constitute a portion, or all, of permitted use. Active use does not include temporary nonuse or suspended use for forage within all or a portion of an allotment. (43 CFR 4100.0-

5)

ACTIVITY PLAN: A type of implementation plan (see Implementation plan); an activity plan 

usually describes multiple projects and applies best management practices to meet land 

use plan objectives. Examples of activity plans include interdisciplinary management 

plans, habitat management plans, recreation area management plans, and allotment 

management plans. (H-1601, BLM Land Use Planning Handbook)

ACTUAL USE: Annual livestock grazing report describing where, how many, what kind or 

class of livestock, and how long livestock graze on an allotment, or on a portion or 

pasture of an allotment. (43 CFR 4100.0-5)

ADDITIONALITY: The conservation benefits of compensatory mitigation are demonstrably 

new and would not have resulted without the compensatory mitigation project. 

(adopted and modified from BLM Manual Section 1794)

ADMINISTRATIVE PURPOSES: Administrative use functions involving regular maintenance 

or operation of facilities or programs.

ADMINISTRATIVE USE: Official use related to management and resources of the public 

lands by federal, state, or local governments or non-official use sanctioned by an 

appropriate authorization instrument, such as right-of-way (ROW), permit, lease, or 

maintenance agreement.

AFFECTED ENVIRONMENT: The natural, physical, and human-related environment that is 

sensitive to changes from the alternatives.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

2 Glossary

AIR POLLUTION: The contamination of the atmosphere by any toxic or radioactive gases and 

particulate matter as a result of human activity.

AIR QUALITY: Air quality depends on the quantity and type of pollutants present in the 

atmosphere and the dispersion potential of an area to dilute those pollutants.

AIR QUALITY RELATED VALUE (AQRV): A resource identified by the Federal Land 

Management Agency for one or more Federal areas that may be adversely affected by a 

change in air quality. The resource may include visibility or a specific scenic, cultural, 

physical, biological, ecological, or recreational resource identified by the FLM for a 

particular area. AQRV impacts may also include sulfur, nitrogen, acid deposition, and 

lake acidification.

ALLOTMENT: An area of land designated and managed for grazing of livestock (43CFR 

4100.0-5). An allotment may be grazed by one or more livestock operators. Allotments 

generally consist of BLM lands but may also include other federally managed, stateowned, and private lands. An allotment may include one or more separate pastures. 

Livestock numbers and periods of use are specified for each allotment.

ALLOTMENT MANAGEMENT PLAN (AMP): A document prepared in consultation with the 

grazing lessees or permittees involved, which applies to livestock operations on the 

public lands and which (1) prescribes the manner in, and extent to which livestock 

operations will be conducted in order to meet the multiple-use, sustained-yield, 

economic and other needs and objectives as determined for the lands by the Secretary 

concerned; and (2) describes the type, location, ownership, and general specifications 

for the range improvements to be installed and maintained on the lands to meet the 

livestock grazing and other objectives of land management; and (3) contains such other 

provisions relating to livestock grazing and other objectives found by the Secretary 

concerned to be consistent with the provisions of this Act and other applicable law 

(from FLPMA, Title 43 Chapter 35, Subchapter I 1702[k]).

ALLOWABLE SALE QUANTITY (ASQ): The gross amount of timber volume that may be 

sold annually from a specified area over a stated period of time in accordance with the 

management plan.

ALL-TERRAIN VEHICLE (ATV): A wheeled vehicle (other than a snowmobile) that is 

defined as having a wheelbase and chassis width of 50-inches or less, steered using 

handlebars, generally having a dry weight of 800-pounds or less, travels on three or 

more low-pressure tires, and has a seat designed to be straddled by the operator.

ALTERNATIVE: A mix of management prescriptions applied to specific land areas to achieve 

a set of goals and objectives. Each alternative represents a different way of achieving a 

set of similar management objectives. 

AMENDMENT: The process for considering or making changes in the terms, conditions, and 

decisions of approved RMPs or management framework plans. Usually only one or two 

issues are considered that involve only a portion of the planning area. (H-1601, BLM 

Land Use Planning Handbook)
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ANALYSIS OF THE MANAGEMENT SITUATION (AMS): Assessment of the current 

management direction. It includes a consolidation of existing data needed to analyze 

and resolve identified issues, a description of current BLM management guidance, and a 

discussion of existing problems and opportunities for solving them.

ANIMAL UNIT MONTH (AUM): The amount of forage necessary for the sustenance of one 

cow or its equivalent for a period of one month, approximately 800 pounds of forage. 

(43 CFR 4100.0-5)

APPEAL: Application for review of an implementation decision by a higher administrative 

level.

APPROPRIATE FIRE MANAGEMENT RESPONSE (AMR): Any specific action suitable to 

meet fire management objectives. Typically, eth AMR ranges across a spectrum of 

tactical options (from monitoring to intensive management actions). The response 

action is based on an evaluation of risks to firefighter and public safety, the 

circumstances under which the fire occurs, including weather and fuel conditions, 

natural and cultural resource management objectives, protection priorities, and values to 

be protected. The evaluation must also include an analysis of the context of the specific 

fire within the overall local, geographic area, or national wildland fire situation. 

AREA OF CRITICAL ENVRIRONMENTAL CONCERN (ACEC): Areas within the public 

lands where special management attention is required (when such areas are developed 

or used or where no development is required) (1) to protect and prevent irreparable 

damage to important historic, cultural, or scenic values, fish and wildlife resources, or 

other natural systems or processes, or (2) to protect life and safety from natural hazards 

(FLPMA Section 103 (a)).

ASSESSMENT: The act of evaluating and interpreting data and information for a defined 

purpose (H-1601-1, BLM Land Use Planning Handbook). 

ASSETS: Term utilized to describe roads, primitive roads, and trails that comprise the 

transportation system. Also the general term utilized to describe all BLM constructed 

“Assets” contained within the Facility Asset Management System.

ATMOSPHERIC DEPOSITION: Air pollution produced when acid chemicals are incorporated 

into rain, snow, fog or mist and fall to the earth. Sometimes referred to as “acid rain” 

and comes from sulfur oxides and nitrogen oxides, products of burning coal and other 

fuels and from certain industrial processes. If the acid chemicals in the air are blown 

into areas where the weather is wet, the acids can fall to earth in the rain, snow, fog, or 

mist. In areas where the weather is dry, the acid chemicals may become incorporated 

into dust or smoke.

ATTAINMENT AREA: A geographic area in which criteria air pollutant levels meet the 

health-based primary standard (national ambient air quality standard (NAAQS) for the 

pollutant. An area may have on acceptable level for one criteria air pollutant but may 

have unacceptable levels for others. Thus, an area could be attainment and 
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Proposed Resource Management Plan and Final Environmental Impact Statement

4 Glossary

nonattainment simultaneously. Attainment areas are defined using federal pollutant 

limits set by EPA.

AUTHORIZED OFFICER: The federal employee who has the delegated authority to make a 

specific decision.

AVOIDANCE AREA: Areas determined to be less suitable for a ROW because of (1) 

important and/or valued resources or resources assigned to a special status, or (2) a 

substantive conflict with use. These areas exhibit constraints to siting facilities and are 

less desirable for a ROW but could be mitigated to reduce potential effects the ROW 

might have on the environment. 

AVOIDANCE MITIGATION: Avoiding the impact altogether by not taking a certain action 

or parts of an action (40 CFR 1508.20(a)) (e.g. may also include avoiding the impact by 

moving the proposed action to a different time or location).

AVULSED: Avulsed lands are those lands which have been eroded by meandering river 

channels. The lands are effectively removed from federal ownership and management. 

As a river channel changes lands are avulsed from one bank and accreted to the 

opposite bank, adding to acreage ownership on the opposite bank. 

BACKCOUNTRY BYWAYS: Vehicle routes that traverse scenic corridors using secondary or 

backcountry road systems. National backcountry byways are designated by the type of 

road and vehicle needed to travel the byway.

BANKHEAD-JONES LAND USE LANDS: Formerly privately owned sub-marginal 

farmlands incapable of producing sufficient income to support the family of a farm 

owner and acquired by the United States, purchased under Title III of the BankheadJones Farm Tenant Act of July 22, 1937. These acquired lands became known as land 

utilization projects and were subsequently transferred from jurisdiction of the USDA to 

the US-DOI. They are now administered by the BLM.

BASAL AREA: The cross-sectional area of a single stem, including the bark, measured at 

breast height (4.5 feet above the ground).

BASELINE: The pre-existing condition of a defined area and/or resource that can be 

quantified by an appropriate metric(s). During environmental reviews, the baseline is 

considered the affected environment that exists at the time of the review’s initiation, and 

is used to compare predictions of the effects of the proposed action or a reasonable 

range of alternatives.

BENEFICIAL OUTCOMES: Also referenced as “recreation benefits”; improved conditions, 

maintenance of desired conditions, prevention of worse conditions, and the realization 

of desired experiences.

BEST MANAGEMENT PRACTICES (BMPs): A suite of techniques that guide or may be 

applied to management actions to aid in achieving desired outcomes. Best management 

practices are often developed in conjunction with LUPs, but they are not considered a 
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LUP decision unless the LUP specifies that they are mandatory. They may be updated 

or modified without a plan amendment if they are not mandatory. (H-1601, BLM Land 

Use Planning Handbook)

BIG GAME: Indigenous, ungulate (hoofed) wildlife species that are hunted, such as elk, deer, 

bison, bighorn sheep, and pronghorn antelope.

BIOLOGICAL ASSESSMENT (BA): The document prepared by or under the direction of 

BLM concerning listed and proposed species and designated and proposed critical 

habitat that may be present in the action area and contains the BLM’s determination of 

potential effects of the action on such species and habitat. Biological assessments are 

required for formal consultations and conferences on “major construction projects.” 

They are recommended for all formal consultations and formal conferences and many 

informal consultations where a written evaluation of the effects of an action on listed or 

proposed species and on designated or proposed critical habitat is needed. (M-6840, 

Special Status Species Manual).

BIOLOGICAL CRUST: Microorganisms (e.g., lichens, algae, cyanobacteria, micro fungi) and 

non-vascular plants (e.g., mosses, lichens) that grow on or just below the soil surface. 

Synonym: microbiotic crust and cryptogamic crust. ( BLM 2005c TR 1734-06 

Interpreting Indicators of Rangeland Health, Version 4 (2005))

BIOLOGICAL OPINION (BO): The document which includes: (1) the opinion of the USFWS 

as to whether or not a federal action is likely to jeopardize the continued existence of 

listed species or result in the destruction of adverse modification of designated critical 

habitat, (2) a summary of the information on which the opinion is based, and (3) a 

detailed discussion of the effects of the action on listed species or designated critical 

habitat. Depending upon the determination of jeopardy or non-jeopardy, the BO may 

contain reasonable and prudent alternatives, a statement of anticipated take of listed 

animals, and conservation recommendations for listed plants. (M-6840, Special Status 

Species Manual).

BIOLOGICALLY SIGNIFICANT UNIT (BSU): A Biologically Significant Unit for this 

plan is the summary of all the Priority Habitat Management Areas within a Greater 

Sage-Grouse population as delineated in the COT report.

BLACK-FOOTED FERRET HABITAT: A complex of prairie dog towns within 1.5 

kilometers of each other comprising a total of 1,000 acres (Biggens 1993, Biggens et al. 

2006).

BOARD FOOT: The amount of wood contained in an unfinished board 1 inch thick, 12 inches 

long, and 12 inches wide; abbreviated bd ft (1,000 bd ft is written as 1 MBF and 

1,000,000 BF is written as 1 MMBF). 

CANDIDATE SPECIES: Taxa for which the US Fish and Wildlife Service has sufficient 

information on their status and threats to propose the species for listing as endangered 

or threatened under the Endangered Species Act, but for which issuance of a proposed 

rule is currently precluded by higher priority listing actions. Separate lists for plants, 
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vertebrate animals, and invertebrate animals are published periodically in the Federal 

Register (M-6840, Special Status Species Manual).

CANOPY: The continuous cover formed by tree crowns consisting of one or several layers. 

CASUAL USE: Activities that involve practices that do not ordinarily disturb or damage the 

public lands, resources, or improvements and, therefore, do not require a ROW grant or 

temporary use permit (43 CFR 2800). Also, any short-term noncommercial activity that 

does not damage or disturb the public lands, their resources, or improvements and that 

is not prohibited by closure of the lands to such activities (43 CFR 2920). Casual use 

generally includes collecting geochemical, rock, soil, or mineral specimens using hand 

tools, hand panning, and non-motorized sluicing. It also generally includes use of metal 

detectors, gold spears, and other battery-operated devices for sensing the presence of 

minerals, and hand battery-operated dry washers. Casual use does not include use of 

mechanized earth-moving equipment, truck mounted drilling equipment, suction 

dredges, motorized vehicles in areas or on routes designated as closed to off-road 

vehicles, chemicals, or explosives. It also does not include occupancy or operations 

where the cumulative effects of the activities result in more than negligible disturbance.

CAVE: A cave or cavern is a natural underground space large enough for a human to enter. 

Some people suggest that the term cave should only apply to cavities that have some 

part that does not receive daylight; however, in popular usage, the term includes smaller 

spaces like rock shelters and grottos.

CLOSED: Generally denotes that an area is not available for a particular use or uses. For 

example, 43 CFR 8340.0-5 sets forth the specific meaning of “closed” as it relates to 

off-highway vehicle (OHV) use, and 43 CFR 8364 defines “closed” as it relates to 

closure and restriction orders. (H-1601-1, BLM Land Use Planning Handbook). 

CODE OF FEDERAL REGULATIONS (CFR): The official, legal tabulation or regulations 

directing Federal Government activities. (BLM National Management Strategy for 

OHV Use on Public Lands)

CO-DOMINANT: A tree whose crown helps to form the general level of the main canopy.

COLLABORATION: A cooperative process in which interested parties, often with widely 

varied interests, work together to seek solutions with broad support for managing public 

and other lands. (H-1601, BLM Land Use Planning Handbook)

COMMERCIAL THINNING: Any type of thinning producing merchantable material at least 

equal to the value of the direct costs of harvesting.

COMMUNITY RECREATION-TOURISM MARKET: A community or communities 

dependent on public lands recreation or related tourism use, growth, or development. 

Major investments in facilities and visitor assistance are authorized within SRMAs 

where the BLM’s strategy is to target demonstrated community recreation-tourism 

market demand. Here, recreation management actions are geared toward meeting 

primary recreation-tourism market demand for specific activity, experience, and benefit 
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Glossary 7

opportunities. These opportunities are produced through maintenance of prescribed 

natural resource or community setting character and by structuring and implementing 

management, marketing, monitoring, and administrative actions accordingly.

COMPENSATORY MITIGATION: Compensating for the (residual) impact by replacing or 

providing substitute resources or environments (40 CFR 1508.20).

COMPENSATORY MITIGATION PROJECTS: The restoration, creation, enhancement, 

and/or preservation of impacted resources (adopted and modified from 33 CFR 332), 

such as on-the-ground actions to improve and/or protect habitats (e.g. chemical 

vegetation treatments, land acquisitions, conservation easements). (adopted and 

modified from BLM Manual Section 1794).

COMPENSATORY MITIGATION SITES: The durable areas where compensatory mitigation 

projects will occur. (adopted and modified from BLM Manual Section 1794).

COMPREHENSIVE TRAVEL MANAGEMENT: The proactive interdisciplinary planning; 

on-the-ground management and administration of travel networks (both motorized and 

non-motorized) to ensure public access, natural resources, and regulatory needs are 

considered. It consists of inventory, planning, designation, implementation, education, 

enforcement, monitoring, easement acquisition, mapping and signing, and other 

measures necessary to provide access to public lands for a wide variety of uses

(including uses for recreational, traditional, casual, agricultural, commercial, 

educational, and other purposes).

CONDITIONS OF APPROVAL (COA): Conditions of approval are the conditions or 

provisions (requirements) under which an application for a permit to drill or a sundry 

notice is approved.

CONDITION CLASS (fire regimes): Fire regime condition classes are a measure describing 

the degree of departure from historical fire regimes, possibly resulting in alterations of 

key ecosystem components, such as species composition, structural stage, stand age, 

canopy closure, and fuel loadings. One or more of the following activities may have 

caused this departure: fire suppression, timber harvesting, livestock grazing, 

introduction, and establishment of exotic plant species, introduced insects or disease, or 

other management activities.

CONDITION CLASS 1: Fire regimes are within a historical range, and the risk of losing key 

ecosystem components from fire is low. Vegetation attributes (species composition and 

structure) are intact and functioning within an historical range.

CONDITION CLASS 2: Fire regimes have been moderately altered from their historical range. 

The risk of losing key ecosystem components from fire is moderate. Fire frequencies 

have departed from historical frequencies by one or more return intervals (increased or 

decreased). This results in moderate changes to one or more of the following: fire size, 

frequency, intensity, severity, and landscape patterns. Vegetation attributes have been 

moderately altered from their historical range.
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CONDITION CLASS 3: Fire regimes have been altered significantly from their historical 

ranges. The risk of losing key ecosystem components from fire is high. Fire frequencies 

have departed from historical frequencies by multiple return intervals. This action 

results in dramatic changes to one or more of the following: fire size, frequency, 

intensity, severity, and landscape patterns. Vegetation attributes have been altered 

significantly from their historical range.

CONFORMANCE: A proposed action shall be specifically provided for in the land-use plan, or 

if not specifically mentioned, shall be clearly consistent with the goals, objectives, or 

standards of the approved land use plan. (H-1601, BLM Land Use Planning Handbook)

CONIFER: A tree or shrub of the order Coniferae with cones and needle-shaped or scale like 

leaves. 

CONIFEROUS: Pertaining to conifers, which bear woody cones containing naked seeds.

CONSERVATION AGREEMENT: A formal signed agreement between the US Fish and 

Wildlife Service and other parties that implement specific actions, activities, or 

programs designed to eliminate or reduce threats to, or otherwise improve the status of, 

a species. Conservation agreements can be developed at a state, regional, or national 

level and generally include multiple agencies at both the state and federal level, as well 

as tribes. Depending on the types of commitments the BLM makes in a conservation 

agreement and the level of signatory authority, plan revisions or amendments may be 

required before the conservation agreement is signed or subsequently in order to 

implement the conservation agreement. (M-6840, Special Status Species Manual)

CONSERVATION STRATEGY: A strategy outlining current activities or threats that are 

contributing to the decline of a species, along with the actions or strategies needed to 

reverse or eliminate such a decline or threats. Conservation strategies are generally 

developed for species of plants and animals that are designated as BLM sensitive 

species or that have been determined by the USFWS to be federal candidates under the 

ESA.

CONTROLLED SURFACE USE: Use and occupancy is allowed (unless restricted by another 

stipulation), but identified resource values require special operational constraints that 

may modify the lease rights. CSU is used for operating guidance, not as a substitute, for 

the No Surface Occupancy (NSO) or timing stipulations. (2) Stipulations to be attached 

to oil and gas leases to protect specific areas or resources, such as riparian and wetland 

areas, rivers, sensitive species, viewsheds, and watersheds.

COOPERATING AGENCY: The Council on Environmental Quality (CEQ) regulations 

implementing National Environmental Policy Act (NEPA) define a cooperating agency 

as any agency that has jurisdiction by law or special expertise for proposals covered by 

NEPA (40 CFR 1501.6). Any federal, state, local government jurisdiction with such 

qualifications may become a cooperating agency by agreement with the lead agency. 

(H-1601, BLM Land Use Planning Handbook)
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CORD: A stack of fuelwood that measures 4 foot by 4 foot by 8 foot (128 cubic feet) including 

wood, bark, and air space within the stack.

COUNCIL ON ENVRIONMENTAL QUALITY (CEQ): CEQ is an advisory council to the 

President of the U.S. established by the National Environmental Policy Act of 1969. It 

reviews federal programs to analyze and interpret environmental trends and 

information.

CREMAINS: Cremated human remains. Cremated remains are not considered a hazardous 

substance. (WO IM-2011-159)

CRITICAL HABITAT: (1) The specific areas within the geographical area currently occupied 

by a species, at the time it is listed in accordance with the ESA, on which are found 

those physical or biological features (i) essential to the conservation of the species and 

(ii) that may require special management considerations or protection, and (2) specific 

areas outside the geographical area occupied by a species at the time it is listed on 

determination by the USFWS and/or NMFS that such areas are essential for the 

conservation of the species. Critical habitats are designated in 50 CFR Parts 17 and 226. 

The constituent elements of critical habitat are those physical and biological features of 

designated or proposed critical habitat essential to the conservation of the species, 

including, but not limited to: (1) space for individual and population growth, and for 

normal behavior; (2) food, water, air, light, minerals, or other nutritional or 

physiological requirements; (3) cover or shelter; (4) sites for breeding, reproduction, 

rearing of offspring, germination, or seed dispersal; and (5) habitats that are protected 

from disturbance or are representative of the historic geographic and ecological 

distributions of a species. (M6840, Special Status Species Manual)

CROWN: The part of the tree or woody plant bearing live branches and foliage. 

CRUCIAL VALUE HABITAT: Any particular range or habitat component that directly limits 

a community, population, or subpopulation to reproduce and maintain itself at a certain 

level over the long-term. Those sensitive use areas that, because of limited abundance 

and/or unique qualities, constitute irreplaceable critical requirements for high interest 

wildlife. This may also include highly sensitive habitats, including fragile soils that 

have little or no reclamation potential. Restoration or replacement of these habitats may 

not be possible. Examples include the most crucial (critical) summer and/or winter 

range or concentration areas; critical movement corridors; breeding and rearing 

complexes; spawning areas; developed wetlands; Class 1 and 2 streams, lake, ponds or 

reservoirs; and riparian habitats critical to high interest wildlife.

CRUCIAL WINTER RANGE: That part of the winter range where a high proportion of the 

species’ population is located during severe winter conditions.

CULTURAL RESOURCES or CULTURAL PROPERTY: A definite location of human 

activity, occupation, or use identifiable through field inventory (survey), historical 

documentation, or oral evidence. The term includes archaeological, historic, or 

architectural sites, structures, or places with important public and scientific uses and 
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10 Glossary

may include definite locations (sites or places) of traditional cultural or religious 

importance to specified social and/or cultural groups. (Cf. “traditional lifeway value”; 

see “definite location.”) Cultural resources are concrete, material places and things that 

are located, classified, ranked, and managed through the system of identifying, 

protecting, and utilizing for public benefit described in this Manual series. (M-8100-1, 

BLM Cultural Resources Management)

CULTURAL RESOURCE INVENTORY CLASSES: There are three cultural resource 

inventory classes as identified in M-8100-1, BLM Cultural Resources Management. 

1. Class I-existing data inventory. A study of published and unpublished documents, 

records, files, registers, and other sources, resulting in analysis and synthesis of all 

reasonably available data. Class I inventories encompass prehistoric, historic, and 

ethnological/sociological elements and are in large part chronicles of past land uses. 

They may have major relevance to current land use decisions. 

2. Class II-sampling field inventory. A statistically based sample survey designed to 

help characterize the probable density, diversity, and distribution of archaeological 

properties in a large area by interpreting the results of surveying limited and 

discontinuous portions of the target area.

3. Class III-intensive field inventory. A continuous, intensive survey of an entire target 

area, aimed at locating and recording all archaeological properties that have surface 

indications, by walking close-interval parallel transects until the area has been 

thoroughly examined. Class III methods vary geographically, conforming to the 

prevailing standards for the region involved. (M-8100-1, BLM Cultural Resources 

Management)

CUMULATIVE EFFECT: The impact on the environment resulting from the impact of one 

action added to other past, present, and reasonable foreseeable future actions regardless 

of what agency (federal or nonfederal) or person undertakes such other actions. 

Cumulative impacts can result from individually minor but collectively significant 

actions taking place over time. (H-1790-1, BLM NEPA Handbook)

DEFERRED ROTATION: Rotation grazing with regard to deferring pastures turn-out dates 

beyond the growing season, if they were used early the prior year, or that have been 

identified as needing deferment for resource reasons.

DESIGNATED ROADS, PRIMITIVE ROADS, AND TRAILS: Specific roads, primitive 

roads, and trails identified by the BLM (or other agency) where some type of motorized 

vehicle use is appropriate and allowed, either seasonally or year-long (from MS-1626).

DESIGN VALUE: A statistic that describes the air quality status of a given location relative to 

the level of the National Ambient Air Quality Standards (NAAQS). Design values are 

defined to be consistent with the individual NAAQS in terms of their averaging times 

and their statistical formats.

DESIRABLE NON-NATIVE: Any species not naturally occurring within a given area, which 

independently or in conjunction with other species contributes beneficially to a site’s 

ecological function, recovery, or the desired future condition of a site.
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DESIRED CONDITION: Description of those factors that should exist within ecosystems to 

maintain their survival and to meet social and economic needs.

DESIRED OUTCOMES: A type of land use plan decision expressed as a goal or objective.

DESTINATION RECREATION-TOURISM MARKET: This market is composed of national 

or regional recreation-tourism visitors and other constituents who value public lands as 

recreation-tourism destinations. Major investments in facilities and visitor assistance are 

authorized within SRMAs where the BLM’s strategy is to target demonstrated 

destination recreation-tourism market demand. Here, recreation management actions are 

geared toward meeting primary recreation-tourism market demand for specific activity, 

experience, and benefit opportunities. These opportunities are produced through 

maintenance of prescribed natural resource setting character and by structuring and 

implementing management, marketing, monitoring, and administrative actions 

accordingly.

DIAMETER AT BREAST HEIGHT (DBH): Standard measurement of a tree’s diameter, 

usually taken at 4.5 feet above the ground. 

DISPERSED RECREATION: Recreation activities of an unstructured type that are not 

confined to specific locations or dependent on recreation sites. Examples of these 

activities may be hunting, fishing, off-road vehicle use, hiking, and sightseeing.

DISPOSAL: Transfer of public land out of federal ownership to another party through sale, 

exchange, Recreation and Public Purposes Act of 1926, Desert Land Entry or other land 

law statutes.

DISRUPTIVE ACTIVITIES: Those uses and activities that are likely to alter the behavior of, 

displace, or cause excessive stress to wildlife populations occurring at a specific 

location and/or time. In this context, disruptive activity(ies) refers to those actions that 

alter behavior or cause the displacement of wildlife such that reproductive success is 

negatively affected, or the physiological ability to cope with environmental stress is 

compromised. This term does not apply to the physical disturbance of the land surface, 

vegetation, or features. Examples of disruptive activities may include fence 

construction, noise, vehicle traffic, or other human presence regardless of the activity. 

The tern is used in conjunction with protecting wildlife during crucial life stages (for 

example, breeding, nesting, birthing, etc.), although it could apply to any resource 

value. This definition is not intended to prohibit all activities or authorized uses. 

These definitions are not intended to prohibit all activities or authorized uses. For 

example, emergency activities (fire suppression, search and rescue, etc.), or rangeland 

monitoring, dispersed recreational activities (hunting, hiking, etc.), and livestock 

grazing are not considered surface-disturbing or disruptive activities.

DOMINANT: A tree whose crown extends above the general level of the main canopy. 

DURABILITY (PROTECTIVE and ECOLOGICAL): The maintenance of the effectiveness of 

a mitigation site and project for the duration of the associated impacts, which includes 
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12 Glossary

resource, administrative/legal, and financial considerations. (adopted and modified 

from BLM Manual Section 1794)

EASEMENT: An interest in land entitling the owner or holder, as a matter or right, to enter 

upon land owned by another party for a particular purpose.

ECOLOGICAL SITE: A kind of land with a specific potential natural community and specific 

physical site characteristics, differing from other kinds of land in their ability to produce 

distinctive kinds and amounts of vegetation and to respond to management. Ecological 

sites are defined and described with information about soil, species composition, and 

annual production.

ECOLOGICAL SITE DESCRIPTION: Description of the soils, uses, and potential of a kind of 

land with specific physical characteristics to produce distinctive kinds and amounts of 

vegetation. (Interpreting Indicators of Rangeland Health)

ECOSYSTEM: Organisms together with their abiotic environment, forming an interacting 

system, inhabiting an identifiable space. (Society for Range Management)

ELIGIBLE RIVER: A river or river segment found eligible for inclusion into the National Wild 

and Scenic Rivers System through the determination that it is free-flowing and, with its 

adjacent land area, possesses one or more river-related outstandingly remarkable values. 

(Wild and Scenic Rivers Act) 

EMERGENCY STABILIZATION AND REHABILITATION (ESR): Prompt action(s) 

following a wildfire that are necessary to stabilize and prevent unacceptable degradation 

to natural and cultural resources, minimize threats to life and property, repair lands 

unlikely to recover, and repair or replace minor facilities damaged by fire. 

ENDANGERED SPECIES: An endangered species is defined as any species that is in danger 

of extinction throughout all or a significant portion of its range (BLM Manual 6840, 

Special Status Species Manual).

ENVIRONMENTAL ASSESSMENT (EA): A concise public document for which a federal 

agency is responsible that serves to (1) briefly provide sufficient evidence and analysis 

for determining whether to prepare an environmental impact statement or a finding of 

no significant impact, (2) aid an agency’s compliance with the NEPA when no 

environmental impact statement is necessary, and (3) facilitate preparation of an 

environmental impact statement when one is necessary. (40 CFR 1508.9)

ENVIRONMENTAL IMPACT STATEMENT (EIS): A detailed written statement as required 

by Section 102 (2) of the NEPA, which states that all agencies of the Federal 

Government shall include in every...major federal action significantly affecting the 

quality of the environment, a detailed statement prepared by the responsible official on 

(1) the environmental impacts of the proposed action, (2) any adverse environmental 

effects that cannot be avoided should the proposal be implemented, (3) alternatives to 

the proposed action, (4) the relationship between local short-term uses of man’s 

environment and the maintenance and enhancement of long-term productivity, and (5) 
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Glossary 13

any irreversible and irretrievable commitments of resources that would be involved in 

the proposed action, should it be implemented. (40 CFR 1508.11 and the NEPA of 

1969)

EPHEMERAL STREAM: A stream that flows only in direct response to precipitation, and 

whose channel is at all times above the water table. Generally, ephemeral streams do 

not flow continuously for more than 30 days and have more robust upland vegetation 

than found outside the ephemeral riparian wetland area.

EXISTING WAY: A way existing at the time that a Wilderness Study Area survey was 

completed. 

EVALUATION (plan evaluation): The process of reviewing the land use plan and the periodic 

plan monitoring reports to determine whether the land use plan decisions and NEPA 

analysis are still valid and whether the plan is being implemented.

EXCEEDANCE: With respect to a national ambient air quality standard means one occurrence 

of a measured or modeled concentration greater than the specified concentration level of 

such standard for the averaging period (1-hr, 3-hr, 8-hr, 24-hr, or annual) specified by 

the standard.

EXCEPTIONAL EVENT: An event that affects air quality, is not reasonably controllable or 

preventable, is an event caused by human activity that is unlikely to recur at a particular 

location or a natural event, and is determined by the EPA Administrator in accordance 

with 40 CFR 50.14 to be an exceptional event. It does not include stagnation of air 

masses or meteorological inversions, a meteorological event involving high 

temperatures or lack of precipitation, or air pollution relating to source noncompliance.

EXCLUSION AREA: Areas determined unsuitable for a ROW because of (1) unique, highly 

valued, complex, or legally protected resources; (2) potentially significant 

environmental impact resulting from conflict with current land uses; or (3) areas posing 

substantial hazard to construction and/or operation of linear facility (e.g., electric 

transmission line, pipeline, telephone line, fiber optic line). In these areas, ROWs would 

be granted only in cases where there is a legal requirement to provide such access.

EXTENSIVE RECREATION MANAGEMENT AREA (ERMA): The ERMA is an 

administrative unit that requires specific management consideration in order to address 

recreation use, demand, or R&VS program investments.

FEDERAL LANDS: As used in this document, lands owned by the United States, without 

reference to how the lands were acquired or what federal agency administers the lands. 

The term includes mineral estates and coal estates underlying private surface but 

excludes lands held by the United States in trust for Indians, Aleuts, or Eskimos.

FEDERAL LAND POLICY AND MANAGEMENT ACT OF 1976 (FLPMA): Public law 94-

579. An Act to establish public land policy; to establish guidelines for its 

administration; to provide for the management, protection, development, and 

enhancement of the public lands; and for other purposes.
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FEDERAL LAND TRANSACTION FACILITATION ACT (FLTFA): FLTFA monies accrue 

from disposal of BLM lands by sale and the monies stay within the state where the 

disposal parcels are located. The BLM is entitled to 60% of the fund, while the Forest 

Service, Park Service and Fish and Wildlife Service are each entitled to 10%. The 

remaining 10% covers administrative costs. A proposal to use the fund for a specific 

acquisition must be presented to and agreed upon by all four agencies. 

FEDERAL REGISTER: A daily publication that reports Presidential and federal agency 

documents. (BLM National Management Strategy for OHV Use on Public Lands)

FIRE FREQUENCY: How often a fire burns in a given area; often expressed in terms of fire 

return intervals. For example, a site might burn over every 5 to 15 years. 

FIRE INTENSITY: Expression used to describe the power of wildland fires. More commonly 

described as the rate of energy released per unit length of the fire front. 

FIRE MANAGEMENT PLAN: Strategic implementation-level plans that define a program to 

manage wildland fires, fuel reduction, and fire rehabilitation based on an area’s 

approved RMP. Fire management plans must address a full range of fire management 

activities that support ecosystem sustainability, values to be protected, protection of 

firefighter and public safety, and public health and environmental issues and must be 

consistent with resource management objectives and activities of the area.

FIRE PREPAREDNESS: Activities that lead to a safe, efficient, and cost-effective fire 

management program in support of land and resource management objectives through 

appropriate planning and coordination. 

FIRE REGIME/CONDITION CLASS: An interagency standardized tool for determining the 

degree of departure from reference condition vegetation, fuels, and disturbance regimes. 

Assessing FRCC can help guide management objectives and set priorities for treatments

FIRE SEVERITY: A qualitative measure of the fire’s immediate effects on the ecosystem. 

Relates to the extent of mortality and survival of plant and animal life – both above and 

below ground and to loss of organic matter.

FIRE SUPPRESSION: All work activities connected with fire extinguishing operations, 

beginning with discovery of a fire and continuing until the fire is completely out.

FLUID MINERALS: Fluid minerals includes: Oil, gas, coal bed natural gas, and geothermal 

resources.

FLUVIAL: Pertaining to streams or produced by stream action.

FORAGE: Vegetation of all forms available and of a type used for animal consumption.

FOREST: An ecosystem characterized by a more or less dense and extensive tree cover, often 

consisting of stands varying in characteristics such as species composition, structure, 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Glossary 15

age class, and associated processes, and commonly including meadows, streams, fish, 

and wildlife.

FOREST ECONOMIC ANALYSIS SPREADSHEED TOOL (FEAST): A modeling tool used 

to assist in the development of economic impacts. The goal for FEAST model is to 

assist both economists and planning specialists in completing economic impact 

analyses. 

FOREST HEALTH: The perceived condition of a forest derived from concerns about such 

factors as its age, structure, composition, function, vigor, presence of unusual levels of 

insects or disease, an resilience to disturbance.

FOREST HEALTH TREATMENTS: Treatments that restore forest ecosystems or stands to a 

condition that sustains complexity, function, and/or productivity while providing for 

human needs.

FOREST LAND: Land that is now, or has the potential of being, at least 10 percent stocked by 

forest trees (based on crown closure) or 16.7 percent stocked (based on tree stocking).

FOSSIL: Fossils are remains, traces, or imprints of organisms, preserved in or on the earth’s 

crust, and include fossilized bones, impressions of parts of organisms, or tracks. 

FRAGMENTATION: Fragmentation is the splitting or isolating of patches of similar habitat. 

Habitat can be fragmented by natural events or development activities.

FREE-FLOWING RIVER: “Free-flowing,” as applied to any river or section of a river, means 

existing or flowing in a natural condition without impoundment, diversion, 

straightening, rip-rapping, or other modifications of the waterway. (Wild and Scenic 

Rivers Act)

FUEL LOADING: The weight of fuels in a given area, usually expressed in tons per acre, 

pounds per acre, or kilograms per square meter.

FUEL MANAGEMENT: Manipulation or reduction of fuels to meet forest protection and 

management objectives while preserving and enhancing environmental quality.

FUEL TREATMENT: The rearrangement or disposal of fuels to reduce the fire hazard.

FUEL TYPE: An identifiable association of fuel elements of a distinctive plant species, form, 

size, arrangement, or other characteristics that will cause a predictable rate of fire spread 

or difficulty of control under specified weather conditions.

FUNCTIONAL HABITAT: The combination of requirements (i.e. food, water, cover, and 

space), juxtaposed in a manner necessary to provide sustainable populations of fish and 

wildlife species. In addition, anthropogenic activities within this habitat must be such 

that fish or wildlife can subsist without reducing sustainability of the species. Habitat 

functionality would vary by wildlife species and by location.
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FUNCTIONING AT RISK: (1) A condition in which vegetation and soil are susceptible to 

losing their ability to sustain naturally functioning biotic communities. Human 

activities, past or present, may increase the risks. (Rangeland Reform Final 

Environmental Impact Statement [FEIS] at 26.) (2) Uplands or riparian-wetland areas 

that are properly functioning, but a soil, water, or vegetation attribute makes them 

susceptible to degradation and lessens their ability to sustain natural biotic communities.

Uplands are particularly at risk if their soils are susceptible to degradation. Human 

activities, past or present, may increase the risks. (Rangeland Reform Draft 

Environmental Impact Statement [DEIS] Glossary). See also Properly Functioning 

Condition and Nonfunctioning Condition (H-4180-1, BLM Rangeland Health Standards 

Manual).

GEOCACHING: Geocaching is an outdoor adventure game for global position system (GPS) 

users. Participating in a cache hunt is an activity designed to take advantage of the 

features and capability of a GPS unit and enjoy the freedom of access to public land. 

GPS users use the location coordinates to find the caches. Once found, a cache may 

provide the visitor with a variety of awards. The visitor is asked to sign a logbook and 

to leave or replace items they find in the cache. 

GEOGRAPHIC INFORMATION SYSTEM (GIS): A system of computer hardware, software, 

data, and applications that capture, store, edit, analyze, and display a wide array of 

geospatial information. (H-1601, BLM Land Use Planning Handbook)

GOAL: A broad statement of a desired outcome; usually not quantifiable and may not have 

established timeframes for achievement. . (H-1601, BLM Land Use Planning 

Handbook)

GRAZING LEASE: A document authorizing use of the public lands outside an established 

grazing district. Grazing leases specify all authorized use including livestock grazing, 

suspended use, and conservation use. Leases specify the total number of AUMs 

apportioned, the area authorize for grazing use, or both. (43CFR 4100.0-5)

GRAZING PERMIT: A document authorizing the use of the public lands within an established 

grazing district. Grazing permits specify all authorized use including livestock grazing, 

suspended use, and conservation use. Permits specify the total number of AUMs 

apportioned, the area authorized for grazing use, or both (43CFR 4100.0-5).

GRAZING PLAN: A concisely written program of livestock grazing management, including 

supportive measures, if required, designed to attain specific management goals in a 

grazing allotment. A grazing plan is prepared in consultation with the permittee(s), 

lessee(s), and the interested public. Livestock grazing is considered in relation to other 

uses of the range and to renewable resources, such as watershed, vegetation, and 

wildlife. A grazing plan establishes seasons of use, the number of livestock to be 

permitted, the range improvements needed, and the grazing system.
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Glossary 17

GRAZING PREFERENCE (or Preference): A superior or priority position against others for 

the purpose of receiving a grazing permit or lease. This priority is attached to base 

property owned or controlled by the permittee or lessee (43CFR 4100.0-5).

GUIDELINES: A practice, method, or technique determined to be appropriate to ensure that 

standards can be met or that significant progress can be made toward meeting the 

standard. Guidelines are tools such as grazing systems, vegetative treatments, or 

improvement projects that help managers and permittees achieve standards. Guidelines 

may be adapted or modified when monitoring or other information indicated the 

guideline is not effective, or a better means of achieving the applicable standard 

becomes appropriate. (H-4180-1, BLM Rangeland health Standards Manual) 

HABITAT: An environment that meets a specific set of physical, biological, temporal, or 

spatial characteristics that satisfy the requirements of a plant or animal species or group 

of species for part or all of their life cycle. (M6840, Special Status Species Manual)

HABITAT TYPE: An aggregation of units of land capable of producing similar plant 

communities at climax.

HABITAT MANAGEMENT PLAN: .(HMP): a written and approved activity plan for a 

geographical area of public lands which identifies wildlife habitat management actions 

to be implemented in achieving specific objectives related to RMP planning document 

decisions. (BLM Manual 6780, 1981.)

HARVESTING: The felling, skidding, on-site processing, and loading of trees or logs onto 

trucks.

HERD AREA: The geographic area identified as having been used by a herd as its habitat in 

December 1971.

HERD MANAGEMENT AREA (HMA): Public land under the jurisdiction of the BLM that 

has been designated for special management emphasizing the maintenance of an 

established wild horse or burro herd. (H-4710-1)

HERD MANAGEMENT AREA PLAN (HMAP): An activity plan that focuses on and contains 

the necessary instructions for the management of wild horses on specified public lands 

to meet wild horse health, resource condition, sustained yield, multiple use, economic, 

and other objectives. The HMAP prescribes measures for the protection, management, 

and control of wild horses and burros and their habitat on one or more herd 

management areas, in conformance with decisions made in approved management 

framework or RMPs.

HISTORIC RANGE OF VARIABILITY (HVR): Characterizes fluctuations in ecosystem 

conditions or processes over time; thereby providing a reference against which to 

evaluate recent and potential future ecosystem change. Landres et al. (1999) defined 

natural variability as “the ecological conditions and their variability over space and time 

relatively unaffected by people.” The theory behind HRV is that the broad historical 

envelope of possible ecosystem conditions, such as burned area, vegetation cover type 
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area, or patch size distribution, provides a representative time series of reference 

conditions to guide land management (Aplet and Keeton 1999). For the RMP, the term 

“historical” is used to reference the time period prior to European settlement.

HISTORIC RESOURCES or HISTORIC PROPERTY: Any prehistoric or historic district, site, 

building, structure, or object included in, or eligible for inclusion in, the National 

Register. The term includes, for purposes of these regulations, artifacts, records, and 

remains that are related to and located within such properties. The term “eligible for 

inclusion in the National Register” includes both properties formally determined as such 

by the Secretary of the Interior and all other properties that meet National Register 

listing criteria (quoted from 36 CFR 800.2(e); compare National Historic Preservation 

Act, Section 301, Appendix 5). (See also “cultural resource-cultural property.” 

“Cultural property” is an analogous BLM term not limited by National Register status.) 

(M-8100-1, BLM Cultural Resources Management) The term can also refer to cultural 

properties that have a period of use between Euro-American settlements to present.

HYDROLOGIC CONDITION: The current state of the processes controlling the yield, timing 

and quality of water in the watershed. Each physical and biologic process that regulates 

or influences stream flow and groundwater character has a range of variability 

associated with the rate or magnitude of energy and mass exchange. At any point in 

time, each of these processes can be defined by their current rate or magnitude relative 

to the range of variability associated with each process. Integration of all processes at 

one time represents hydrologic condition.

IMPLAN: The IMPLAN Model is an input-output impact model system which provides users 

with the ability to define industries, economic relationships and projects to be analyzed. 

This can be used to assess the economic impacts of resource management decisions, 

facilities, industries, or changes in their level of activity in a given area. The current 

IMPLAN input-output database and model is maintained and sold by MIG, Inc. 

(Minnesota IMPLAN Group).

IMPACTS (or EFFECTS): Environmental consequences (the scientific and analytical basis for 

comparison of alternatives) as a result of a proposed action. Effects may be either direct, 

which are caused by the action and occur at the same time and place, or indirect, which 

are caused by the action and are later in time or farther removed in distance, but are still 

reasonably foreseeable, or cumulative. (BLM National Management Strategy for OHV 

Use on Public Lands)

IMPLEMENTATION DECISIONS: Decisions that take action to implement LUP decisions; 

generally appealable to the Interior Board of Land Appeals under 43 CFR 4.410. (H1601-1, BLM Land Use Planning Handbook)

IMPLEMENTATION PLAN: An area or site-specific plan written to implement decisions 

made in a LUP. Implementation plans include both activity plans and project plans. (H1601-1, BLM Land Use Planning Handbook)
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IMPORTANT VALUE: As related to ACECs, a relevant value, resource, system, process, or 

hazard that has substantial significance and values. This generally requires qualities of 

more than local significance and special worth, consequence, meaning, distinctiveness, 

or cause for concern. A natural hazard can be important if it is a significant threat to 

human life or property. (43 CFR 1610.7-2(a) (2)).

INDIAN TRUST ASSETS: Lands, natural resources, money or other assets held by the federal 

government in trust for that are restricted against alienation for Indian tribes and 

individual Indians.

INDIAN TRUST RESOURCES: Lands and interests in lands, minerals, natural resources, or 

other physical assets held in trust by the federal government for beneficial owners and 

natural resources in which Indian tribes have federally protected or reserved interests 

(e.g. water, fish, wildlife, vegetation).

INDICATOR (species): Components of a system whose characteristics (presence or absence,

quantity, distribution) are used as an index of an attribute (e.g., rangeland health 

attribute) that are too difficult, inconvenient, or expensive to measure. (Interagency 

Technical Reference 1734-8, 2000) (H-4180-1, BLM Rangeland Health Standards 

Manual)

INHOLDING: A nonfederal parcel of land that is completely surrounded by federal land.

INTEGRATED PEST MANAGEMENT (IPM): A long-standing, science-based, decisionmaking process that identifies and reduces risks from pests and pest management 

related strategies. It coordinates the use of pest biology, environmental information, and 

available technology to prevent unacceptable levels of pest damage by the most 

economical means, while posing the least possible risk to people, property, resources, 

and the environment. IPM provides an effective strategy for managing pest in all arenas 

from developed agricultural, residential, and public areas to wild lands. IPM serves as 

an umbrella to provide an effective, all encompassing, low-risk approach to protect 

resources and people from pests. BLM Departmental Manual 517 (Pesticides) defines 

integrated pest management as "a sustainable approach to managing pest by combining 

biological, cultural, physical, and chemical tools in a way that minimizes economic, 

health, and environmental risks. 

INTEGRATED WEED MANAGEMENT (IWM): This is a decision support system involving 

deliberate selections, integration, and implementation of effective weed management 

tactics. It utilizes cost/benefit analysis and takes into consideration public interests and 

social, economical, and ecological impacts in the decision making process.

INTERDISCLIPLINARY TEAM: Staff specialists representing identified skill and knowledge 

needs working together to resolve issues and provide recommendations to an authorized 

officer. (H-4180-1, BLM Rangeland Health Standards Manual)

INTERIM MANAGEMENT POLICY (IMP): An interim measure governing lands under 

wilderness review. This policy (H-8550-1) protects wilderness study areas from 

impairment of their suitability as wilderness.
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INTERIOR BOARD OF LAND APPEALS (IBLA): The DOI Office of Hearings and Appeals 

Board acts for the Secretary of the Interior in responding to appeals of decisions on the 

use and disposition of public lands and resources. Because the IBLA acts for and on 

behalf of the Secretary of the Interior, its decisions usually represent the Department’s 

final decision but are subject to the courts.

INTERMITTENT STREAM: A stream that flows only at certain times of the year when it 

receives water from springs or from some surface sources such as melting snow in 

mountainous areas. During the dry season and throughout minor drought periods, these 

streams will not exhibit flow. Geomorphological characteristics are not well defined and 

are often inconspicuous. In the absence of external limiting factors, such as pollution 

and thermal modifications, species are scarce and adapted to the wet and dry conditions 

of the fluctuating water level.

INVASIVE NON-NATIVE SPECIES (INNS): See invasive plants and species

INVASIVE PLANTS AND SPECIES: Plants and/or organisms that have been introduced into 

an environment where they did not evolve. Executive Order 13112 focuses on organism 

whose presence is likely to cause economic harm, environmental harm, or harms to 

human health.

INVASIVE WEEDS – NOXIOUS WEEDS: Non-native invasive plants that are fast spreading 

and often expensive or difficult to control. Noxious weeds may proliferate, forming 

mono-cultures, which can crowd out other plants that provide biodiversity.

JURISDICTION: The legal right to control or regulate use of a transportation facility. 

Jurisdiction requires authority, but not necessary ownership.

K FACTOR: A soil erodibility factor used in the universal soil loss equation that is a measure 

of the susceptibility of soil particles to detachment and transport by rainfall and runoff. 

Estimation of the factor takes several soil parameters into account, including soil 

texture, percent of sand greater than 0.10 millimeter, soil organic matter content, soil 

structure, soil permeability, clay mineralogy, and coarse fragments. K factor values 

range from .02 to .64, the greater values indicating the highest susceptibilities to 

erosion.

KARST TOPOGRAPHY: Karst is a landscape shaped by the dissolution of a layer or layers of 

soluble bedrock usually carbonate rock such as limestone or dolomite. Due to 

subterranean drainage, there may be very limited surface water, even to the absence of 

all rivers and lakes or perennial streams. Many karst regions display distinctive surface 

features, with sinkholes or dolines being the most common. Some karst regions include 

thousands of caves, even though evidence of caves that are big enough for human 

exploration is not a required characteristic of karst.

LAND CLASSIFICATION: A process for determining the suitability of public lands for 

certain types of disposal or lease under the public land laws or for retention under 

multiple use management. 
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Glossary 21

LAND TENURE ADJUSTMENTS: Ownership or jurisdictional changes are referred as “Land 

Tenure Adjustments.” To improve the manageability of the BLM lands and their 

usefulness to the public, the BLM has numerous authorities for repositioning lands into 

a more consolidated pattern, disposing of lands, and entering into cooperative 

management agreements. These land pattern improvements are completed primarily 

through the use of land exchanges but also through exchange, sale, purchase, donation, 

or other authority, and through the use of cooperative management agreements and 

leases.

LAND TENURE ADJUSTMENT CATEGORY: The designation of an analyzed tract of land 

for retention or manner of disposal based upon resource values, or public access. 

 Category I: Lands managed in Category I – Retention would include all 

ACECs, WSAs, Lands with Wilderness Characteristics, archeological 

sites/historic districts, and lands acquired through LWCF, National Historic 

Trails, National Monuments or other congressionally-designated areas. Lands 

within Category I would not be transferred from BLM management by any 

method for the life of the plan.

 Category II: Retention/Limited Land Ownership Adjustment (no land disposals 

through sale). Public lands within Category II would not be available for sale 

under section 203 of FLPMA. However, lands within this category could be 

exchanged for lands or interest in lands. Some public lands in Category II may 

contain resource values protected by law or policy. If actions cannot be taken to 

adequately mitigate impacts from disposal of those lands, those parcels would be 

retained. 

 Category III (Disposal – land ownership adjustments, including sale): These 

lands generally have low or unknown resource values or are isolated or 

fragmented from other public land ownerships making them difficult to manage. 

Public land parcels in this category are relatively smaller in size (typically 160 

acres or less). A listing of the legal descriptions of these disposal parcels can be 

found at the end of this Appendix (under Legal Descriptions of Disposal Tracts 

by Alternative). These parcels have been found to potentially meet the sale 

criteria of section 203(a)(1) of FLPMA and could be made available for sale, 

however, exchange could have priority over disposal by FLPMA sale.

LAND USE ALLOCATION: The identification in a land use plan of the activities and 

foreseeable development that are allowed, restricted, or excluded for all or part of the 

planning area, based on desired future conditions (from H-1601-1, BLM Land Use 

Planning Handbook).

LAND USE PLAN: A set of decisions that establish management direction for land within an 

administrative area, as prescribed under the planning provisions of FLPMA; an 

assimilation of land use plan level decisions developed through the planning process 

outlined in 43 CFR 1600, regardless of the scale at which the decisions were developed. 

The term includes both RMPs and management framework plans (MFPs). (H-1601-1, 

BLM Land Use Planning Handbook)
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LAND USE PLAN BOUNDARY: The geographic extent of a resource management plan.

LAND USE PLAN DECISION: Establishes desired outcomes and actions needed to achieve 

them. Decisions are reached using the planning process in 43 CFR 1600. When they are 

presented to the public as proposed decisions, they can be protested to the BLM 

Director. They are not appealable to Interior Board of Land Appeals.

LANDS WITH WILDERNESS CHARACTERISTICS (LWC): Lands that have been 

inventoried under the provisions of BLM Manual Section 6300-1 and 6300-2 and found 

to contain wilderness characteristics as defined by section 2(c) of the Wilderness Act of 

1964. If found to possess wilderness characteristics, these lands may be designated as 

“Wild Lands”. 

LATE SEASON: Late summer or fall grazing.

LEASABLE MINERALS: Those minerals or materials designated at leasable under the 

Mineral Leasing Act of 1920. They include coal, phosphate, asphalt, sulphur, potassium 

and sodium minerals; and oil, gas, and geothermal.

LEASE: Section 302 of FLPMA provides the BLM’s authority to issue leases for the use, 

occupancy, and development of public lands. Leases are authorizations to possess and 

use public lands for fixed periods of time. Land uses which may be authorized by lease 

are those involving substantial construction, development, or land improvement and the 

investment of large amounts of capital which is to be amortized over time. A lease

conveys a possessory interest and is revocable only in accordance with its terms and the 

provisions of 43 CFR 2920.1-1(a). There are no limitations on the amount of land that 

may be included in a lease, however the area should be limited to the size justified. Also 

see Permits.

LEASE STIPULATION (Oil & Gas): Conditions of lease issuance that provide protection for 

other resource values or land uses by establishing authority for substantial delay or site 

changes or the denial of operations within the terms of the lease contract. The 

authorized officer has the authority to relocate, control timing, and impose other 

mitigation measures under Section 6 of the Standard Lease Form. Lease stipulations 

clarify the Bureau’s intent to protect known resources or resource values.

LEK: An assembly area where birds, especially sage-grouse, carry on display and courtship 

behavior. Also referred to as a “strutting ground”. The following are the definitions of 

lek terminology when applied to trends and monitoring of leks from Montana Fish, 

Wildlife, and Parks:

 Unconfirmed - Single count with no subsequent survey or a reported lek 

without supporting survey data.

 Confirmed Active - Data supports existence of lek. Supporting data defined as: 

a) minimum of 2 years with 2 or more males lekking on site (preferred) or b) 

1 year with 2 or more males lekking on site followed with evidence of lekking 

(vegetation trampling, feathers, and droppings) during subsequent year.
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 Confirmed Inactive - 10 years with no males or sign of lek activity - supported 

by surveys conducted during 3 or more years over the last 10 years. Sage grouse 

abundance patterns have generally fit within a 10-year time frame, 

encompassing both years of abundance and relative scarcity. For the purpose of 

assigning lek status, 10 years with 3 years of supporting data is minimal for 

characterizing a lek as inactive. However, the capacity for surveying leks at a 

greater annual frequency in 10 years is generally limited and therefore this 

Status Definition incorporates both biological (i.e., past abundance patterns) and 

current administrative factors.

 Confirmed Extirpated - Habitat changes have caused birds to permanently 

abandon a lek (e.g., plowing, urban development, overhead power- line).

LIMITED AREAS: Designated areas where the use is subject to restrictions, such as limiting 

the number or types or vehicles allowed, dates and times of use (seasonal restrictions), 

limiting use to existing roads and trails, limiting use to designated roads and trails 

where use would be allowed only on roads and trails that are signed for use, or limited 

to administrative use. Combinations of restrictions are possible, such as limiting use to 

certain types of vehicles during certain times of the year (BLM National Management 

Strategy for OHV Use on Public Lands).

LU (Land Utilization) PROJECT LANDS (also referred to as Acquired Lands or BankheadJones Lands): Formerly privately owned sub-marginal farmlands incapable of 

producing sufficient income to support the family of a farm owner and acquired by the 

United States, purchased under Title III of the Bankhead-Jones Farm Tenant Act of July 

22, 1937. These acquired lands became known as land utilization projects and were 

subsequently transferred from jurisdiction of the USDA to the USDOI. They are now 

administered by the BLM.

MECHANIZED TRAVEL: Moving by means of mechanical devices, such as a bicycle; not 

powered by a motor. 

MINE: An opening or excavation in the earth for extracting minerals.

MINERAL: Any naturally formed inorganic material, solid or fluid inorganic substance that 

can be extracted from the earth, any of various naturally occurring homogeneous 

substances (as stone, coal, salt, sulfur, sand, petroleum, water, or natural gas) obtained 

usually from the ground. Under federal laws, considered as locatable (subject to the 

general mining laws), leasable (subject to the Mineral Leasing Act of 1920), and salable 

(subject to the Materials Act of 1947).

 Leaseable Minerals: Those minerals or materials designated as leasable under 

the Mineral Leasing Act of 1920, as amended. Leaseable minerals include such 

solid leaseables as coal, phosphate, asphalt, sulphur, potassium, sodium minerals 

and such fluid leaseables as oil and gas.

o Non-Energy Leasable Minerals: These solid minerals include 

phosphate, sodium, potassium, sulphur, potash, and gilsonite. Most of 
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Proposed Resource Management Plan and Final Environmental Impact Statement

24 Glossary

these non-energy leasables are used to make fertilizer, feed stock 

(mineral supplement for livestock) or other industrial processes. See 43 

CFR 3500 for more information on non-energy leasable minerals.

 Locatable Minerals: Minerals subject to exploration, development, and 

disposal by staking mining claims as authorized by the Mining Law of 1872, as 

amended. This includes deposits of gold, silver, and other uncommon minerals 

not subject to lease or sale.

 Saleable Minerals or Mineral Materials: Common materials such as sand and 

gravel and common varieties of stone, pumice, pumicite, and clay that are not 

obtainable under the mining or leasing laws but that can be acquired under the 

Materials Act of 1947, as amended, through sales or special permits.

MINERAL ENTRY: The filing of a claim on public land to obtain the right to any locatable 

minerals it may contain.

MINERAL ESTATE: The ownership of minerals, including rights necessary for access, 

exploration, development, mining, ore dressing, and transportation operations. 

MINIMIZATION MITIGATION: Minimizing impacts by limiting the degree or magnitude of 

the action and its implementation. (40 CFR 1508.20(b))

MINIMIZE: To reduce the adverse impact of an operation to the lowest practical level.

MINING CLAIM: A parcel of land that a miner takes and holds for mining purposes, having 

acquired the right of possession by complying with the Mining Law and local laws and 

rules. A mining claim may contain as many adjoining locations as the locator may make 

or buy. There are four categories of mining claims: lode, placer, millsite, and tunnel 

site.

MITIGATION: A measure that will result in a physical change to the proposed action that will 

actually reduce or eliminate impacts. CEQ NEPA regulations identify five types of 

measures to deal with significant environmental effects: (1) avoiding the impact 

altogether by not taking a certain action or parts of an action; (2) minimizing an impact 

by limiting the degree or magnitude of the action and its implementation; (3) rectifying 

the impact by repairing, rehabilitating, or restoring the affected environment; (4) 

reducing or eliminating the impact over time by preservation and maintenance; or (5) 

compensating for the impact by replacing or providing substitute resources or 

environments.

MONITORING: Observations, data collection, and studies that evaluate compliance of on-the 

ground management with the RMP direction, or the effectiveness of RMP-prescribed 

management direction, in meeting broader goals objectives. Monitoring evaluates 

whether actions (1) comply with NEPA decisions that have been implemented; (2) 

achieve the desired objectives (e.g. effectiveness); and (3) are based on accurate 

assumptions (e.g., validation).
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Proposed Resource Management Plan and Final Environmental Impact Statement

Glossary 25

MOTORIZED: Any machine activated by a nonliving power source, except that small batterypowered, hand-carried devices such as flashlights, shavers, and Geiger counters are not 

classed as motorized equipment. (examples: ATV/OHV, motorcycles, cars, trucks, etc.) 

MULTIPLE USE: The management of the public lands and their various resource values so 

that they are used in the combination that will best meet the present and future needs of 

the American people; making the most judicious use of the land for some or all of these 

resources or related services over areas large enough to provide sufficient latitude for 

periodic adjustments in use to changing needs and conditions; the use of some land for 

less than all of the resources; a combination of balanced and diverse resource uses that 

takes into account the long-term needs of future generations for renewable and 

nonrenewable resources, including recreation, range, timber, minerals, watershed, 

wildlife and fish, and natural scenic, scientific and historical values; and harmonious 

and coordinated management of the various resources without permanent impairment of 

the productivity of the land and the quality of the environment with consideration being 

given to the relative values of the resources and not necessarily to the combination of 

uses that will give the greatest economic return or the greatest unit output (FLPMA) 

(BLM Manual 6840, Special Status Species Manual).

NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) of 1969: An Act which encourages 

productive and enjoyable harmony between man and his environment; promotes efforts 

to prevent or eliminate damage to the environment and biosphere and stimulate the 

health and welfare of man; enriches the understanding of the ecological systems and 

natural resources important to the Nation; and establishes a CEQ (BLM National 

Management Strategy for OHV Use on Public Lands)

NATIONAL REGISTER: The National Register of Historic Places, expanded and maintained 

by the Secretary of Interior, as authorized by Section 2(b) of the Historic Sites act and 

Section 101(a)(1)(A) of the National Historic Preservation Act. The National Register 

lists cultural properties found to qualify for inclusion because of their local, state, or 

national significance. Eligibility criteria and nomination procedures are found in 36 

CFR Part 60. The Secretary’s administrative responsibility for the National Register is 

delegated to the National Park Service. (M-8100-1, BLM Cultural Resource 

Management) 

NATIONAL WILD AND SCENIC RIVERS SYSTEM: A system of nationally designated 

rivers and their immediate environments that have outstanding scenic, recreational, 

geologic, fish and wildlife, historic, cultural, and other similar values and are preserved 

in a free-flowing condition. The system consists of three types of streams: (1) 

recreational—rivers or sections of rivers that are readily accessible by road or railroad 

and that may have some development along their shorelines and may have undergone 

some impoundments or diversion in the past; (2) scenic—rivers or sections of rivers 

free of impoundments with shorelines or watersheds still largely undeveloped but 

accessible in places by roads; and (3) wild—rivers or sections of rivers free of 

impoundments and generally inaccessible except by trails, with watersheds or

shorelines essentially primitive and waters unpolluted.
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26 Glossary

NATIVE AMERICAN TRIBE: Any Native American group in the coterminous United States 

that the Secretary of the Interior recognizes as possessing tribal status (listed 

periodically in the Federal Register). (H-1601, BLM Land Use Planning Handbook)

NATURALNESS: Lands and resources affected primarily by the forces of nature where the 

imprint of human activity is substantially unnoticeable in an area of 5,000 acres or 

greater. BLM has authority to inventory, assess, and/or monitor the attributes of the 

lands and resources on public lands, which, taken together, are an indication of an 

area’s naturalness. These attributes may include the presence or absence of roads and 

trails, fence and other improvements; the nature and extent of landscape modifications; 

the presence of native vegetation communities; and the connectivity of habitats (from 

IM-20030275, change 1, Considerations of Wilderness Characteristics in LUP, 

Attachment 1). 

NEOTROPICAL MIGRATORY BIRDS: Birds that winter in Central America, South America, 

the Caribbean, and Mexico and then return to the United States and Canada during 

spring to breed. Includes almost half of the bird species that breed in the United States 

and Canada.

NET CONSERVATION GAIN: The actual benefit or gain above baseline conditions.

NONFUNCTIONING CONDITION: (1) Condition in which vegetation and ground cover are 

not maintaining soil conditions that can sustain natural biotic communities. (2) 

Riparian-wetland areas are considered to be in nonfunctioning condition when they do 

not provide adequate vegetation, landform, or large woody debris to dissipate stream 

energy associated with high flows and thus are not reducing erosion, improving water 

quality, or other normal characteristics of riparian areas. The absence of a floodplain 

may be an indicator of nonfunctioning condition. (H-4180-1, BLM Rangeland Health 

Standards Manual)

NO SURFACE OCCUPANCY: A fluid mineral leasing constraint that prohibits occupancy or 

disturbance on all or part of the lease surface to protect special values or uses. Lessees 

may exploit the fluid mineral resources under the leases restricted by this constraint 

through use of directional drilling from sites outside the area. Leasing with “no surface 

occupancy” means that there will be no development or disturbance whatsoever of the 

land surface, including establishment of wells or well pads, and construction of roads, 

pipelines, or power lines.

NOXIOUS WEED: A plant species designated by federal or state law and county weed boards, 

are non-native species that generally possess one or more of the following 

characteristics: aggressive and difficult to manage; parasitic; aggressive and difficult to 

manage; parasitic; a carrier or host of serious insects or disease; or non-native, new, or 

not common to the United States. 

OBJECTIVE: A description of a desired outcome for a resource. Objectives can be quantified 

and measured and, where possible, have established timeframes for achievement.
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Glossary 27

OFF-HIGHWAY VEHICLE or OFF-ROAD VEHICLE: Off-road vehicle (OHV) means any 

motorized vehicle designed for or capable of cross-country travel on or immediately 

over land, water, sand, now, ice, marsh, swampland, or other natural terrain; except that 

such term excludes: (1) any registered motorboat, (2) any fire, emergency, or law 

enforcement vehicle when used for emergency operations, and any combat or combat 

support vehicle when used for national defense purposes, and (3) any vehicle whose 

uses is expressly authorized by the respective agency head under a permit, lease, 

license, or contract (E.O. 11644).

OFF-ROAD VEHICLE DESIGNATIONS:

 Open: Designated areas and trails where off-road vehicles may be operated, subject to 

operating regulations and vehicle standards set forth in BLM Manuals 8341 and 8343; 

or an area where all types of vehicle use is permitted at all times, subject to the 

standards in BLM Manuals 8341 and 8343.

 Limited: Designated areas and trails where use of off-road vehicles is subject to 

restrictions, such as limiting the number or types of vehicles allowed, dates and times of 

use (seasonal restrictions), limiting use to existing roads and trails, or limiting use to

designated roads and trails designation, use would be allowed only on roads and trails 

that are signed for use. Combinations of restrictions are possible, such as limiting use 

to certain types of vehicles during certain times of the year.

 Closed: Designated areas and trails where the use of off-road vehicles is permanently 

or temporarily prohibited. The use of off-road vehicles in closed area may be allowed 

for certain reasons; however, such sue shall be made only with the approval of the 

authorized officer.

OFFICIAL USE: Use by an employee, agent, or designated representative of the Federal 

Government or one of its contractors, in the course of his employment, agency, or 

representation. (BLM National Management Strategy for OHV Use on Public Lands)

OLD FOREST STRUCTURE: Physical forest or woodland characteristics that contribute to the 

structure, composition, or function of forested stands for a particular forest type. These 

characteristics include large and old tree components, accumulation of dead wood 

components such as standing snags and/or downed logs, occurrence of climax plant 

species or seral trees with a common decadent attributes such as broken or deformed 

tops and rotten boles, wide variation in tree age classes and stocking levels, and 

multiple canopy layers.

OLD GROWTH: Forested stands in late successional stages of development meeting the main 

characteristics or old forest structures that are described by the forest type for the Eastside Montana Zone in Old-Growth Forest Types of the Northern Region (Green, 1992).

OPEN AREA: An area where all types of vehicle use is permitted at all times, anywhere in the 

area subject to the operating regulations and vehicle standards set forth in 43 CFR 8341 

and 8342. 
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OPERATOR: An operator is one who has authorization from the BLM to conduct activity on 

public land.

OUTSTANDINGLY REMARKABLE VALUES: Values among those listed in Section 1(b) of 

the WSR Act of 1968: “scenic, recreational, geological, fish and wildlife, historical, 

cultural, or other similar values....” Other similar values that may be considered include 

ecological, biological, or botanical.

OVER-SNOW VEHICLE: An over-snow vehicle (OSV) is defined as a motor vehicle that is 

designed for use over snow that runs on a track ot tracks and/or skis, while in use over 

snow. An over-snow vehicle does not include machinery used strictly for the grooming 

on non-motorized trails.

OVERSTOCKED: The situation in which trees are so closely spaced that they compete for 

resources and do not reach full growth potential.

OVERSTORY: That portion of the trees, in a forest of more than one story, forming the upper

or uppermost canopy layer. 

OZONE: Ozone is created and destroyed primarily by ultraviolet radiation.. When high-energy 

ultraviolet rays strike molecules of ordinary oxygen (O2), they split the molecule into 

two single oxygen atoms, known as atomic oxygen (O). A freed oxygen atom then can 

combine with an oxygen molecule to form a molecule of ozone (O3). In atmospheres 

containing nitrogen oxides (NOx, a common pollutant) and volatile organic compounds 

(VOCs), ozone can be created in the presence of sunlight. Although ozone is critical in 

the high atmosphere to protect against ultraviolet (UV) light, low level ozone is 

implicated in impacts as diverse as crop damage and increased incidence of asthma and 

other respiratory complaints. 

PALEONTOLOGICAL RESOURCES: Paleontological resource means any fossilized remains, 

traces, or imprints of organisms, preserved in or on the earth’s crust, that are of 

paleontological interest and that provide information about the history of life on earth, 

except that the term does not include (a) any materials associated with an archaeological 

resource (as defined in Section 3(1) of the Archaeological Resources Protection Act of 

1979 (16 U.S.C. 470bb(1)); or (b) any cultural item (as defined in Section 2 of the 

Native American Graves Protection and Repatriation Act (24 U.S.C. 3001 et seq.)). 

PERENNIAL STREAM: A stream that flows continuously. Perennial streams are generally 

associated with a water table in the localities through which they flow.

PERMIT: A short-term, for up to 3 years, revocable authorization to use public lands for 

specific purposes. Section 302 of FLPMA provides BLM’s authority to issue permits 

for the use, occupancy, and development of the public lands. Permit land uses involve 

either little or no land improvement or construction, or investment which can be 

amortized within the terms of the permit. A permit conveys no possessory interest. The 

authorized officer may renew it at his/her discretion or revoke it in accordance with its 

terms or the provisions of 43 CFR 2920.1-1(b). Also see Leases. 
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PERMITTEE: Holder of a valid permit that authorizes grazing use of the public lands within 

the grazing district, Also a holder of a Special Recreation Permit (SRP) for commercial, 

competitive, organized or vending activities for recreational uses being conducted on 

public lands. Also a holder of a commercial filming permit issued by the BLM for 

filming activities conducted on public lands. 

PERMITTED USE: The forage allocated by, or under the guidance of, an applicable land use 

plan for livestock grazing in an allotment under a permit or lease and expressed in 

AUMs (43 CFR § 4100.0-5) (from H-4180-1, BLM Rangeland Health Standards 

Manual).

PETROGLYPH: A figure, design, or indentation carved, abraded, or pecked on natural rock 

surfaces. 

PICTOGRAPH: A figure or design, colored with charcoal or natural mineral pigments, painted 

onto a rock.

PLANNING AREA: A geographical area for which land use and resource management plans 

are developed and maintained.

PLANNING CRITERIA: The standards, rules, and other factors developed by managers and 

interdisciplinary teams for their use in forming judgment about decision making, 

analysis and data collection during planning; planning criteria streamline and simplify 

the resource management planning actions. (H-1601, BLM Land Use Planning 

Handbook)

PLAT: Map of land parcels. The BLM Master Title Plat system records the size, location and 

ownership status of distinct parcels. The information is derived from warranty deeds 

and is updated as needed. 

PLAY (oil & gas): Defined as a set of known or postulated oil and/or gas accumulations 

sharing similar geologic, geographic and temporal properties such as source rock, 

migration pathway, trapping mechanism, and hydrocarbon type. 

POLE: A tree of a size between a sapling and a mature tree.

POPULATION: Within a species, a distinct group of individuals that tend to mate only with 

members of the group. Because of generations of inbreeding, members of a population 

tend to have similar genetic characteristics.

POTENTIAL FOSSIL YIELD CLASSIFICATION (PFYC): A system of general classification 

based upon the lithology of surface rocks that estimates the likelihood of a given rock 

unit to yield vertebrate or other scientifically important fossil materials.

POTENTIAL TO EMIT (PTE): The maximum capacity of a facility or emitting unit, within 

physical and operational design, to emit a pollutant. Any physical or operational 

limitation on the capacity of the facility or emitting unit to emit a pollutant, including 

air pollution control equipment and restrictions on hours of operation or on the type or 
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Proposed Resource Management Plan and Final Environmental Impact Statement

30 Glossary

amount of material combusted, stored, or processed, is treated as part of its design only 

if the limitation or the effect it would have on emissions is federally enforceable. 

POWER SITE CLASSIFICATION: A classification made by the Federal Power Commission 

that is a segregate against the operation of the public laws for lands that are needed or 

have potential for power projects and associated transmission lines. Lands classified to 

benefit transmission lines are open to the operation of the public land laws subject to 

their use for transmission lines.

POWER SITE RESERVE: A reservation of public lands that have potential value for power 

development.

PRAIRIE DOG HABITAT: The maximum extent of areas occupied by prairie dogs at any 

time during the last 10 years. 

PREFERENCE: A superior or priority position against others for the purpose of receiving a 

grazing permit or lease. This priority is attached to base property owned or controlled 

by the permittee or lessee. (43 CFR 4100.0-5) Active use and suspended use together 

make up permitted use. 

PREHISTORIC: Refers to the period when wherein Native American cultural activities took 

place which was not yet influenced by contact with historic nonnative culture(s). The 

end of this time period varies by region. 

PRESCRIBED FIRE: Any fire ignited by management action to meet specific objectives. A 

written approved fire plan must exist, and NEPA requirements must be met, prior to 

ignition. (H-9214-1, BLM Prescribed Fire Management Handbook)

PREVENTION OF SIGNIFICANT DETERIORATION (PSD): A regulatory program under 

the Clean Air Act (Public Law 84-159, as amended) to limit air quality and AQRV 

degradation in areas currently achieving the National Ambient Air Quality Standards.

The PSD program established air quality classes in which differing amounts of 

additional air pollution are allowed above a legally defined baseline level. Small 

additional air pollution may be considered significant in PSD Class I areas (certain large 

national parks and wilderness areas in existence on August 7, 1977, and specific Tribal 

lands redesignated since then). PSD Class II areas allow deterioration associated with 

moderate, well-controlled growth (most of the country). Area classes are described 

below.

 Class I: an area that allows only minimal degradation above “baseline.” The Clean 

Air Act designated existing national parks over 6,000 acres and national wilderness 

areas over 5,000 acres in existence on August 7, 1977, as mandatory federal Class I 

Areas. These areas also have special visibility protection. In addition, four tribal 

governments have redesignated their lands as Class I Areas.

 Class II: an area that allows moderate degradation above “baseline.” Most of the 

United States (outside nonattainment areas) is Class II.
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Glossary 31

 Class III: any area that allows the maximum amount of degradation above 

“baseline.” Although the U.S. Congress allows air quality regulatory agencies to 

redesignate Class II lands to Class III, none have been designated.

PREVENTION OF SIGNIFICANT DETERIORION (PSD) INCREMENT AND 

INCREMENT ANALYSIS: The allowable PSD increment is the change in pollutant 

concentration allowed in a Class I, Class II, or Class III area. PSD increment values are 

provided in EPA regulations. As performed by the BLM for NEPA analysis, PSD 

increment analysis is a method of comparing predicted (modeled) pollutant 

concentrations to EPA’s allowable PSD increment values for the purpose of public 

disclosure only. The BLM increment analysis is not a regulatory analysis. State air 

quality agencies and the USEPA perform regulatory PSD increment analysis.

PRIMITIVE AND UNCONFINED RECREATION (in regards to designated Wilderness 

Areas): Means non-motorized types of outdoor recreation activities that do not require 

developed facilities or mechanical transport. Mechanical transport means any vehicle, 

device, or contrivance for moving people or material in or over land, water, snow, or air 

that has moving parts. This includes, but is not limited to, sailboats, sailboards, hang 

gliders, parachutes, bicycles, game carriers, carts, and wagons. The term does not 

include wheelchairs, nor does it include horses or other pack stock, skis, snowshoes, 

non-motorized river craft including, but not limited to, drift boats, rafts, and canoes, or 

sleds, travois, or similar devices without moving parts. (43 CFR 6301.5 Definitions.)

There are no designated Wilderness Areas in the Billings Field Office Planning area. 

For lands under Wilderness Review, i.e. Wilderness Study Areas, “No mechanical 

transport, which includes all motorized vehicles plus trail or mountain bikes, will be 

allowed on such trails.” (H-8550-1, Chapter III, § H1) 

PRIMITIVE RECREATION: As defined in the Recreation Opportunity Spectrum (ROS), 

primitive recreation is managed to be essentially free from evidence of humans and 

onsite controls. Motor vehicle use is not permitted. Means of access include hiking, 

cross-country skiing, snowshoeing, non-motorized boating, and horseback riding.

PRIMITIVE ROAD: A linear route managed for use by four-wheel drive or high clearance 

vehicles. Primitive roads do not normally meet any BLM road design standards. 

PRIMITIVE ROUTE: Any transportation linear feature located within areas that have been 

identified as having wilderness characteristics and not meeting the wilderness inventory 

road definition.

PROBABLE SALE QUANTITY (PSQ): The allowable harvest level that can be maintained 

without decline over the long term if the schedule of harvests and regeneration are 

followed. PSQ recognizes a level of uncertainty in meeting the determined level; this 

uncertainty is typically based on other environmental factors that preclude harvesting at 

a particular time (for example, because of watershed or habitat concerns). A PSQ is not 

a commitment to offer for sale a specific level of timber volume every year. 
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Proposed Resource Management Plan and Final Environmental Impact Statement

32 Glossary

PROPERLY FUNCTIONING CONDITION (PFC): (1) An element of the Fundamental of 

Rangeland Health for watersheds and therefore a required element of state or regional 

standard and guidelines under 43 CFR § 4180.2(b). (2) Condition in which vegetation 

and ground cover maintain soil conditions that can sustain natural biotic communities. 

For riparian areas, the process of determining that function is described in BLM 

Technical Reference (TR) 1737-9. Final Environmental Impact Statement at 26, 72. (3) 

Riparian-wetland areas are functioning properly when adequate vegetation, landform, or 

large woody debris are present to dissipate stream energy associated with high-water

flows, thereby reducing erosion and improving water quality; filter sediment, capture 

bed load, and aid floodplain development; improve floodwater retention and 

groundwater recharge; develop root masses that stabilize streambanks against cutting 

action; develop diverse ponding and channel characteristics to provide the habitat and 

the water depth, duration, and temperature necessary for fish production, waterfowl 

breeding, and other uses; and support greater biodiversity. The functioning condition of 

riparian-wetland areas is influenced by geomorphic features, soil, water, and vegetation. 

(4) Uplands function properly when the existing vegetation and ground cover maintain 

soil conditions capable of sustaining natural biotic communities. The functioning 

condition of uplands is influenced by geomorphic features, soil, water, and vegetation. 

See also “Nonfunctioning Condition and Functioning at Risk” (H-4180-1, BLM 

Rangeland Health Standards Manual).

PROPER FUNCTIONING CONDITION FOR LENTIC AREAS: A riparian-wetland areas are 

functioning properly when adequate vegetation, landform, or debris is present to: 

dissipate energies associated with wind action, wave action, and overland flow from 

adjacent sites, thereby reducing erosion and improving water quality; filter sediment 

and aid floodplain development; improve flood-water retention and ground-water 

recharge; develop root masses that stabilize islands and shoreline features against 

cutting action; restrict water percolation; develop diverse ponding characteristics to 

provide the habitat and the water depth, duration, and temperature necessary for fish 

production, waterbird breeding, and other uses; and support greater biodiversity.

PROPER FUNCTIONING CONDITION FOR LOTIC AREAS: A riparian-wetland area is 

considered to be in proper functioning condition when adequate vegetation, landform, 

or large woody debris is present to:

 Dissipate stream energy associated with high waterflow, thereby reducing 

erosion and improving water quality;

 Filter sediment, capture bedload, and aid floodplain development;

 Improve flood-water retention and ground-water recharge;

 Develop root masses that stabilize streambanks against cutting action;

 Develop diverse ponding and channel characteristics to provide the habitat and 

the water depth, duration, and temperature necessary for fish production, 

waterfowl breeding, and other uses;

 Support greater biodiversity.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Glossary 33

PROPOSED SPECIES: Species that have been officially proposed for listing as threatened or 

endangered by the Secretary of the Interior. A proposed rule has been published in the 

Federal Register. (M-6840, Special Status Species Manual)

PRYOR MOUNTAIN WILD HORSE RANGE (PMWHR): The combination of agency (BLM, 

USFS, and NPS) and private rangelands authorized for use by wild horses. Not to be

confused with WILD HORSE RANGE (see definition below) which is a special 

designation of which only the BLM portion of the PMWHR has this status. 

PUBLIC LAND: Any land and interest in land owned by the United States and administered by 

the Secretary of the Interior through the Bureau of Land Management, without regard to 

how the United States acquired ownership, except lands located on the Outer 

Continental Shelf and land held for the benefit of Indians, Aleuts, and Eskimos. (from 

H-1601-1, BLM Land Use Planning Handbook and BLM Public Land Statistics).

PULPWOOD: Roundwood, whole-tree chips, or wood residues that are used for the production 

of wood pulp.

RANGE IMPROVEMENT: An authorized physical modification or treatment which is 

designed to improve production of forage; change vegetation composition; control 

patterns of use; provide water; stabilize soil and water conditions; restore, protect and 

improve the condition of rangeland ecosystems to benefit livestock, wild horses and 

burros, and fish and wildlife. The term includes, but is not limited to, structures, 

treatment projects, and use of mechanical devices or modifications achieved through 

mechanical means. (43CFR 4100.0-5) (H-4180-1, BLM Rangeland Health Standards 

Manual)

RANGELAND: A kind of land on which the native vegetation, climax or natural potential 

consists predominantly of grasses, grasslike plants, forbs, or shrubs. Rangeland includes 

lands revegetated naturally or artificially to provide a noncrop plant cover that is 

managed like native vegetation. Rangeland may consist of natural grasslands, 

savannahs, shrublands, most deserts, tundra, alpine communities, coastal marshes, and 

wet meadows. (H-4180-1, BLM Rangeland Health Standards Manual)

RAPTOR: A group of predatory avian species (e.g., hawks, eagles, falcons, and owls) also 

referred to as birds of prey, which share various physical characteristics (e.g., sharp 

talons, strongly curved bill).

REASONABLE FORESEEABLE DEVELOPMENT (RFD) SCENARIO: The prediction of 

the type and amount of oil and as activity that would occur in a given area. The 

prediction is based on geologic factors, past history of drilling, projected demand for oil 

and gas, and industry interest.

RECLAMATION: Actions taken to restore damaged lands to Proper Functioning Condition 

including removal of structures, replacement or regrading of topsoil, tilling of 

compacted soils to allow infiltration of air and water, installation of erosion control 

structures, seeding or planting of native vegetation and integrated pest management to 

control invasive species. 
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34 Glossary

RECORD OF DECISION (ROD): A document signed by a responsible official recording a 

decision that was preceded by the preparing of an EIS.

RECREATION EXPERIENCE: Psychological outcomes realized either by recreation-tourism 

participants as a direct result of their on-site leisure engagements and recreation-tourism 

activity participation or by nonparticipating community residents as a result of their 

interaction with visitors and guests within their community or interaction with the BLM 

and other public and private recreation-tourism providers and their actions.

RECREATION AND PUBLIC PURPOSES (R&PP) ACT of 1926: The objective of the R&PP 

Act is to meet the needs of state and local government agencies and nonprofit 

organizations by leasing or conveying public land required for recreation and public 

purpose uses. 

RECREATION MANAGEMENT ZONES: The recreation management zones are delineated 

for specific recreation opportunities, predominate recreation and visitor services focus, 

and recreation setting characteristics for long term management. 

RECREATION NICHE: The place or position within the strategically targeted recreationtourism market for each SRMA that is most suitable (i.e., capable of producing certain 

specific kinds of recreation opportunities) and appropriate (i.e., most responsive to 

identified visitor or resident customers), given available supply and current demand, for 

the production of specific recreation opportunities and the sustainable maintenance of 

accompanying natural resource or community setting character.

RECREATION SETTING CHARACTERISTICS MATRIX: More than 1⁄2 mile from either 

mechanized or motorized routes; undisturbed natural landscape; no structures, 

foot/horse and water trails only; fewer than three (3) encounters/day at campsites and 

fewer than six (6) encounters/day on travel routes; fewer than or equal to three (3) 

people per group; no alternation of the natural terrain; footprints only observed; and 

sounds of people rare.

RECREATION OPPORTUNITIES: Favorable circumstances enabling visitors’ engagement in 

a leisure activity to realize immediate psychological experiences and attain more 

lasting, value-added beneficial outcomes.

RECREATION OPPORTUNITY SPECTRUM (ROS): A framework for inventorying, 

planning, and managing recreational opportunities. ROS is divided into six classes: 

primitive, semi-primitive non-motorized, semi-primitive motorized, roaded natural, 

rural, and urban. This system has been replaced by the Recreation Setting 

Characteristics Matrix.

RECREATIONAL RIVER: Those rivers or sections of rivers that are readily accessible by 

road or railroad, that may have some development along their shorelines, and that may 

have undergone some impoundment or diversion in the past.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Glossary 35

RECREATION SETTINGS: The collective distinguishing attributes of landscapes that 

influence and sometimes actually determine what kinds of recreation opportunities are 

produced.

RECREATION SETTING CHARACTER: The distinguishing recreational qualities of any 

landscape, objectively defined along a continuum, ranging from primitive to urban 

landscapes, expressed in terms of the nature of the component parts of its physical, 

social, and administrative attributes. These recreational qualities can be both classified 

and mapped. This classification and mapping process should be based on variation that 

either exists (for example, setting descriptions) or is desired (for example, setting 

prescriptions) among component parts of the various physical, social, and 

administrative attributes of any landscape. The recreation opportunity spectrum is one 

of the tools for doing this. Below is a text version of the recreation setting character 

matrix:

 Primitive Classification:

► Physical:

 More than 1⁄2 mile from either mechanized or motorized routes.

 Undisturbed natural landscape.

 No structures. Foot/horse and water trails only. 

► Social:

 Fewer than three encounters/day at camp sites and fewer than 6 

encounters/day on travel routes. 

 Fewer than or equal to three people per group. 

 No alteration of the natural terrain. Footprints only observed. Sounds 

of people rare.

► Operational:

 Foot, horse, and non-motorized float boat travel.

 No maps or brochures available on-site. Staff is rarely present to 

provide on-site assistance.

 No on-site posting/signing of visitor regulations, interpretive 

information or ethics. Few use restrictions

 Back Country Classification 

► Physical:

 Within 1⁄2 mile of four-wheel drive vehicle, ATV and motorcycles 

routes.

 Character of the natural landscape retained. A few modifications 

contrast with character of the landscape (e.g. fences, primitive roads).

 Maintained and marked trails, simple trailhead developments and 

basic toilets.

► Social:

 3-6 encounters/day off travel routes (e.g., campsites) and 7-15 

encounters/day on travel routes 

 4-6 people per group. 
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Proposed Resource Management Plan and Final Environmental Impact Statement

36 Glossary

 Areas of alteration uncommon. Little surface vegetation wear 

observed. Sounds of people infrequent. 

► Operational:

 Mountain bikes and perhaps other mechanized use, but all is nonmotorized.

 Basic maps, staff infrequently present (e.g. seasonally, high use 

periods) to provide on-site assistance.

 Basic user regulations at key access points. Minimum use 

restrictions.

 Middle Country Classification:

► Physical:

 Within 1⁄2 mile of four-wheel drive vehicle, ATV and motorcycles 

routes.

 Character of the natural landscape retained. A few modifications 

contrast with character of the landscape (e.g. fences, primitive roads).

 Maintained and marked trails, simple trailhead developments and 

basic toilets. 

► Social:

 7-14 encounters/day off travel routes (e.g., staging areas) and 15-29 

encounters/ day on travel routes 

 7-12 people per group. 

 Small areas of alteration. Surface vegetation showing wear with 

some bare soils. Sounds of people occasionally heard.

► Operational

 Four-wheel drives, all-terrain vehicles, dirt bikes, or snowmobiles in 

addition to non-motorized, mechanized use.

 Area brochures and maps, staff is occasionally (e.g. most weekends) 

present to provide on-site assistance.

 Some regulatory and ethics signing. Moderate use restrictions. (e.g. 

camping, human waste).

 Front Country Classification

► Physical: 

 Within 1⁄2 mile of low-clearance or passenger vehicle routes (includes 

unpaved County roads and private land routes).

 Character of the natural landscape partially modified but none 

overpower natural landscape (e.g. roads, structures, utilities).

 Rustic facilities such as campsites, restrooms, trailheads, and 

interpretive displays.

► Social:

 15-29 encounters/day off travel routes (e.g., campgrounds) and 30 or 

more encounters/day on travel routes.

 13-25 people per group.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Glossary 37

 Small areas of alteration prevalent. Surface vegetation gone with 

compacted soils observed. Sounds of people regularly heard

► Operational:

 Two-wheel drive vehicles predominant, but also four wheel drives 

and non-motorized, mechanized use.

 Information materials describe recreation areas & activities, staff 

periodically present (e.g. weekdays & weekends).

 Rules, regulations, and ethics clearly posted. Use restrictions, 

limitations, and/or closures.

 Rural Classification 

► Physical: 

 Within 1⁄2 mile of paved/primary roads and highways.

 Character of the natural landscape considerably modified 

(agriculture, residential or industrial).

 Modern facilities such as campgrounds, group shelters, boat 

launches, and occasional exhibits.

► Social:

 People seem to be generally everywhere.

 26-50 people per group.

 A few large areas of alteration. Surface vegetation absent with 

hardened soils. Sounds of people frequently heard.

► Operational:

 Ordinary highway auto and truck traffic is characteristic.

 Information described to the left, plus experience and benefit 

descriptions, staff regularly present (e.g. almost daily).

 Regulations strict and ethics prominent. Use may be limited by 

permit, reservation, etc.

 Urban Classification

► Physical: 

 Within 1⁄2 mile of streets and roads within municipalities and along 

highways.

 Urbanized developments dominate landscape.

 Elaborate full-service facilities such as laundry, restaurants, and 

groceries.

► Social:

 Busy place with other people constantly in view.

 Greater than 50 people per group.

 Large areas of alteration prevalent. Some erosion. Constantly hear 

people.

► Operational:

 Wide variety of street vehicles and highway traffic is ever-present.
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Proposed Resource Management Plan and Final Environmental Impact Statement

38 Glossary

 Information described to the left, plus regularly scheduled on-site 

outdoor demonstrations and clinics.

 Enforcement in addition to rules to reduce conflicts, hazards, and 

resource damage. 

REGENERATION: The act of renewing tree cover by establishing young trees naturally or 

artificially.

REIS: Regional Economic Information System (REIS). This is an information system used by 

the Bureau of Economic Analysis, U.S. Department of Commerce.

RELEVANT VALUE: As related to ACECs, a relevant value is a significant historic, cultural, 

or scenic value; a fish or wildlife resource or other natural system or process; or natural 

hazard. (43 CFR 1610.7-2(a)(1))

RELICT PLANT COMMUNITY: A remnant or fragment of vegetation remaining from a 

former period when the vegetation was more widely distributed.

RE-PLAT: When tracts of land are changed by avulsion or accretion of land due to changes in 

river channels it may be necessary to re-survey and map the altered landscape to reflect 

current conditions. Lots previously described may be removed from the Master Title 

Plat and new lots platted in their place. 

REQUIRED DESIGN FEATURE (RFD): Required Design Features (RDFs) are required for 

certain activities in all GRSG habitat. RDFs establish the minimum specifications for 

certain activities to help mitigate adverse impacts. However, the applicability and 

overall effectiveness of each RDF cannot be fully assessed until the project level when 

the project location and design are known. Because of site-specific circumstances, some 

RDFs may not apply to some projects (e.g., a resource is not present on a given site)

and/or may require slight variations (e.g., a larger or smaller protective area). All 

variations in RDFs would require that at least one of the following be demonstrated in 

the NEPA analysis associated with the project/activity:

 A specific RDF is documented to not be applicable to the site-specific conditions of 

the project/activity (e.g.due to site limitations or engineering considerations). 

Economic considerations, such as increased costs, do not necessarily require that an 

RDF be varied or rendered inapplicable;

 An alternative RDF is determined to provide equal or better protection for GRSG or 

its habitat;

 A specific RDF will provide no additional protection to GRSG or its habitat.

RESERVE ALLOTMENTS: A separate BLM administered grazing unit (allotment or pasture), 

that is reserved for nonrenewable grazing use by permittees/lessees or others 

participating in land restoration or recovery efforts that preclude use of all or part of the 

permitted use assigned to their base property. 

RESERVE COMMON ALLOTMENT: An area which is designated in the land use plan as 

available for livestock grazing, but reserved as an area available for use as an alternative 

to grazing in another allotment in order to facilitate rangeland restoration treatments and 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Glossary 39

recovery from natural disturbances such as drought or wildfire. The reserve common 

allotment would provide needed flexibility that would help the agency apply temporary 

rest from grazing where vegetation treatments and/or management would be most 

effective.

RESIDUAL IMPACTS: Impacts that remain after applying avoidance and minimization 

mitigation; also referred to as unavoidable impacts.

RESILIENCE: The capacity of a plant community or ecosystem to maintain or regain normal 

function and development following disturbance. 

RESOURCE ADVISORY COUNCIL (RAC): A council established by the Secretary of the 

Interior to provide advice or recommendations to BLM management (H-1601-1, BLM 

Land Use Planning Handbook)

RESOURCE MANAGEMENT PLAN (RMP): A land use plan as described by the Federal 

Land Policy and Management Act. The RMP generally establishes in a written 

document: (1) land uses for limited, restricted or exclusive use; designations, including 

ACEC designation; and transfer from BLM administration; (2) allowable resource uses 

(either singly or in a combination) and related levels of production or use to be 

maintained; (3) resource condition goals and objectives to be attained; (4) program 

constraints and general management practices needed to achieve the above items; (5) 

need for an area to be covered by more detailed and specific plans; (6) support action, 

including such measures as resource protection, access, development, realty action, 

cadastral survey, etc., as necessary to meet the above; (7) general implementation 

sequences in which carrying out a planned action; and (8) intervals and standards for 

monitoring and evaluating the plan to determine the effectiveness of the plan and the 

need for amendment or revision. (43 CFR 1601.0-5(k)

REST ROTATION: A grazing system, or plan that rests (and defers) use in specific pasture(s) 

in an allotment on an annual basis. The number of years between rest for a pasture 

depends on the number pastures in the allotment.

REVISION: The process of completely rewriting the land use plan due to changes in the 

planning area affecting major portions of the plan or the entire plan. 

RIGHT-OF-WAY (ROW): Public lands authorized to be used or occupied for specific purposes 

pursuant to a right-of-way grant, which are in the public interest and which require 

ROWs over, on, under, or through such lands. A 44LD513 ROW is a ROW that BLM 

issues to itself.

 Major Rights-of-Way: High-voltage transmission lines (100kV and over) and major 

pipelines (24 inches and over in width)

 Minor Rights-of-Way and Land Use Authorizations/Permits: Communication sites and 

towers

RIGHT-OF-WAY CORRIDOR: A parcel of land that has been identified by law, Secretarial 

order, through a LUP or by other management decision as being the preferred location 
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Proposed Resource Management Plan and Final Environmental Impact Statement

40 Glossary

for existing and future ROW grants and suitable to accommodate one type of ROW or 

one or more ROWs that are similar, identical or compatible. The purpose of establishing 

ROW corridors is to encourage the concentration of utilities in a defined area to reduce 

the proliferation of multiple single-user rights of way, and to reduce the extent of 

environmental impact analysis for each separate right-of-way proposal. 

RIPARIAN AREA: A form of wetland transition between permanently saturated wetlands and 

upland areas. Riparian areas exhibit vegetation or physical characteristics that reflect the 

influence of permanent surface or subsurface water. Typical riparian areas include lands 

along, adjacent to, or contiguous with perennially and intermittently flowing rivers and 

streams, glacial potholes, and the shores of lakes and reservoirs with stable water levels. 

Excluded are ephemeral streams or washes that lack vegetation and depend on free 

water in the soil.

RIVER: As defined in the Wild and Scenic Rivers Act, “river” means a flowing body of water 

or estuary or section, portion, or tributary thereof, including rivers, streams, creeks, 

runs, kills, rills, and small lakes.

ROAD: A linear route declared a road by the owner, managed for use by low clearance 

vehicles having four or more wheels, and maintained for regular and continuous use.

 Closed

 Limited

 Open

 Permanent Road

ROADED NATURAL: As defined in the Recreation Opportunity Spectrum, roaded natural 

recreation is managed to provide a natural-appearing environment with moderate 

evidence of humans. Motor vehicle use is permitted and facilities for this use are 

provided. Activities include wood gathering, downhill skiing, fishing, OHV driving, 

interpretive uses, picnicking, and vehicle camping.

ROCK ART: A generic term used to describe both petroglyphs (carvings) and/or pictographs 

(paintings).

ROTATION: Livestock rotations from one pasture to the next (in an allotment) at specified 

times of the year. 

ROUTES: Multiple roads, trails and primitive roads; a group or set of roads, trails, and 

primitive roads that represents less than 100 percent of the BLM transportation system. 

Generically, components of the transportation system are described as “routes.”

RURAL: As defined in the Recreation Opportunity Spectrum, rural recreation is managed to 

provide a setting that is substantially modified with moderate to high evidence of 

civilization. Motor vehicle use is permitted and visitor conveniences may be provided. 

Activities are facility/vehicle dependent and include sightseeing, horseback riding, road 

biking, golf, swimming, picnicking, and outdoor games.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Glossary 41

SAGE-GROUSE HABITAT – GENERAL HABITAT AREAS: Areas with or without ongoing or imminent impacts containing sage-grouse habitat outside of the priority areas. 

Management actions would maintain habitat for sustainable sage-grouse populations to 

promote movement and genetic diversity. Areas are delineated based on sage-grouse 

habitat. 

SAGE-GROUSE HABITAT – PROTECTION PRIORITY AREAS: Areas with limited 

impacts containing substantial and high quality sage-grouse habitat that support 

sustainable sage-grouse populations. Management actions would emphasize the 

protection and enhancement of sustainable sage-grouse populations. Areas are 

delineated by using “key”, “core” and connectivity data/maps and other resource 

information. 

SAGE-GROUSE HABITAT – RESTORATION AREAS: Areas with on-going or imminent 

impacts containing substantial and high quality sage-grouse habitat that historically 

supported sustainable sage-grouse populations. Management actions would emphasize 

restoration for the purpose of establishing or restoring sustainable sage-grouse 

populations. Areas are delineated by using “key,” “core,” and connectivity data/maps 

and other resource information. 

SAPLING: A young tree larger than a seedling, but smaller than a pole. 

SCENIC BYWAYS: Highway routes that have roadsides or corridors of special aesthetic, 

cultural, or historical value. An essential part of the highway is its scenic corridor. The 

corridor may contain outstanding scenic vistas, unusual geologic features, or other 

natural elements.

SCENIC QUALITY RATINGS: The relative scenic quality (A, B, or C) assigned a landscape 

by applying the scenic quality evaluation key factors; scenic quality A being the highest 

rating, B a moderate rating, and C the lowest rating. The evaluation factors are 

landform, vegetation, water, color, adjacent scenery, scarcity, and cultural 

modifications. (M-8400, Visual Resource Management)

SCENIC RIVER: A river or section of a river that is free of impoundments and whose 

shorelines are largely undeveloped but accessible in places by roads.

SCOPING: An early and open process for determining the scope of issues to be addressed and 

or identifying the significant issues related to a proposed action. This effort involves the 

participation of affected federal, state, and local agencies, and any affected Native 

American tribe, the proponent of the action, and other interested persons, unless there is 

a limited expectation under 40 CFR 1507.3I. 

SEASON OF USE: The period of time during which livestock grazing is permitted on a given 

allotment, as specified in the mandatory terms and conditions of the grazing lease or 

permit.

SECTION 7 CONSULTATION: A part or section of the Endangered Species Act (ESA),called 

“Interagency Cooperation”, is the mechanism by which Federal agencies ensure the 
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Proposed Resource Management Plan and Final Environmental Impact Statement

42 Glossary

actions they take, including those they fund or authorize, do not jeopardize the existence 

of any listed species. 

SECTION 106 COMPLIANCE: The requirement of Section 106 of the National Historic 

Preservation Act that any project that the Federal Government funds, licenses, permits, 

or assists be reviewed for impacts on significant historic properties and that the State 

Historic Preservation Officer and the Advisory Council on Historic Preservation be 

allowed to comment on a project.

SEEDLING: A young plant or tree grown from a seed. 

SEMI-PRIMITIVE MOTORIZED: As defined in the Recreation Opportunity Spectrum, semiprimitive motorized recreation is managed to provide a natural-appearing environment 

with evidence of humans and management controls present, but subtle. Means of access 

include motorized vehicles and mountain bicycles.

SEMI-PRIMITIVE NON-MOTORIZED: As defined in the Recreation Opportunity Spectrum, 

semi-primitive non-motorized recreation is managed to be largely free from evidence of 

humans and onsite controls. Motor vehicle use is not permitted (except as authorized). 

Facilities for the administration of livestock and for visitor use are allowed but limited. 

Means of access include hiking, cross-country skiing, snow shoeing, non- motorized 

boating, and horseback riding.

SENSITIVE CLASS II AREA: A Class II area under the Prevention of Significant 

Deterioration (PSD) Program for which a federal land management (FLM) agency, state 

agency, or tribal authority requests Air Quality Related Value (AQRV) analysis 

comparable to that performed for PSD Class I areas. Agencies with jurisdiction over 

sensitive Class II areas sometimes request that the lead agency implement mitigation 

measures to protect AQRVs at sensitive Class II areas. Sensitive Class II areas are not 

addressed by the Clean Air Act.

SENSITIVE SPECIES: Species that require special management consideration to avoid 

potential future listing under the ESA and that have been identified in accordance with 

procedures set forth in this manual ( 6840 Manual) Those species designated by a State 

Director, usually in cooperation with the state agency responsible for managing the 

species and State Natural heritage programs, as sensitive. They are those species that (1) 

could become endangered in or extirpated from a state, or within a significant portion of 

its distribution; (2) are under status review by the FWS and/or NMFS; (3) are

undergoing significant current or predicted downward trends in habitat capability that 

would reduce a species’ existing distribution; (4) are undergoing significant current or 

predicted downward trends in population or density such that federal listed, proposed, 

candidate, or state-listed status may become necessary; (5) typically have small and 

widely dispersed populations; (6) inhabit ecological refugia or other specialized or 

unique habitats; or (7) are state listed but that may be better conserved through 

application of BLM-sensitive species status (M6840, Special Status Species Manual).
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Glossary 43

SERAL (state or stage): One of three successional states based on the current composition of 

the vegetative community. States include early, mid and late seral states culminating in 

a climax community. Transition from one state to the next can be natural or induced. 

Induced transition is typically disturbance induced and can be progressive or 

retrogressive. Natural succession form one stage to the next is typically progressive, 

culminating in the climax community. “Climax community” is often used

synonymously with terms such as Potential Natural Community (PNC) and Potential 

Natural Vegetation (PNV) and is the highest potential vegetative community that the 

site will support.

SETTING CHARACTER: See Recreation Setting Character.

SIGNIFICANT: An effect that is analyzed in the context of the proposed action to determine 

the degree or magnitude of importance of the effect, whether beneficial or adverse. The 

degree of significance can be related to other actions with individually insignificant but 

cumulatively significant impacts. 

SIGNIFICANT PALEONTOLOGICAL RESOURCE (syn. Significant Fossil Resource): Any 

paleontological resource that is considered to be of scientific interest, including most 

vertebrate fossil remains and certain rare or unusual invertebrate and plant fossils. A 

significant paleontological resource may be considered be to scientifically important 

because it is a rare or previously unknown species, it is of high quality and wellpreserved, it preserves a previously unknown anatomical or other characteristic, or 

provides new information about the history of life on earth. Paleontological resources 

that may be considered to not have paleontological significance include those that lack 

provenience or context, lack physical integrity because of decay or natural erosion, or 

that are overly redundant or are otherwise not useful for research.

SILVICULTURE: The art and science of controlling the establishment, growth, composition, 

health, and quality of forests and woodlands to meet the diverse needs and values of 

landowners and society on a sustainable basis. 

SITE: The combination of biotic, climatic, topographic, and soil conditions of an area. 

SITE PREPARATION: Hand or mechanized manipulation of a site, designed to enhance the 

success of regeneration. 

SOCIOECONOMIC STUDY AREA: The geographic area used for estimation and analysis of 

economic and social impacts.

SOLITUDE: Visitors may have outstanding opportunities for solitude, or primitive and 

unconfined types of recreation when the sights, sounds, and evidence of other people 

are rare or infrequent, where visitors can be isolated, alone, or secluded form others, 

where the use of the area is through non-motorized, non-mechanical means, and where 

no or minimal developed recreation facilities are encountered in an area of 5,000 acres 

or greater (from IM-2003-275, Change 1, Considerations of Wilderness Characteristics 

in LUP, Attachment 1). 
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44 Glossary

SPECIAL RECREATION MANAGEMENT AREA (SRMA): The SRMA is an administrative 

unit where the existing or proposed recreation opportunities and recreation setting 

characteristics are recognized for their unique value, importance, or distinctiveness; 

especially compared to other areas used for recreation.

SPECIAL RECREATION PERMIT (SRP): Is an authorization which allow specified and often 

time-restricted recreational uses of the public lands and related waters. Permits are 

administered under the BLM Handbook H -2930 and policy is specifically provided for 

in the Federal Lands Recreation Enhancement Act (REA), P.L. 108-47. They are used 

as a means to manage visitor use, protect natural and cultural resources, as a means to 

achieve the goals and objectives of the Field Office recreation program as outlined in a 

land use plan, and as a mechanism to authorize the types of described as follows:

 Commercial use

 Competitive

 Vending

 Special area use

 Organized Use

 Commercial Filming Permits in conjunction with an SRP.

SPECIAL STATUS SPECIES: Collectively, federally listed or proposed and Bureau sensitive

species (BLM State Director designated sensitive species), which include both Federal 

candidate species and delisted species within 5 years of delisting. (BLM Manual 6840, 

Special Status Species Management). (H-1601-1, BLM Land Use Planning Handbook)

SPLIT ESTATE: Surface land and mineral estate of a given area under different ownerships. 

Frequently, the surface will be privately owned and the minerals federally owned.

SPLIT SEASON: Removing livestock from the allotment and returning them later in the year

within the permitted time.

SPOT TREATMENT: An application of an herbicide to a small selected area as opposed to 

broadcast application.

SPRAGUE’S PIPIT HABITAT: Moderately suitable and optimal habitat classes from the 

NTNHP Maxent Inductive Model of Sprague’s pipit breeding habitat.

STANDARD: A description of the physical and biological conditions or degree of function 

required for healthy, sustainable lands (e.g., Land Health Standards). To be expressed as 

a desired outcome (goal). (H-1601-1, BLM Land Use Planning Handbook)

STANDARDS FOR RANGELAND HEALTH: Descriptions of the desired condition of the 

biological and physical components and characteristics of rangeland. The four standards 

deal with upland soils, riparian and wetland areas, desired species, and water quality.

STAND DENSITY: A quantitative measure of stocking expressed either absolutely in terms of 

number of trees, basal area or volume per unit area or relative to some standard 

condition. 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Glossary 45

STATE IMPLEMENTATION PLAN: A detailed description of the programs a state will use to 

carry out its responsibilities under the Clean Air Act. 

STATE LISTED SPECIES: Species listed by a state in a category implying but not limited to 

potential endangerment or extinction. Listing is either by legislation or regulation. (M6840, Special Status Species Manual)

STIPULATIONSs: Requirements that are part of the terms of various types of leases. Some 

stipulations are standard on all federal leases. Other stipulations may be applied to the 

lease at the discretion of the surface management agency to protect valuable surface 

resources and uses. 

SUITABLE RIVER: A river segment found, through administrative study by an appropriate 

agency, to meet the criteria for designation as a component of the National Wild and 

Scenic Rivers system, specified in Section 4(a) of the Wild and Scenic Rivers Act.

SUPPRESSED: A tree condition characterized by low growth rate and low vigor as a result of 

competition.

SUPPRESSION: Actions taken to extinguish or reduce the intensity or extent of wildland fires, 

including the construction of fuel breaks by manual or mechanical means, ground or 

aerial application of water or water/chemical mixtures, ignition of backfires or burning 

out of fuels increase the size of fuel breaks. 

SUSTAINED SLOPE: A slope, measured the length of an incline, where short variances within 

the slope do not affect the overall grade. 

SURFACE DISTURBING ACTIVITIES or SURFACE DISTURBANCE: The physical 

disturbance or removal of land surface and vegetation. Some examples of surfacedisturbing activities include, but are not limited to, construction of roads, well pads, 

pipelines, powerlines, reservoirs, facilities, recreation sites, and mining. Vegetation 

renovation treatments that involve soil penetration and/or substantial mechanical 

damage to plants (plowing, chiseling, chopping, etc.) are also surface-disturbing 

activities.

SURFACE OCCUPANCY: Placement or construction of the land surface (temporary or 

permanent) for more than 14 days requiring continual service or maintenance. Casual 

use is excluded. 

SUSTAINABILITY: Long-term management of ecosystems to meet the needs of present 

human populations without interruption, weakening, or loss of the resource base for 

future generations. (EPA)

SUSTAINED YIELD: The achievement and maintenance in perpetuity of a high-level annual 

or regular periodic output of the various renewable resources of the public lands 

consistent with multiple use. 
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TAKE: For the purposes of the endangered species act, the term “take” means to harass, harm, 

pursue, hunt, shoot, wound, kill, trap, capture, or collect or to attempt to engage in any 

such conduct (Endangered Species Act of 1973). 

TECHNICAL/ECONOMICALLY FEASIBLE: Actions that are practical or feasible from the 

technical and economic standpoint and using common sense, rather than simply 

desirable from the standpoint of the applicant. It is the BLM’s sole responsibility to 

determine what actions are technically and economically feasible. The BLM will 

consider whether implementation of the proposed action is likely given past and current 

practice and technology; this consideration does not necessarily require a cost-benefit 

analysis or speculation about an applicant’s costs and profit.” (Modified from the 

CEQ’s 40 Most Asked Questions and BLM NEPA Handbook, Section 6.6.3)

TEMPORARY DISRUPTIVE ACTIVITIES: Activities that involve human presence or 

activities to be in crucial habitats for less than one hour during a 24-hour period in a site 

specific area. (MT-IM-2010-017, 11-30-09, “Guidance of Greater Sage Grouse 

Management and Conservation in RMP’s in Management Zones 1 & 2 within Montana 

/ Dakotas BLM”, Attachment 3, Definitions

TERRITORY: The USFS geographic area identified as having been used by a herd as its 

habitat in 1971 at the passage of the Wild Free-Roaming Horse and Burro Act (PL 92-

195) as amended.

THINNING: A cultural treatment made to reduce stand density of trees primarily to improve 

growth, enhance forest health, or recover potential mortality. 

THREATENED SPECIES: Any species that is likely to become endangered within the 

foreseeable future throughout all or a significant portion of its range (BLM Manual 

6840, Special Status Species Management).

TIMELINESS: The lack of time lag between impacts and the achievement of compensatory 

mitigation goals and objectives (BLM Manual Section 1794).

TIMING LIMITATION (seasonal restriction): A restriction on permitted activities which 

allows certain activities during specific periods to avoid the disturbance of plant or 

animal species during critical periods of the life cycle including, mating, parturition, or 

periods of environmental stress caused by limited food supplies or extreme 

temperatures. 

TOTAL MAXIMUM DAILY LOAD (TMDL): An estimate of the total quantity of pollutants 

(from all sources: point, nonpoint, and natural) that may be allowed into waters without 

exceeding applicable water quality criteria.

TRADITIONAL CULTURAL PROPERTY: A property that derives significance from 

traditional values associated with it by a social or cultural group, such as an Indian tribe 

or local community. A traditional cultural property may qualify for the National 

Register of Historic Places if it meets the criteria and criteria exceptions at 36 CFR 

60.4. See National Register Bulletin 38.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Glossary 47

TRAIL: A linear route managed for human-powered, stock, or some off-highway forms of 

transportation or for historical or heritage values. Trails are not generally managed for 

use by four-wheel drive or high clearance vehicles.

TRANSPORTATION LINEAR FEATURES: “Linear features” represents the broadest 

category of physical disturbance (planned and unplanned) on BLM land. Transportation 

related linear features include engineered roads and trails, as well as user-defined, nonengineered roads and trails created as a result of the public use of BLM land. Linear 

features may include roads and trails identified for closure or removal as well as those 

that make up the BLM’s defined transportation system.

TRANSPORTATION SYSTEM: The sum of the BLM’s recognized inventory of linear 

features (roads, primitive roads, and trails) formally recognized, designated, and 

approved as part of the BLM’s transportation system.

TRAVEL MANAGEMENT AREAS: Polygons or delineated areas where a rational approach 

has been taken to classify areas open, closed or limited, and have identified and/or 

designated a network of roads, trails, ways, and other routes that provide for public 

access and travel across the planning area. All designated travel routes within travel 

management areas should have a clearly identified need and purpose as well as clearly 

defined activity types, modes of travel, and seasons or timeframes for allowable access 

or other limitations (MS-1626). 

Travel Management Areas - definitions of terminology used on Travel Management Area 

maps and in Chapter 2 Travel Management Area Alternatives comparison

 Open to all Vehicles (O): Route is open to all uses without any stipulations or 

restrictions

 Open with Additional Management (MO): Route is open to all uses with some 

forms of additional management, such as adaptive management monitoring or 

specific mitigations, monitoring, or maintenance.

 Open with Restrictions – Seasonal (ML or L) – Pryors: Route is open to all uses 

with seasonal restrictions. There may be some forms of additional management 

such as adaptive management monitoring or specific mitigation, monitoring, or 

maintenance.

 Open with Restrictions – Conditional (ML or L) – Shepherd: Route is open to 

all uses except during periods of high soil moisture/high erosion potential, 

during which time route will be closed to all motorized uses. There may be 

some forms of additional management such as adaptive management 

monitoring or specific mitigation, monitoring, or maintenance.

 Open to Technical 4WD by Permit Only (Alt C) – (Open with Restrictions –

Vehicle Type (ML or L)) – Horsethief: Open to modified 4wd vehicles with 

special event permit only. There may be some forms of additional management 

such as adaptive management monitoring or specific mitigation, monitoring, or 

maintenance.

 Open to Motorcycles Only (Open with Restrictions – Vehicle Type (ML or L)): 

Route is open to Motorcycles. There may be some forms of additional 
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Proposed Resource Management Plan and Final Environmental Impact Statement

48 Glossary

management such as adaptive management monitoring or specific mitigation, 

monitoring, or maintenance.

 Open to Vehicles 50” or Less (Open with Restriction – Vehicle Type (ML or 

L)): Route is open to vehicles 50" wide or less. There may be some forms of 

additional management such as adaptive management monitoring or specific 

mitigation, monitoring, or maintenance.

 Administrative Use Only (L or ML): Route limited to administrative or 

authorized use only. There may be some forms of additional management such 

as adaptive management monitoring or specific mitigation, monitoring, or 

maintenance.

 Closed to All Vehicles (C): Route is closed to all uses, including nonmotorized uses, in that a trail or route would not be officially recognized or 

maintained.

 Non-motorized Use Only: Route is limited to non-motorized use only (closed 

to all motorized uses). There may be some forms of additional management 

such as adaptive management monitoring or specific mitigation, monitoring, or 

maintenance.

TRIBAL TRUST RESOURCES: Those natural resources, either on or off Indian lands, 

retained by, or reserved by or for Indian tribes, through treaties, statutes, judicial 

decisions, and executive orders, which are protected by a fiduciary obligation on the 

part of the United States.

UNALLOTTED LANDS: Public lands available for grazing that currently have no livestock 

grazing authorized. 

UNDERTAKING: A project, activity, or program funded in whole or in part under the direct or 

indirect jurisdiction of a federal agency, including those carried out by or on behalf of a 

federal agency; those carried out with federal financial assistance; those requiring a 

federal permit, license, or approval; and those subject to state or local regulation 

administered pursuant to a delegation or approval by a federal agency.

UNSUITABILITY CRITERIA: Criteria of the federal coal management program by which 

lands may be assessed as unsuitable for all or certain stipulated methods of coal mining. 

(43 CFR 4300)

URBAN: As defined in the Recreation Opportunity Spectrum, urban recreation is managed to 

provide a setting that is largely modified. Large numbers of users can be expected, and 

vegetation cover is often exotic and manicured. Facilities for highly intensified motor 

vehicle use and parking are available, with mass transit often included to carry people 

throughout the site.

USER DAY: Any calendar day, or portion thereof, for each individual accompanied or serviced 

by an operator or permittee on the public lands or related waters; synonymous with 

passenger day or participant day.

UTILITY: A service that a public utility provides (e.g., electricity, telephone or water).
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Proposed Resource Management Plan and Final Environmental Impact Statement

Glossary 49

UTILITY CORRIDOR: A parcel of land, linear or aerial in character, that has been identified 

by law, Secretarial Order, the land-use planning process, or by other management 

decisions, as being a preferred location for existing and future ROW grants and suitable 

to accommodate more than one type of ROW or one or more ROW that are similar, 

identical, or compatible. 

VALID EXISTING RIGHTS: Legal “rights” or interest that are associated with land or mineral 

estate and that cannot be divested from the estate until that interest expires, is 

relinquished, or acquired. Various laws, leases, and filings under federal law establish 

valid existing rights.

VEGETATION TYPE: A plant community with distinguishable characteristics described by 

the dominant vegetation present. 

VISIBILITY (air quality): A measure of the ability to see and identify objects at different 

distances.

VISITOR USE: Visitor use of a resource for inspiration, stimulation, solitude, relaxation, 

education, pleasure, or satisfaction.

VISUAL RESOURCE MANAGEMENT (VRM): A system by which BLM inventories and 

manages scenic values and visual quality of public lands. The system is based on 

research that has produced ways of accessing aesthetic qualities of the landscape in 

objective terms. In RMPs, lands are assigned management classes, which determine the 

amount of modification allowed for the basic elements of the landscape. 

VISUAL RESOURCE MANGEMENT CLASSES: A process to define the degree of 

acceptable visual change within a characteristic landscape. Visual Resources are 

inventoried using procedures established in the BLM Handbook H-8410-1 and are 

managed under the guidelines in BLM Handbook H-8431. A class is based on the 

physical and sociological characteristics of any given homogeneous area and serves as a 

management objective. Categories assigned to public lands are based on scenic quality, 

sensitivity level, and distance zones. Each class has an objective that prescribes the 

amount of change allowed in the characteristic landscape (from H-1601-1, BLM Land 

Use Planning Handbook). The four classes are described below:

 Class I provides for natural ecological changes with very little management 

activity. This class includes primitive areas, some natural areas, some wild and 

scenic rivers, and other similar areas where landscape modification activities 

should be restricted.

 Class II areas are those areas where changes in any of the basic elements (form, 

line, color, or texture) caused by management activity should not be evident in 

the characteristic landscape. The goal is to retain the existing landscape 

character. 

 Class III includes areas where changes in the basic elements (form, line, color, 

or texture) caused by a management activity may be evident in the characteristic 
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Proposed Resource Management Plan and Final Environmental Impact Statement

50 Glossary

landscape. The level of change from an activity should not dominate the 

landscape, but may attract attention of the casual observer. Changes should 

repeat the basic landscape elements. 

 Class IV applies to areas where changes may subordinate the original 

composition and character; however, they should reflect what could be a natural 

occurrence within the characteristic landscape, if possible. The level of change 

to the existing landscape can be high and may dominate the view. This class 

provides for management activities which require modification to the existing 

landscape character. .

WAIVER: Permanent exemption from a lease stipulation. The stipulation no longer applies 

anywhere within the leasehold.

WATER QUALITY: The chemical, physical, and biological characteristics of water with 

respect to its suitability for a particular use. 

WAY: A vehicle route within a WSA that was in existence and inventoried during the FLPMA 

Section 603-mandated wilderness inventory. Interim Management Policy for Lands 

under Wilderness Review (H-8550-1) defines a way as “a track maintained solely by 

the passage of vehicles, which has not been improved and/or maintained by mechanical 

means to ensure relatively regular and continuous use.” The term is also used during 

wilderness inventory to identify routes that are not roads. The term is developed from 

the definition of the term “roadless” provided in the Wilderness Inventory Handbook 

(September 27, 1978), as follows: “roadless: refers to the absence of roads which have 

been improved and maintained by mechanical means to insure relatively regular and 

continuous use. A way maintained solely by the passage of vehicles does not constitute 

a road.” A trace maintained solely by the passage of vehicles which has not been 

improved and /or maintained by mechanical means to ensure relatively regular and 

continuous use. (Interim Management Policy for lands under Wilderness review- IMP, 

H -8550-1). 

WETLANDS: Areas that are inundated or saturated by surface or ground water often and long 

enough to support, and under normal circumstances do support, a prevalence of 

vegetation typically adapted for life in saturated soil conditions.

WILD AND SCENIC RIVER: Rivers identified in Section 5 of the Wild and Scenic Rivers Act 

of 1968 for study as potential additions to the National Wild and Scenic Rivers System. 

The rivers will be studied under the provisions of Section 4 of the act (from M-8351, 

BLM WSR Policy and Program).

WILDERNESS: A congressionally designated area of undeveloped federal land retaining its 

primeval character and influence, without permanent improvements or human 

habitation, that is protected and managed to preserve its natural conditions and that (1) 

generally appears to have been affected mainly by the forces of nature, with human 

imprints substantially unnoticeable; (2) has outstanding opportunities for solitude or a 

primitive and unconfined type of recreation; (3) has at least 5,000 acres or is large 

enough to make practical its preservation and use in an unimpaired condition; and (4) 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Glossary 51

may also contain ecological, geological, or other features of scientific, educational, 

scenic, or historic value. The definition is contained in Section 2(c) of the Wilderness 

Act of 1964 (78 Stat. 891) (from H-6310-1, Wilderness Inventory and Study 

Procedures). These lands are included in the National Wilderness Preservation System. 

WILDERNESS CHARACTERISTICS: Wilderness characteristics include size, the appearance 

of naturalness, outstanding opportunities for solitude, or a primitive and unconfined 

type of recreation. They may also include ecological, geological, or other features of 

scientific, educational, scenic, or historical value. A complete definition is contained in 

Section 2 (c) of the Wilderness Act of 1964 (78 Stat 891)

WILDERNERSS STUDY AREAS (WSAs): Areas designated as having wilderness 

characteristics as described in Section 2 (c) of the Wilderness Act (78 Stat. 891), made 

through the inventory and study process authorized by Section 603or Section 202 of 

FLPMA. Areas designated as WSAs must be managed as being under wilderness 

review until Congress either designates these lands as wilderness or releases them for 

other purposes. They are not managed as if they are already designated Wilderness, but 

as not to impair their suitability for potential designation by Congress. If the lands are 

released from wilderness review, they are managed under the general BLM 

management policies and applicable land use plans.

WILDFIRE: An unplanned ignition of a wildland fire (such as a fire caused by lightening, 

volcanoes, unauthorized and accidental human caused fires) and escaped prescribed 

fires. (2009 Guidance for Implementation of Federal Wildland Fire Management 

Policy)

WILD HORSE RANGE: An area of land designated from a herd management area to be 

managed principally, but not exclusively, for wild horse or burro herds.

WILD HORSES AND BURROS: Unbranded and unclaimed horses and burros that use the 

public lands as all or part of their habitat or that have been removed from these lands by 

the authorized officer but have not lost their status under Section 3 of the Act (H-4750-

2, BLM Wild Horse and Burro Adoption Handbook)

WILD LANDS: A designation resulting from a plan decision to protect lands with wilderness 

characteristics (LWC) located outside of the Wilderness Study Areas (WSAs) and 

Wilderness Areas. Wild land protection measures are developed in the course of plan 

development BLM is required under Section 201 of FLPMA to conduct and maintain a 

current inventory of natural resources. BLM conducts its wilderness characteristics 

inventory through the BLM Manual 6301 and incorporates the findings in the RMP 

through its Manual 6302. These manuals implement Secretarial Order 3310 and 

incorporates principles from BLM guidance (ex: Organic Act directives) and legal rules 

developed as part of BLM’s original wilderness inventories. 

WILDLAND FIRE: Any non-structure fire that occurs in vegetation or natural fuels. Wildland 

fire includes prescribed fire and wildfire. (2014 NWCG glossary)
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Proposed Resource Management Plan and Final Environmental Impact Statement

52 Glossary

WILDLAND URBAN INTERFACE (WUI): The line, area, or zone in which structures and 

other human development meet or intermingle with undeveloped wildland or vegetative 

fuels. 

WILD RIVER: Those rivers or sections of rivers that are free of impoundments and generally 

inaccessible except by trail, with watersheds or shorelines essentially primitive and 

unpolluted. These represent vestiges of primitive America.

WILD, SCENIC, OR RECREATIONAL: The term used for what is traditionally shortened to 

wild and scenic rivers. Designated river segments are classified as wild, scenic, or 

recreational but cannot overlap (from M-8351, BLM WSR Policy and Program).

WINTER RANGE: Range that is grazed by livestock or wildlife during the winter.

WITHDRAWAL: An action that restricts the use of public lands by removing them from the 

operation of some or all of the public land laws (e.g. mineral rights).

WOODLAND: A community of trees that are often small, characteristically short-boled 

relative to their crown depth and forming only an open canopy with the intervening area 

being occupied by a lower vegetation type.
Petroglyph Canyon ACEC

APPENDICES A-B
Appendix A A - i

Appendix A: 

Federal Laws, Regulations, Policies, and Guidance 
Appendix A A - ii

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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix A A - 1

A. Federal Laws, Regulations, Policies, and Guidance

The development of the Billings/Pompeys Pillar RMP/EIS followed all applicable laws, 

regulations, and policies, including, but not limited to, those listed in Table A-1.

Table A-1: Specific Mandates and Authorities

Federal Law or Statute Year

Acquired Lands Act – Act of August 7, 1947; (61 Stat 913) 1947

Act of April 23, 1932 (47 Stat 136) 1932

Act of June 28, 1934; Section 7 (43 USC 315f), as amended 1934

Act of June 30, 1950 (16 USC 508(e) and (e)) 1950

Act of July 23, 1955 (P L 167; 43 CFR 3710) 1955

Act of August 13, 1954 (68 Stat. 708, 30 USC 521 subpart) 1954

Act of September 1, 1949, Section 3 (30 USC 192c) 1949

Act of September 28, 1962 (P L 87-713,76 Stat 652) 1962

Act of October 30, 1978 (92 Stat 2073-2075) 1978

Airport and Airway Improvement Act, Section 516 (49 USC 2215) 1982

American Indian Religious Freedom Act of 1978 (PL 95-579; 90 Stat 469; 42 USC 1996) 1996

American Recovery and Reinvestment Act 2009

Antiquities Act of 1906 (PL 59-209; 34 Stat 225; 16 USC 431-433) 1906

Appropriations Act of 1952, McCarran Amendment (31 USC 9701) 1952

Archaeological and Historic Preservation Act (16 USC 469-469c-1) 1974

Archaeological and Paleontological Salvage Act for Federal Highway Projects (23 USC 305; 72 Stat 913 (1958), 74 

Stat 525 (1960) 1960

Archaeological Resources Protection Act of 1979 (PL 96-95; Stat 721; 16 USC 470 et seq.) as amended (PL 100-

555; PL 100-588) 1979

Bald Eagle Protection Act (16 USC 668-668d, 54 Stat 250) 1940

Carey Act of August 18, 1894, as amended (43 USC et seq.) 1894

Carson-Foley Act of 1968 (42 USC 1241-1243) 1968

Classification and Multiple Use Act of 1964 (43 USC 1411-18) 1964

Clean Air Act, as amended 1963

Clean Water Act, as amended (30 USC 1251) 1977

Coastal Zone Management Act (PL 92-583, 16 USC 1451-1456) 1972

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) (42 USC 9601) 1980

Control of Pollution from Federal Facilities Act of 1970 (33 USC 1323) 1970

Department of Energy Organization Act (42 USC 7101 et seq.) 1977

Desert Land Act (19 Stat 377; 43 USC 321-323), as amended 1877

Domestic Minerals Program Extension Act 1953

Earl Douglass, 44 L.D. 325, August 6, 1915 1915
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix A A - 2

Table A-1: Specific Mandates and Authorities

Economy Act 1932, as amended (PL 72-211; 417 USC 686) 1832

Emergency Planning and Community Right-to-Know Act (42 USC 11001-11050) 1986

Emergency Wetland Resources Act (16 USC 3901) 1986

Endangered Species Act (16 USC 1531-1544, 87 Stat 884), as amended 1973

Energy Independence and Security Act 2007

Energy Policy Act (PL 109-58) 2005

Energy Policy and Conservation Act Reauthorization of 2000, as amended (PL 106-469) 2000

Engle Act (43 USC 155 et seq.) 1958

Executive Memorandum, Government-to-Government Relations with Native American Tribal governments 1994

Executive Order of April 17, 1926, Public Water Reserve No. 107 1926

Executive Order 11514 – Protection and Enhancement of Environmental Quality 1970

Executive Order 11593 – Protection and Enhancement of the Cultural Environment 1971

Executive Order 11644 – Use of Off-Road Vehicles on the Public Lands 1972

Executive Order 11738 – Administration of the Clean Air Act and the Federal Water Pollution Control Act 1973

Executive Order 11752 – Prevention, Control, and Abatement of Environmental Pollution at Federal Facilities 1973

Executive Order 11987 – Exotic Organisms 1977

Executive Order 11988 – Floodplain Management 1977

Executive Order 11989 – Off-Road Vehicles on Public Lands 1977

Executive Order 11990 – Protection of Wetlands 1977

Executive Order 11991 – Relating to Protection and Enhancement of Environmental Quality 1977

Executive Order 12088 – Federal Compliance with Pollution Control Standards 1978

Executive Order 12580 – Superfund Implementation and 13016 – Amendment to Executive Order 12580 1987 and 

1996

Executive Order 12898 – Federal Actions to Address Environmental Justice in Minority Populations and LowIncome Populations 1994

Executive Order 12962 – Recreational Fisheries 1995

Executive Order 13007 – Providing for American Indian and Alaska Native Religious Freedom and Sacred land 

Protections 1996

Executive Order 13084 – Consultation and Coordination with Indian Tribal Governments 1998

Executive Order 13112 – Invasive Species 1999

Executive Order 13148 – Greening of the Government through Leadership in Environmental Management 2000

Executive Order 13186 – Responsibilities of Federal Agencies to Protect Migratory Birds 2001

Executive Order 13195 – Trails for America in the 21

st Century 2001

Executive Order 13212 - Actions to Expedite Energy-Related Projects 2001

Executive Order 13287 – Preserve America 2003

Executive Order – Delegating to the Secretary of the Interior the Authority of the President to withdraw or reserve 

lands of the United States for Public Purposes 1952

Executive Order 13175 – Consultation and Coordination with Indian Tribal Governments 2000

Executive Order 13443 – Facilitation of Hunting Heritage and Wildlife Conservation 2007
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix A A - 3

Table A-1: Specific Mandates and Authorities

Executive Order 6910 and Executive Order 6964, and amendments 1934

Federal Aid Highway Act (23 USC 107 (d) and 317) 1958

Federal Cave Resources Protection Act (16 USC 4301 et seq.) 1988

Federal Coal Leasing Amendments Act (90 Stat 1083-1092), as amended 1976

Federal Coal Management Program Coal Screening Process (43 CFR 3420.1-4) 1997

Federal Environmental Pesticide Control Act (7 USC 136 et seq.) 1972

Federal Facilities Compliance Act of 1992 1992

Federal Insecticide, Fungicide, and Rodenticide Act of 1947, as amended (7 USC 136 et seq.) 1947

Federal Land Policy and Management Act of 1976 (PL 94-579; 90 Stat 2743; 43 USC 1701) 1976

Federal Lands Recreation Enhancement Act 2004

Federal Land Transaction Facilitation Act (43 USC 2301, et seq.) 1974

Federal Oil and Gas Royalty Management Act 1982

Federal Plant Pest Act (7 USC 150aa et seq.) 1957

Federal Property and Administration Services Act of 1949 1949

Federal Water Pollution Control Act (33 USC 1251-1376), as amended 1948

Federal Water Projects Recreation Act (16 USC 460(L)(12)-460(L)(21)), as amended 1965

Federal Wildland Fire Management Policy 2001

Fish and Wildlife Coordination Act of 1934 (16 USC 661-667e), as amended 1934

Fish and Wildlife Conservation Act (16 USC 2901-2911) 1980

Food, Drug, and Cosmetic act of 1938 and the Miller Amendment to the Act (21 (USC 301 et seq.) 1938

Food Security Act of 1985 (16 USC 3801-3862) 1985

Geothermal Steam Act of 1970 (30 USC 1001 et seq.), as amended 1970

General Allotment Act, Section 4 (25 USC 334), as amended 1887

General Mining Law of 1872, as amended (30 USC 21) 1872

General Resurvey Acts, 43 USC 772 and 773 1909

Healthy Forests Restoration Act (PL 108-148) 2003

Historic Sites Act of 1935 ((PL 74-292; 49 Stat 666; 16 USC 461 et seq.) 1935

Horse Protection Act of 1970 (15 USC 1821 et seq.) 1970

Lacey Act (18 USC 42), as amended 1988

Land and Water Conservation Act, as amended (16 USC 460 et seq.) 1965

Lode Law Act of 1866 (14 Statute 251) 1866

Materials Act of July 31, 1947 (30 USC 601-604), as amended 1947

Migratory Bird Conservation Act of 1929 (16 USC 715) 1929

Migratory Bird Treaty Act of 1918 (16 USC 703 et seq.) 1918

Mineral Leasing Act of 1920, as amended (30 USC 181) 1920

Mineral Leasing Act for Acquired Lands of 1947, as amended (30 USC 351 et seq.) 1947

Mining Law of 1872, as amended 1872

Mining and Mineral Policy Act of 1970 (30 USC 21) 1970
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix A A - 4

Table A-1: Specific Mandates and Authorities

Mining Claim Rights Restoration Act (30 USC 621-625) 1955

Multiple Mineral Development Act (30 USC 521-531 et seq.) 1954

National Environmental Policy Act of 1969 (PL 91-190; 83 Stat 852; 42 USC 4321) 1969

National Fire Plan 2000

National Historic Preservation Act of 1966, as amended (PL 89-665; 80 Stat 915; 16 USC 470) 1966

National Materials and Minerals Policy, Research, and Development Act of 1980 (PL 96-479, 94 Stat.2305) 1980

National Oil and Hazardous Substances Pollution Contingency Plan (40 CFR 300) 1988

National Parks and Recreation Act of 1978 (16 USC 1242 and 1243) 1978

National Trails System Act of 1968 (16 USC 1241 et seq.), as amended 1968

National Wild and Scenic Rivers Act (16 USC 1271 et seq.) 1968

Native American Graves Protection and Repatriation Act of 1990 (PL 101-601; 104 Stat 3048; 25 USC 3001) 1990

Naval Petroleum Reserves Production Act (43 CFR 2361.1(f)) 1976

Neotropical Migratory Bird Conservation Act (PL 106-247) 2000

Non-Indigenous Aquatic Nuisance Prevention and Control Act of 1990, as amended (16 USC et seq.) 1990

Noxious Weed Control Act of 2004 (PL 108-412) 2004

O & C Lands Act of 1937 (62 Stat 162) 1948

Occupational Safety and Health Act (29 USC 651 et seq.) 1970

Oil Pollution Act (33 USC 2701 et seq.) 1990

Paleontological Resources Protection Act of 2009 (PL 111-11) 2009

Placer Law – Act of July 9, 1870 (16 Stat 217) 1870

Plant Protection Act (7 USC 7701-7772) 2000

Pollution Prevention Act (42 USC 13101et seq.) 1990

Public Rangelands Improvement Act (43 USC 1901 et seq.) 1978

Recreation and Public Purposes Act (43 USC 869), as amended in 1988 1926

Reorganization Plan No. 3 of 1946 (5 USC Section 402) 1946

Reservoir Salvage act of 1960, as amended by Archaeological and Historic Preservation Act of 1974 (PL 86-523; 74 

Stat 220, 221; 16 USC 469; PL 93-291; 88 Stat 174; 16 USC 469) 1960

Resource Conservation and Recovery act of 1976, as amended (42 USC 6901 et seq.) and the Bevill Amendment 

(Section 3001(b)(3)(A)(ii) and 40 CFR 261.4(b)(7)) 1976

Riparian-Wetlands Initiative for the 1990s, The U.S. Department of the Interior, Bureau of Land Management, 

January 22, 1992 1992

Rivers and Harbors Act of 1899 (10 USC 1899, Section 10) 1899

Safe Drinking Water Act, as amended 1977 (42 USC 201) 1977

Secretarial Order 3206 - American Indian Tribal Rights, Federal Tribal Trust Responsibilities, and the ESA 1997

Secretarial Order 3226 – Climate Change 2001

Secretarial Order 3308 – Management of the National Landscape Conservation System 2010

Secretarial Order 3310 – Protecting Wilderness Characteristics on Lands Managed by the Bureau of Land 

Management 2010

Secretarial Order 3336 – Rangeland Fire Management, Prevention, and Restoration 2015
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix A A - 5

Table A-1: Specific Mandates and Authorities

Sikes Act of 1974, as amended (16 USC 670 et seq.) 1974

Soil and Water Resources Conservation act of 1977 (16 USC 2001) 1977

Soil Conservation and Domestic Allotment Act of 1935, as amended (16 USC 590) 1935

Soil Information Assistance for Community Planning and Resource Development Act of 1966 (42 USC 3271) 1966

Stock Raising Homestead Act of 1916, as amended (43 USC 299) 1916

Surface Mining Control and Reclamation Act (30 USC 1201 et seq.) 1977

Surface Resources Act of 1955 (30 USC 611-614) 1955

Survey Statutes, 43 USC 751, 752, and 753 2011

Taylor Grazing Act of 1934, as amended (43 .S.C. 315) 1934

Toxic Substance and Control Act of 1976 (PL 104-66), as amended in 1995 1976

Unified Federal Policy for a Watershed Approach to Federal Land and Resource Management 2000

U.S. Onshore Orders:

Onshore Order No. 1 – Approval of Operations on Onshore Federal and Indian Oil and Gas Leases

Onshore Order No. 2 – Onshore Oil and Gas Drilling Operations on Federal and Indian Oil and Gas 

Leases

Onshore Order No. 3 – Site Security on Federal Oil and Gas Leases

Onshore Order No. 4 – Measurement of Oil on Federal Oil and Gas Leases

Onshore Order No. 5 – Measurement of Gas on Federal Oil and Gas Leases

Onshore Order No. 6 – Hydrogen Sulfide Operations on Federal Oil and Gas Leases

Onshore Order No. 7 – Disposal of Produced Water from Federal Oil and Gas Leases

1983

1988

1989

1989

1989

1991

1993

U.S. v Peck, No. 97-8122, 1999 WL 33022 1999

Water Quality Act of 1987, as amended from the Federal Water Pollution Control Act of 1977 (Clean Water Act), as 

mended (33 USC 1251 et seq.) 1987

Water Resources Development Act 1974

Water Resources Planning Act (42 USC 1962a-1962(a)(4)(e)), as amended 1965

Watershed Protection and Flood Protection Act, as amended (16 USC et seq.) 1954

Watershed Protection and Enhancement Agreements (“Wyden Amendment”) (PL 104-208, sec. 124, PL 105-277, 

sec 136 of the 1999 Interior Appropriations Act of 1998) 1998

Wild and Free Roaming Horses and Burros Act of 1971 (16 USC 1331 et seq.), as amended 1971

Wilderness Act of 1964, as amended (16 USC 1131 et seq.) 1964

Wild Horse and Burro Sale Authority, within Consolidated Appropriations Act of 2005 (PL 108-477, Sec 142) 2005

DOI Directives Year

Department Manual 517, Integrated Pest Management

303 Department Manual 7, Standards for Indian Trust Lands Boundary Evidence

600 Department Manual 5, Standards for Federal Lands Boundary Evidence

757 Department Manual 2, Surveying

BLM Directives Year

Abandoned Mine Lands (AML) National Strategic Plan 2006

Applications for Permit to Drill (APD) Fees 2007
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix A A - 6

Table A-1: Specific Mandates and Authorities

Applications for Permit to Drill (APD) 2007

BLM Montana/Dakota Recreation and Visitor Services Strategy 2010

BLM Policy Statement on Riparian Management Activity Guide 1987

BLM Priorities for Recreation and Visitor Services 2003

BLM MOU-MT931-6901 delegating a portion of Wyoming to Montana (PMWHR) 1969

Competitive Leasing (43 CFR 3120) 2002

Delegation of Authority, Cooperative Agreements, and Contracts for Oil and Gas Inspection (43 CFR 3190) 1987

Federal Coal Management Program Regulations (43 CFR Group 4300) 1979

Federal Manual for Identifying and Delineating Jurisdictional Wetlands 1991

Fish and Wildlife 2000 BLM National, State, and District Policies 2000

Grazing Administration Range Improvements and Water Rights (43 CFR 4100 et seq.) 2002 

(revised)

Geothermal Leasing (43 CFR 3200) 1998

Geothermal Resources Unit Agreements (43 CFR 3280) 1973

Instruction Bulletin 2002-101, Cultural Resource Considerations in Resource Management Plans 2002

Instruction Memorandum 2014-131, Implementation of the Federal Lands Hunting, Fishing and Shooting Sports 

Roundtable Memorandum of Understanding 2014

Instruction Memorandum 2014-146, Guidance on Preparing Federal Register Notices 2014

Instruction Memorandum 2012-067, Clarification of Cultural Resource Considerations for Off-Highway Vehicle 

Designations and Travel Management 2012

Instruction Memorandum 2012-044, BLM National Greater Sage-Grouse Land Use Planning Strategy 2012

Instruction Memorandum 2012-043, Greater Sage-Grouse Interim Management Policies and Procedures 2012

Instruction Memorandum 2011-004, Revised Recreation and Visitor Services Land Use Planning Guidance 2011

Instruction Memorandum 2011-138, Sage Grouse Conservation Related to Wild Land Fire and Fuels Management 2011

Instruction Memorandum 2011-154, Requirement to Conduct and Maintain Wilderness Inventories and to Consider 

Lands with Wilderness Characteristics in Land Use Planning 2011

Instruction Memorandum 2011-159, Scattering of Cremated Remains 2011

Instruction Memorandum 2010-181, White Nose Syndrome 2010

Instruction Memorandum 2010-149, Sage-Grouse Conservation Related to Wildland Fire and Fuels Management 2010

Instruction Memorandum 2010-117, Oil and Gas Leasing Reform – Land Use Planning and Lease Parcel Reviews 2010

Instruction Memorandum 2009-215, Planning for Special Designations within the National System of Public Lands 2009

Instruction Memorandum 2009-167, Application of the Visual Resource Management Program to Renewable 

Energy 2009

Instruction Memorandum 2009-138, Confidentiality of Paleontological Locality under the Omnibus Public Lands Act 

of 2009 2009

Instruction Memorandum 2009-043, Wind Energy Development Policy 2009

Instruction Memorandum 2009-039, Transmittal of Revised 6840 Special Status Species Manual and Direction for 

State Directors to Review and Revise Existing Bureau Sensitive Species Lists 2009

Instruction Memorandum 2009-113, Casual Collection of Common Invertebrate and Plant Paleontological 

Resources under the Paleontological Resources Preservation Act of 2009 2009
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix A A - 7

Table A-1: Specific Mandates and Authorities

Instruction Memorandum 2009-011, Assessment and Mitigation of Potential Impacts to Paleontological Resources 2009

Instruction Memorandum 2008-204, Off-Site Mitigation 2008

Instruction Memorandum 2008-014, Clarification of Guidance and Integration of Comprehensive Travel and 

Transportation Management Planning into Land Use Planning 2008

Instruction Memorandum 2008-009, Potential Fossil Yield Classification (PFYC) System for Paleontological 

Resources on Public Lands 2008

Instruction Memorandum 2007-096, Refinement of the Methodology to Identify Abandoned Mine Land Sites Near 

Populated Places and High Use Areas 2007

Instruction Memorandum 2007-030, Clarification of Cultural Resource Considerations for Off-Highway Vehicle 

(OHV) Designation and Travel Management 2007

Instruction Memorandum 2006-197, BLM Energy and Non-Energy Mineral Policy 2006

Instruction Memorandum 2006-145, Cooperative Conservation Based Strategic Plan for the Abandoned Mine Lands 

Program 2006

Instruction Memorandum 2006-071, Process Improvement for Oil, Gas, Geothermal, Geophysical, and Related 

Rights-of-Way Approvals 2006

Instruction Memorandum 2005-247, National Environmental Policy Act (NEPA) Compliance for Oil, Gas, and 

Geothermal Development 2005

Instruction Memorandum 2005-227, NHPA Section 106 and Oil and Gas Permitting 2005

Instruction Memorandum 2005-210, Energy Policy and Conservation Act (EPCA) Inventory – Data Compilation for 

Phases III and IV 2005

Instruction Memorandum 2005-176, Filing of Protests on Lands Included in Oil and Gas Lease Sales 2005

Instruction Memorandum 2005-069, Offsite Compensatory Mitigation Guidelines 2005

Instruction Memorandum 2005-003, Cultural Resources, Tribal Consultation, and Fluid Minerals Leasing 2005

Information Memorandum 2003-147, Application for Permit to Drill (APD) – Process Improvement #3 – Cultural 

Resources 2003

Information Memorandum 2003-020, Interim Wind Energy Development Policy 2003

Information Memorandum 2002-196, Right-of-Way Management - Land Use Planning 2002

Information Memorandum 99- 039, Issuance of Grazing Permits in Compliance with Applicable Laws, Regulations, 

and Policy

1999

Instruction Memorandum MT-2009-039 2009 Montana/Dakotas Special Status Species List 2009

Instruction Memorandum MT -2010-017 Guidance for Greater Sage-Grouse Management and Conservation in 

Resource Management Plan (RMP) Revisions in Management Zones 1 and 2 Within the Montana/Dakotas BLM 2010

Instruction Memorandum MT-2010-001 Review of Proposed Recreation and Visitor Services Strategy for 

Montana/Dakotas Bureau of Land Management 2010

Instruction Memorandum MT-2012-039 Montana/Dakotas Sign Maintenance Program 2012

Memorandum on Administration on the Pryor Mountain Wild Horse Range between Wyoming and Montana 1975

Memorandum – Government-to-Government Relations with Native American Tribal Governments 1994

National Programmatic Agreement with the Advisory Council on Historic Preservation and the National Conference 

of State Historic Preservation Officers 1997

Order No. 3175 – Departmental Responsibilities for Indian Trust Resources (Section 2 of Reorganization Plan No. 3 

of 1950 – 64 Stat 1262) 1993

BLM Manuals
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix A A - 8

Table A-1: Specific Mandates and Authorities

BLM Manual 1553, Planning and Creating Graphics

BLM Manual 1610, Land Use Planning

BLM Manual 1613, ACECs

BLM Manual 1626, Travel and Transportation

BLM Manual 1703, Hazardous Materials Management

BLM Manual 1790, NEPA

BLM Manual 3031, Energy Mineral Resource Assessment

BLM Manual 4180, Rangeland Health Standards

BLM Manual 4700, Wild Free-Roaming Horse and Burro Management

BLM Manual 6220, National Monuments, National Conservation Areas, and Similar Designations

BLM Manual 6280, Management of National Scenic and Historic Trails and Trails Under Study or Recommended as 

Suitable for Congressional Designation

BLM Manual 6500, Wildlife and Fisheries Management

BLM Manual 6330, Management of BLM Wilderness Study Areas

BLM Manual 6521, State Agencies

BLM Manual 6525, Sikes Act Wildlife Programs

BLM Manual 6600, Fish, Wildlife, and Special Status Plant Resources Inventory and Monitoring

BLM Manual 6840, Special Status Species Management

BLM Manual 7000, Soil, Water, and Air Management 

BLM Manual 8100, Foundations for Managing Cultural Resources

BLM Manual 8110, Identifying Cultural Resources

BLM Manual 8120, Tribal Consultation under Cultural Resources 

BLM Manual 8120-1, Guidelines for Conducting Tribal Consultation

BLM Manual 8130, Planning for Uses of Cultural Resources

BLM Manual 8160, Native American Consultation and Coordination

BLM Manual 8170, Interpreting Cultural Resources for the Public

BLM Manual 8270, Paleontological Resource Management

BLM Manual 8300, Recreation Management

BLM Manual 8320, Planning for Recreation and Visitor Services

BLM Manual 8351, Wild and Scenic River Policy

BLM Manual 8400-1, Visual Resource Management

BLM Manual 9011, Chemical Pest Control (1992)

BLM Manual 9014, Use of Biological Control Agents of Pests on Public Lands (1990)

BLM Manual 9015, Management and Coordination of Noxious Weeds Activities

BLM Manual 9130, Signs

BLM Manual 9211, Fire Planning

BLM Manual 9600, Cadastral Sruvey

Regulations
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix A A - 9

Table A-1: Specific Mandates and Authorities

36 CFR Part 800: Protection of Historic Properties

36 CFR Part 60: National Register of Historic Places

36 CFR Part 78: Waiver of Federal Agency Responsibilities under Section 110 of the National Historic Preservation 

act

40 CFR 1500-1508

43 CFR Part 7: Protection of Archaeological Resources

43 CFR 37.2, Cave Management Policy

43 CFR 1600, Planning, Programming and Budgeting

43 CFR 1610.4, Resource Management Planning Process

43 CFR 1610.7-2, Designations of Areas of Critical Environmental Concern

43 CFR 2200.0-6 (b), Exchanges

43 CFR 2801.2 (c), Objectives of BLM’s Right-of-Way Program 

43 CFR 2801.5

43 CFR 2802.10, Lands Available for FLPMA Grants

43 CFR 3101.1‐2

43 CFR 3120, Competitive Leasing

43 CFR 3162.5

43 CFR 3190, Delegation of Authority, Cooperative Agreements, and Contracts for Oil and Gas Inspection

43 CFR 3200, Geothermal Leasing

43 CFR 3461.5

43 CFR 3809.5

43 CFR 4100, Grazing Administration, Range Improvements, and Water Rights

43 CFR 4300, Federal Coal Management Program Regulations

43 CFR 8340, Off-Road Vehicles

50 CFR 400, Interagency Cooperation under the ESA

BLM Handbooks

Handbook H-1601-1, Land Use Planning

Handbook H-1624-1, Planning for Fluid Mineral Resources

Handbook H-1790-1, National Environmental Policy Act

Handbook H-2200-1, Land Exchange Handbook

Handbook H-3070-1, Economic Evaluation of Coal Properties

Handbook H-3070-2, Economic Evaluation of Oil and Gas Properties 

Handbook H-3600-1, Mineral Materials Disposal

Handbook H-4120-1 Grazing Management

Handbook H-4180-1, Rangeland Health Standards

Handbook H-4700-1, Wild Horses and Burros Management 

Handbook H-8120-1, General Procedural Guidance for Native American Consultation

Handbook H-8342-1, Travel and Transportation Handbook
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix A A - 10

Table A-1: Specific Mandates and Authorities

Handbook H-8270-1 General Procedural Guidance for Paleontological Resource Management

Handbook H-8410-1, Visual Resource Inventory Handbook

Handbook H-9011-1, Chemical pest Control (1988)

Handbook H-9211-1, Fire Management Activity Planning 

Handbook H-9214-1, Prescribed Fire Management Handbook

Handbook H-9600-1, Cadastral Survey Handbook
Appendix B B- i

Appendix B: 

Best Management Practices
Appendix B B- ii

This page intentionally left blank
Appendix B B- iii

Table of Contents

B. Best Management Practices ...............................................................................................................1

B.1 Air.............................................................................................................................................1

Air Resource BMPs: Best Management Practices for Fluid Minerals (USDOI, BLM) ..1

B.2 Water........................................................................................................................................2

Water Quality BMPs (Best Management Practices) for Montana Forests ......................2

Montana Guide to the Streamside Management Zone Law ............................................2

Erosion and Sediment Control Practices: Field Manual ...................................................3

Erosion and Sediment Control Practices: Reference Manual...........................................3

Montana Non-Point Source Management Plan .................................................................4

National Menu of Stormwater Best Management Practices (US EPA)...........................4

Water-Road Interaction Technology Series Documents (USFS) May 2000 ....................5

B.3 Invasive Species and Noxious Weeds .................................................................................5

Invasive Species: Final Vegetation Treatments using Herbicides on BLM in 17 

Western States.........................................................................................................................5

B.4 Wildlife Habitat ......................................................................................................................6

Suggested Practices for Avian Protection on Power Lines: State of the Art in 2006 

Avian Power Line Interaction Committee (APLIC). .........................................................6

Com Towers etc. .....................................................................................................................6

B.5 Wildland Fire Ecology and Management ...........................................................................8

Interagency Burned Area Emergency Response Handbook............................................8

Burned Area Emergency Stabilization and Rehabilitation Handbook...........................8

Interagency Standards for Fire and Fire Aviation Operations (Redbook).....................9

B.6 Fluid Minerals.........................................................................................................................9

Best Management Practices for Oil and Gas Development on Public Lands ................9

BMPs for Fluid Minerals........................................................................................................9

Western Governors’ Association Coal Bed Methane BMPs Handbook .........................9

Handbook on Best Management Practices and Mitigation Strategies for Coal Bed 

Methane in the Montana Portion of the Powder River Basin ........................................10

B.7 Coal.........................................................................................................................................10

Coal Mining BMPs ...............................................................................................................10

B.8 Mineral Materials .................................................................................................................10

Mineral materials site BMP (construction and stormwater) ..........................................10

B.9 Livestock Grazing.................................................................................................................11

Montana Best Management Practices for Grazing ..........................................................11

B.10 Transportation and Facilities ..............................................................................................11

Low Volume Roads Engineering Best Management Practices Field Guide (U.S. Forest 

Service)...................................................................................................................................11

B.11 Resource Program Best Management Practices (BMPs) .................................................13

Surface Disturbing Activities..............................................................................................14

Air...........................................................................................................................................14

Soil ..........................................................................................................................................16

Climate:..................................................................................................................................18

Water/Wetlands/Riparian etc. ..........................................................................................19

Vegetation..............................................................................................................................21

Vegetation - Rangelands......................................................................................................21
Appendix B B- iv

Vegetation - Invasive Species and Noxious Weeds .........................................................23

Wildlife Habitat and Special Status Species .....................................................................24

Fisheries Habitat and Special Status Species ....................................................................26

Cultural and Heritage Resources .......................................................................................27

Paleontological Resources ...................................................................................................29

Wildfire Ecology and Management...................................................................................30

Visual Resource Management ............................................................................................32

Fluid Mineral Exploration and Development..................................................................33

Fluid Mineral Extraction......................................................................................................34

Realty, Cadastral Survey, and Lands.................................................................................39

Management of Land Boundaries......................................................................................40

Livestock Grazing.................................................................................................................41

Recreation..............................................................................................................................42

Health and Safety .................................................................................................................43

Transportation– Travel Management (Road design and maintenance).......................43

B.12 BLM Wind Energy Development Program Policies and Best Management Practices 

(BMPs) ...............................................................................................................................................44

A.1 Policies .......................................................................................................................45

A.2 Best Management Practices (BMPs) ......................................................................48
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 1

B. Best Management Practices

The publications referenced in this appendix are sources of “Best Management Practices” 

(BMPs). BMPs are measures that have been developed by agency, industry, scientific, and/or 

working groups as voluntary methods for reducing environmental impacts associated with 

certain classes of activity. BLM typically uses these measures as guidelines or “project design 

features” during implementation planning at the activity and/or project-specific levels. 

The list included in this appendix is not limiting, but references the most frequently used sources. 

As new publications are developed, BLM may consider those BMPs. In addition, many BLM 

handbooks (such as BLM Manual 9113-Roads and 9213-Interagency Standards for Fire and 

Aviation Operation) also contain BMP-type measures for minimizing impacts. These BLMspecific guidance and direction documents are not referenced in this appendix. 

Planning implications: Use of Best Management Practices is not mandatory, since individual 

measures may not be appropriate for use in every situation. They may be added, dropped, or 

modified through plan maintenance. 

NEPA implications: Only the wind energy development BMPs have been analyzed in a NEPA 

process. The use of other BMPs should be analyzed on a case-by-case basis in NEPA documents 

associated with projects on the public lands. These case-by-case analyses should not “tier to” the 

BMP publication as a way to dismiss environmental impacts (i.e., must still analyze and disclose 

the environmental considerations and effects associated with use of the BMP).

In this sections B.1 through B.10 reference specific documents in which to locate BMPs. Section 

B.11 lists BMPs by resource or resource use. Section B.12 is the BLM Wind Energy 

Development Program Policies and Best Management Practices (BMPs). 

B.1 Air

Air Resource BMPs: Best Management Practices for Fluid Minerals 

(USDOI, BLM) 

Developed by: U.S. Department of Interior, Bureau of Land Management

Publication reference:

Available Online:

http://www.blm.gov/style/medialib/blm/wo/MINERALS__REALTY__AND_RESOURCE_PR

OTECTION_/bmps.Par.60203.File.dat/WO1_Air%20Resource_BMP_Slideshow%2005-09-

2011.pdf

Description: Updated in May 2011, this Power Point presentation provides a summary of typical 

Best Management Practices (BMPs) for protecting air resources during oil and gas development 

and production operations. Emission reduction BMPs are provided for criteria air pollutants, 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 2

hazardous air pollutants, volatile organic compounds (an ozone precursor), and greenhouse 

gases. Emission source types include combustion emissions from mobile and stationary sources, 

fugitive emissions, and stationary source vented emissions from non-combustion sources.

Emission controls include transport reduction strategies and fugitive dust controls, as well as 

emission control techniques for drilling, completion, and production. Emission monitoring and 

maintenance strategies are also addressed. This document provides a partial list of air resource 

BMPs and includes links to many additional BMP descriptions that addressing technical and 

economic considerations.

B.2 Water

Water Quality BMPs (Best Management Practices) for Montana Forests 

Developed by: MSU Extension Service, Missoula, Montana, in cooperation with the Montana 

Department of Natural Resources & Conservation, Forestry Division Montana Logging 

Association.( Logan, Robert. 2001).

Publication Reference: Publication EB 158

Available from: Conservation Districts Bureau, DNRC, P.O. Box 20160, Helena, MT. 59620-

1601, or MSU Extension Forestry, 32 Campus Drive, Missoula, MT 59812, or MSU Extension 

Publications, P.O. Box 172040, Bozeman, MT 59717.

Description: Discusses methods for managing forest land, while protecting water quality and 

forest soils. These BMPs are intended for all forest land in Montana, including non-industrial 

private, forest industry, and state or federally-owned forests. These are preferred (but voluntary) 

methods that go beyond Montana State Streamside Management Zone Law. These BMPs

includes definitions, basic biological information, and BMPs for: Streamside Management 

Zones, road design, use, planning and location, construction, drainage and closure, stream 

crossings, soils, timber harvesting methods, reforestation, winter planning, and clean-up.

Montana Guide to the Streamside Management Zone Law

Developed by: Montana Department of Natural Resources and Conservation Service Forestry 

Bureau, in cooperation with Montana Department of Environmental Quality, Montana Logging 

Association, Montana Wood Products Association, Plum Creek Timber LP, USDA Forest 

Service, USDI Bureau of land Management.

Publication Reference: Revised 2006; reprinted November 2006

Available from: Montana Department of Natural Resources and Conservation, 2705 Spurgin 

Road, Missoula, MY 59801-3199 or local MY DNRC field offices. 

Description: MT State Law (77-5-301[1] MCA). Complementary BMPs are found in the Water 

Quality BMPs for Montana Forests (also referenced in the appendix). Provides definitions, 

stream classifications, guidelines and exceptions on the seven forest practices prohibited by 

Montana law in Stream Management Zones: 1. broadcast (Slash) burning, 2. operation of 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 3

wheeled or tracked vehicles except on established roads, 3. the forest practice of clearcutting, 4. 

the construction of roads, except when necessary to cross a stream or wetlands; 5. the handling, 

storage, application, or disposal of hazardous or toxic materials in a manner that pollutes 

streams, lakes, or wetland, or that may cause damage or injury to humans, land, animals or 

plants; 6. the side casting of road material into a stream, lake, wetland, or watercourse; and 7. the 

deposit of slash in streams, lakes, or other water bodies. 

Erosion and Sediment Control Practices: Field Manual 

Developed by: Prepared for the Montana Department of Transportation 

Publication reference: FHWA/MT-030003/8165 

Available From: National Technical Information Service, Springfield, VA 21161 

Description: The Erosion and Sediment Control Best Management Practices Construction Field 

Manual was developed to assist in design, construction, and post-construction phases of MDT 

projects. This manual provides background to concepts of Erosion and Sediment Control. Most 

of MDTs Best Management Practices are listed within the manual based on application 

categories. Each BMP is described; its applications and limitations are listed, as well as its 

design criteria. Construction phase and post-construction phase BMPs are described. This 

manual is a field guide and condensed version of the Erosion and Sediment Control Design 

Construction Best Management Practices Manual. For more detailed discussion on topic found 

within, refer to the Erosion and Sediment Control Construction Best Management Practices 

Manual. 

Erosion and Sediment Control Practices: Reference Manual 

Developed by: Prepared for the Montana Department of Transportation 

Publication reference: FHWA/MT-030003/8165 

Available From: National Technical Information Service, Springfield, VA 21161 

Description: The Erosion and Sediment Control Construction Best Management Practices 

Manual was developed to assist in the design, construction, and post-construction phases of 

MDT projects. This manual provides background to State and Federal regulations associated 

with erosion and sediment control practices including a general overview of the erosion and 

sediment processes. Best Management practices are listed within the manual based on 

application categories. Each BMP is described; its applications and limitations are listed, as well 

as its design criteria. The design phase includes development of construction plans, NOI, and 

SWPPP. Construction phase includes the finalization of the SWPPP, NOI, and the 

implementation of BMPs. Post-Construction phase includes monitoring, maintenance, and 

removal activities.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 4

Montana Non-Point Source Management Plan 

Developed by: Montana Department of Environmental Quality, Water Quality Planning Bureau, 

Watershed Protection Section 

Publication reference: 2007 

Available From: Montana Department of Environmental Quality, Water Quality Planning 

Bureau, Watershed Protection Section, P.O. Box 200901, Helena, MT 59620-0901 

Online at: 

http://www.deq.state.mt.us/wqinfo/nonpoint/2007NONPOINTPLAN/Final/NPSPlan.pdf

Description: This document describes the Montana Department of Environmental Quality’s 

(DEQ) updated strategy for controlling nonpoint source (NPS) water pollution, which is the 

state’s single largest source of water quality impairment. NPS pollution is contaminated runoff 

from the land surface that can be generated by most land use activities, including agriculture, 

forestry, urban and suburban development, mining, and others. Common NPS pollutants include 

sediment, nutrients, temperature, heavy metals, pesticides, pathogens, and salt. The purpose of 

the Montana NPS Pollution Management Plan (Plan) is: 1) to inform the state’s citizens about 

NPS pollution problems and 2) to establish goals, objectives, and both long-term and short-term 

strategies for controlling NPS pollution on a statewide basis. The goal of Montana’s NPS 

Management Program is to protect and restore water quality from the impacts of non-point 

sources of pollution in order to provide a clean and healthy environment.

National Menu of Stormwater Best Management Practices (US EPA) 

Developed by: U.S. Environmental Protection Agency

Publication reference: 

Available Online: http://cfpub.epa.gov/npdes/stormwater/menuofbmps/index.cfm

Description: The National Menu of Best Management Practices for Stormwater Phase II was 

first released in October 2000. EPA has renamed, reorganized, updated, and enhanced the 

features of the website. These revisions include the addition of new fact sheets and revisions of 

existing fact sheets. Because the field of stormwater is constantly changing, EPA expects to 

update this menu as new information and technologies become available. The Menu of BMPs is 

based on the Stormwater Phase II Rule's six minimum control measures. 

1. Public Education - BMPs for MS4s to inform individuals and households about ways 

to reduce stormwater pollution. 

2. Public Involvement - BMPs for MS4s to involve the public in the development, 

implementation, and review of an MS4's stormwater management program. 

3. Illicit Discharge Detection & Elimination - BMPs for identifying and eliminating 

illicit discharges and spills to storm drain systems. 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 5

4. Construction - BMPs for MS4s and construction site operators to address stormwater 

runoff from active construction sites. 

5. Post Construction - BMPs for MS4s, developers, and property owners to address 

stormwater runoff after construction activities have completed. 

6. Pollution Prevention/Good Housekeeping- BMPs for MS4s to address stormwater 

runoff from their own facilities and activities. 

Water-Road Interaction Technology Series Documents (USFS) May 2000

Available at: http://www.stream.fs.fed.us/water-road/

B.3 Invasive Species and Noxious Weeds 

Invasive Species: Final Vegetation Treatments using Herbicides on BLM 

in 17 Western States

Developed By: Bureau of Land Management

Publications reference: U.S. Department of the Interior Bureau of Land Management (BLM). 

2007. Vegetation Treatments Using Herbicides on BLM in 17 Western States. Programmatic 

Environmental Impact Statement, Final. ROD: September 29, 2007. BLM/WO/GI/-07/018+6711 

Available from: http://www.blm.gov/wo/st/en/prog/more/veg_eis.html

Description: Considered activities, including noxious weed and invasive terrestrial plant species 

management, hazardous fuels reduction treatments, emergency stabilization and rehabilitation 

efforts. Addressed human health and ecological risk for the use of chemical herbicides on public 

lands and provided a cumulative impact analysis addressing the use of chemical herbicides in 

conjunction with other treatment methods.

The ROD also identifies which standard operation procedures must be used with all applications 

of herbicides. Standard operation procedures are found in Appendix B of the ROD.

BLM must also implement additional measures to mitigate potential adverse environmental 

effects of using herbicides as appropriate from site specific assessments to ensure that all 

practicable means to avoid or minimize environmental harm have been adopted. All BLM 

District and Field Offices must adhere to the mitigation measures listed in Appendix C of the 

ROD.

To prevent the spread of noxious weeds and invasive plants, the BLM will follow prevention 

measures to minimize the amount of existing non-target vegetation that is disturbed during 

project planning. Preventions measures are found in Table 2-7, on page 2-24 of the Final 

Programmatic EIS (June 2007) and ROD (September 2007). (PEIS)
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 6

B.4 Wildlife Habitat

Suggested Practices for Avian Protection on Power Lines: State of the Art 

in 2006 Avian Power Line Interaction Committee (APLIC).

Developed by: First published in 1975 (Miller et al.), later updated in 1981 (Olendorff et al.) and 

most recently revised in 1996 by Edison Electric Institute and the Avian Power Line Interaction 

Committee (APLIC) in collaboration with the Raptor Research Foundation. 2006

Publication reference: CEC-500-2009-022

Available from: Santa Cruz Predatory Bird Research Group morning@ucsc.edu, Avian Power 

Line Interaction Committee www.aplic.org, Edison Electric www.eei.org, California Energy 

Commission www.energy.ca.gov

Description: Examines the history of raptor-power line interactions from biological and 

electrical standpoints; and proposes specific solutions for reducing avian-caused electrical 

outages and avian fatalities through cooperative measures between utilities, industry, and federal 

and state agencies.

Com Towers etc.

The following is an attachment from a USFWS Memo from the Director of USFWS pertaining to 

management guidance for the protection of wildlife for siting, construction, operation, and 

decommissioning of communication towers dated September 14, 2000.

Service Interim Guidelines for Recommendations on Communications Tower Siting, 

Construction, Operation, and Decommissioning

1. Any company/applicant/licensee proposing to construct a new communications tower 

should be strongly encouraged to collocate the communications equipment on an 

existing communication tower or other structure (e.g., billboard, water tower, or 

building mount). Depending on tower load factors, from 6 to 10 providers may 

collocate on an existing tower. 

2. If collocation is not feasible and a new tower or towers are to be constructed, 

communications service providers should be strongly encouraged to construct towers 

no more than 199 feet above ground level, using construction techniques which do 

not require guy wires (e.g., use a lattice structure, monopole, etc.). Such towers 

should be unlighted if Federal Aviation Administration regulations permit. 

3. If constructing multiple towers, providers should consider the cumulative impacts of 

all of those towers to migratory birds and threatened and endangered species as well 

as the impacts of each individual tower. 

4. If at all possible, new towers should be sited within existing "antenna farms" (clusters 

of towers). Towers should not be sited in or near wetlands, other known bird 

concentration areas (e.g., State or Federal refuges, staging areas, rookeries), in known 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 7

migratory or daily movement flyways, or in habitat of threatened or endangered 

species. Towers should not be sited in areas with a high incidence of fog, mist, and 

low ceilings. 

5. If taller (>199 feet AGL) towers requiring lights for aviation safety must be 

constructed, the minimum amount of pilot warning and obstruction avoidance 

lighting required by the FAA should be used. Unless otherwise required by the FAA, 

only white (preferable) or red strobe lights should be used at night, and these should 

be the minimum number, minimum intensity, and minimum number of flashes per 

minute (longest duration between flashes) allowable by the FAA. The use of solid red 

or pulsating red warning lights at night should be avoided. Current research indicates 

that solid or pulsating (beacon) red lights attract night-migrating birds at a much 

higher rate than white strobe lights. Red strobe lights have not yet been studied. 

6. Tower designs using guy wires for support which are proposed to be located in 

known raptor or waterbird concentration areas or daily movement routes, or in major 

diurnal migratory bird movement routes or stopover sites, should have daytime visual 

markers on the wires to prevent collisions by these diurnally moving species. (For 

guidance on markers, see Avian Power Line Interaction Committee (APLIC). 1994. 

Mitigating Bird Collisions with Power Lines: The State of the Art in 1994. Edison 

Electric Institute, Washington, D.C., 78 pp, and Avian Power Line Interaction 

Committee (APLIC). 1996. Suggested Practices/or Raptor Protection on Power Lines. 

Edison Electric Institute Raptor Research Foundation, Washington, D. C; 128 pp. 

Copies can be obtained via the Internet at http://www.eei.org/resources/pubcat/enviro

or by calling 1-800/334-5453).

7. Towers and appendant facilities should be sited, designed and constructed so as to 

avoid or minimize habitat loss within and adjacent to the tower "footprint." However, 

a larger tower footprint is preferable to the use of guy wires in construction. Road 

access and fencing should be minimized to reduce or prevent habitat fragmentation 

and disturbance, and to reduce above ground obstacles to birds in flight. 

8. If significant numbers of breeding, feeding, or roosting birds are known to habitually 

use the proposed tower construction area, relocation to an alternate site should be 

recommended. If this is not an option, seasonal restrictions on construction may be 

advisable in order to avoid disturbance during periods of high bird activity. 

9. In order to reduce the number of towers needed in the future, providers should be 

encouraged to design new towers structurally and electrically to accommodate the 

applicant/licensee's antennas and comparable antennas for at least two additional 

users (minimum of three users for each tower structure), unless this design would 

require the addition of lights or guy wires to an otherwise unlighted and/or unguyed 

tower. 

10. Security lighting for on-ground facilities and equipment should be down-shielded to 

keep light within the boundaries of the site. 

11. If a tower is constructed or proposed for construction, Service personnel or 

researchers from the Communication Tower Working Group should be allowed 

access to the site to evaluate bird use, conduct dead-bird searches, to place net 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 8

catchments below the towers but above the ground, and to place radar, Global 

Positioning System, infrared, thermal imagery, and acoustical monitoring equipment 

as necessary to assess and verify bird movements and to gain information on the 

impacts of various tower sizes, configurations, and lighting systems.

12. Towers no longer in use or determined to be obsolete should be removed within 12 

months of cessation of use.

In order to obtain information on the extent to which these guidelines are being implemented, 

and to identify any recurring problems with their implementation which may necessitate 

modifications, letters provided in response to requests for evaluation of proposed towers should 

contain the following request: 

"In order to obtain information on the usefulness of these guidelines in preventing bird strikes, 

and to identify any recurring problems with their implementation which may necessitate 

modifications, please advise us of the final location and specifications of the proposed tower, and 

which of the measures recommended for the protection of migratory birds were implemented. If 

any of the recommended measures cannot be implemented, please explain why they were not 

feasible."

B.5 Wildland Fire Ecology and Management 

Interagency Burned Area Emergency Response Handbook 

Guidebook version 1.3 October 2006

Developed by: DOI, Bureau of Land Management

Publication reference: Interagency Burned Area Rehabilitation Guidebook, Interpretation of 

Department of the Interior 620 DM 3, For the Burned Area Rehabilitation of Federal and Tribal 

Trust Lands, Version 1.3.

Available from: http://www.fws.gov/fire/ifcc/esr/Policy/BAR_Guidebook11-06.pdf (last 

accessed 6/10/2011)

Description: Interpretation of Department of the Interior 620 DM 3 for the burned area 

rehabilitation of Federal and Tribal Trust Lands.

Burned Area Emergency Stabilization and Rehabilitation Handbook 

Developed by: DOI, Bureau of Land Management 

Publication reference: Burned Area Emergency Stabilization and Rehabilitation Handbook (H1742-1, 2007)

Available from:

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/policy/bl

m_handbook.Par.52739.File.dat/h1742-1.pdf (last accessed 6/10/2011)
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 9

Description: This document addresses the process for implementing emergency fire 

rehabilitation projects following wildland fires.

Interagency Standards for Fire and Fire Aviation Operations (Redbook)

Developed by: Department of the Interior; Bureau of Land Management, U.S. Fish and Wildlife 

Service, and National Park Service, and Department of Agriculture; U.S. Forest Service

Available from: National Interagency Fire Center, 3833 S. Development Avenue 

Boise, Idaho 83705-5354 http://www.nifc.gov/policies/pol_ref_redbook_2011.html (last 

accessed 6/10/2011)

Description: This document addresses specific action items that are contained in the Guidance 

for Implementation of Federal Wildland Fire Management Policy (February 13, 2009).

B.6 Fluid Minerals

Best Management Practices for Oil and Gas Development on Public 

Lands

Available from: http://www.blm.gov/bmp/Technical_Information.htm

BMPs for Fluid Minerals 

Developed by: Bureau of Land Management 

Publication reference: BLM/WO/ST-06/021+3071/REV 07 

Available from: Online at: http://www.blm.gov/bmp/

Description: BMPs for oil and gas demonstrate practical ideas which may eliminate or minimize 

adverse impacts from oil and gas development to public health and the environment, landowners, 

and natural resources; enhance the value of natural and landowner resources; and reduce conflict. 

The publication reference is to the “Gold Book” which is formally titled “Surface Operating 

Standards and Guidelines for Oil and Gas Exploration and Development.” In addition, the first 

internet citation is to a location maintained by the Washington Office of the BLM containing 

general and technical information on the use and application of BMPs. The second location 

refers the reader directly to an online version of the “Gold Book.” The third and fourth locations 

refer the reader to color charts for use in selecting paint colors for oil and gas facilities. 

Western Governors’ Association Coal Bed Methane BMPs Handbook 

http://www.westgov.org/wga/initiatives/coalbed/
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 10

Handbook on Best Management Practices and Mitigation Strategies for 

Coal Bed Methane in the Montana Portion of the Powder River Basin

Prepared for: U.S. Department of Energy National Petroleum Technology Office National 

Energy Technology Laboratory Tulsa, Oklahoma

Developed by: Lead researcher: ALL Consulting Tulsa, Oklahoma; and Co-researcher ; the 

Montana Board of Oil & Gas Conservation Billings, Montana. 

Publication reference: 

Available Online: http://bogc.dnrc.state.mt.us/website/mtcbm/webmapper_cbm_info_res.htm; 

last accessed 9/8/2010

Description: This handbook is intended to serve as a resource to industry, regulators, land 

managers, and concerned citizens. The handbook presents background information on CBM 

activity in the Montana portion of the Powder River Basin (Study Area) while also presenting a 

number of Best Management Practices and Mitigation Strategies specific to CBM that have been 

successfully used throughout the United States.

B.7 Coal 

Coal Mining BMPs

Developed by: Office of Water, Office of Science and Technology, Engineering and Analysis 

Division, U.S. Environmental Protection Agency

Publication reference: COAL REMINING, BEST MANAGEMENT PRACTICES 

GUIDANCE MANUAL, MARCH 2000

Available From: Office of Water Office of Science and Technology Engineering and Analysis 

Division U.S. Environmental Protection Agency Washington DC, 20460

Description: The manual was created to support EPA’s proposal of a Re-mining subcategory 

under existing regulations for the Coal Mining industry. The purpose of this guidance manual is 

to assist operators in the development and implementation of a best management practice (BMP) 

plan specifically designed for a particular re-mining operation. This guidance manual was also 

developed to give direction to individuals reviewing remining applications and associated BMP

plans. This document is not intended as a substitute for thoughtful and thorough planning and

decision making based on site-specific information and common sense.

B.8 Mineral Materials

Mineral materials site BMP (construction and stormwater)

Developed by: U.S. Environmental Protection Agency, adopted by Montana DEQ
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 11

Publication Reference: The National Menu of Best Management Practices for Stormwater 

Phase II, EPA, October, 2000.

Description: EPA has found the practices listed in the menu of BMPs to be representative of the 

types of practices that can successfully achieve the minimum control measures. The list of BMPs 

is not all-inclusive, and it does not preclude MS4s from using other technically sound practices. 

However, in all cases the practice or set of practices chosen needs to achieve the minimum 

measure. 

EPA also recognizes that some MS4s may already be meeting the minimum measures, or that 

only one or two additional practices may be needed to achieve the measures. Existing stormwater 

management practices should be recognized and appropriate credit given to those who have 

already made progress toward protecting water quality. There is no need to spend additional 

resources for a practice that is already in existence and operational.

B.9 Livestock Grazing

Montana Best Management Practices for Grazing

Developed by: Working group with representation from: MSU College of Agriculture, Society 

of American Fisheries, Montana Stockgrowers Association, Montana Woolgrowers Association, 

USDI Bureau of Land Management, USDA Forest Service, USDA Natural Resources 

Conservation Service, Montana Farm Bureau, and Montana Department of Natural Resource and 

Conservation. 

Publication reference: N/A, first printed in 1999

Available From: Conservation Districts Bureau, and Montana Department of Natural Resources 

and Conservation, P.O. Box 201601, Helena MT 59620-1601.

Description: Describes BMPs for livestock grazing designed to protect and enhance water 

quality, soils, plant communities, and other rangeland resources. Explains how and why to use 

BMPs to manage upland rangeland, forested rangeland, and riparian areas; and describes how 

grazing BMPs fit into a grazing management plan. 

B.10 Transportation and Facilities 

Low Volume Roads Engineering Best Management Practices Field Guide 

(U.S. Forest Service) 

Developed by: US Agency for International Development (USAID) with the cooperation of the 

USDA, the Forest Service, the Office of International Programs, and the International Programs 

Department at Virginia Polytechnic Institute and State University. (Gordon Keller & James 

Sherar USDA Forest Service/USAID).
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 12

Available on line: 

http://ntl.bts.gov/lib/24000/24600/24650/Chapters/B_Preface_TableOfContents_Glossary.pdf

Description: The basic objective of this guide is to help engineers, planners, environmental 

specialists, and road managers make good decisions, protect the environment, and build good 

low-volume roads. This Low-Volume Roads Engineering Best Management Practices Field 

Guide is intended to provide an overview of the key planning, location, design, construction, and 

maintenance aspects of roads that can cause adverse environmental impacts and to list key ways 

to prevent those impacts. Best Management Practices are general techniques or design practices 

that, when applied and adapted to fit site specific conditions, will prevent or reduce pollution and 

maintain water quality. BMPs for roads have been developed by many agencies since roads often 

have a major adverse impact on water quality, and most of those impacts are preventable with 

good engineering and management practices. Roads that are not well planned or located, not 

properly designed or constructed, not well maintained, or not made with durable materials often 

have negative effects on water quality and the environment. 

Road Construction and maintenance: H-9113-1—Road Design Handbook. 

BLM Manual: M9113

Developed by:

Publication reference:

Available from:

Description:
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 13

B.11 Resource Program Best Management Practices (BMPs)

Best management practices (BMP) are those land and resource management techniques 

determined to be the most effective and practical means of maximizing beneficial results and 

minimizing conflicts and adverse environmental impacts of management actions. BMPs could 

include, but are not limited to structural and nonstructural controls, specific operations, and 

maintenance procedures. BMPs can be applied before, during and after activities to reduce or 

eliminate adverse environmental impacts. BMPs are not one-size-fits-all solutions. BMPs should 

be matched and adapted through interdisciplinary analysis to determine which management 

practices would be necessary to meet the goals and objectives in the Resource Management Plan 

(RMP). The actual practices and mitigation measures that are best for a particular site are 

evaluated through the site-specific National Environmental Policy Act (NEPA) process and vary 

to accommodate unique site-specific and local resource conditions.

BMPs described in this appendix are designed to assist in achieving the RMP objectives. These 

guidelines could apply, where appropriate, to all use authorizations, including projects initiated 

by the Bureau of Land Management (BLM). BMPs are dynamic, and should not be interpreted as 

specific direction at the same level as the RMP decisions. BMPs are selected and implemented as 

necessary, based on site-specific conditions, to meet resource objectives for specific management 

actions.

This appendix does not provide an exhaustive list of BMPs. Additional BMPs may be identified 

during an interdisciplinary process when evaluating site-specific management actions.

Implementation and effectiveness of BMPs must be monitored to determine whether the 

practices are achieving RMP goals and objectives. Adjustments could be made as necessary to 

ensure RMP goals and objectives are being met, as well as to conform with changes in BLM 

regulations, policy, direction, or new scientific information. BMPs may also be updated as new 

technology emerges. In addition, applicants can suggest alternate conditions that could 

accomplish the same result.

Because the management of environmental impacts is an ongoing process, continual refinement 

of BMP design is necessary. This process can be described in these five steps: (1) selection of 

design of a specific BMP; (2) application of the BMP; (3) monitoring; (4) evaluation; and (5) 

feedback. Data gathered through monitoring is evaluated and used to identify changes needed in 

BMP design or application or in the monitoring program.

These best management practices have been organized by the primary resource the best 

management practices could benefit or protect. Each best management practice could actually be 

implemented by a number of resource programs within the Field Office. Best management 

practices would be implemented at the discretion of the Billings Field Office on a projectspecific basis, depending on the specific characteristics of the project area and the types of 

disturbance being proposed. They may not be appropriate to implement in all cases. It has been 

assumed for impact analysis that best management practices would be implemented whenever 

appropriate.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 14

Surface Disturbing Activities

 Evaluate areas subject to surface disturbance for the presence of cultural and 

paleontological resources/values. This is usually accomplished through the 

completion of a cultural and paleontological inventory. An on-the-ground 

inspection by a qualified archaeologist and/or paleontologist is required. In cases 

where cultural and/or paleontological resources are found, the preferred response 

would be to modify the proposed action to avoid the cultural/paleontological 

resource (avoidance). If avoidance is not possible, actions would be taken to 

preserve the data or value represented by the cultural resource (mitigation).

 Evaluate areas subject to surface disturbance for the presence of threatened, 

endangered or candidate animal or plant species. This is usually accomplished 

through the completion of a biological inventory. An on-the-ground inspection by 

a qualified biologist is required. In cases where threatened, endangered, or 

candidate species are affected, the preferred response would be to modify the 

proposed action to avoid species or their habitat (avoidance). If avoidance of a 

threatened, endangered, or candidate species or its habitat is not possible, a 

Section 7 consultation with USFWS would be required, and a biological 

assessment would be prepared to recommend actions to protect the species or its 

habitat.

 Consider requiring special design and reclamation measures to protect scenic and 

natural landscape values. These may include transplanting trees and shrubs, 

mulching and fertilizing disturbed areas, use of low-profile permanent facilities, 

and painting to minimize visual contrasts. Surface disturbing activities may be 

moved to avoid sensitive areas or to reduce the visual effects of the proposal.

 Design above-ground facilities requiring painting to blend in with the surrounding 

environment.

 Implement reclamation concurrent with construction and site operations to the 

extent possible. Final reclamation actions shall be initiated within 6 months of the 

termination of operations unless otherwise approved in writing by the authorized 

officer.

 Ensure fill material is pushed into cut areas and up over back slopes. Depressions 

should not be left that would trap water or form ponds.

Air

Impacts to air resources and air quality related values (AQRVs) can be reduced using the 

following BMPs.

a) Fugitive dust emissions can be reduced by:

1) using two-track primitive roads whenever possible rather than developing a 

dirt road;
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 15

2) applying water or chemical suppressants (e.g., magnesium chloride, calcium 

chloride, lignin, sulfonate, or asphalt emulsion) to non-primitive unpaved 

roads or surfacing non-primitive unpaved roads with gravel, chip-seal, or 

asphalt; 

3) imposing vehicle speed limits on unpaved roads;

4) restricting the extent of surface impacts during construction activities and 

ongoing operations by using directional drilling to reduce the number of oil 

and gas well pads;

5) using dust abatement techniques before, during, and after surface clearing 

and excavation activities;

6) covering construction materials and stockpiled soils if they are a source of 

fugitive dust;

7) suspending construction activities during high winds;

8) adding gravel to non-reclaimed well pad areas;

9) re-vegetating areas when construction is complete;

10) locating linear facilities in the same or parallel trenches and constructing 

them at the same time; and

11) mowing rather than removing vegetation.

b) Fugitive dust and vehicle exhaust emissions related to oil and gas activity can be 

reduced by restricting vehicle trips by:

1) consolidating facilities by using directional drilling and multiwell oil and gas 

pads;

2) developing centralized liquid collection (water, produced water, and 

fracturing liquid) facilities and production (treatment and product storage) 

facilities to reduce the number and average distance of vehicle trips;

3) using shuttles or vanpools for employee commuting;

4) using automated equipment and remote telemetry; and

5) using solar power to add automated equipment in areas without access to 

electricity.

c) Non-vehicular engine exhaust emissions can be reduced by:

6) electrifying equipment when feasible;
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 16

7) achieving high levels of emission control by installing and operating lowemission equipment (i.e., drill rig engines with emissions at least as low as 

Tier 4 engine standards) or operating older equipment that has been 

retrofitted with additional emission controls such as nonselective catalytic 

reduction or catalytic oxidation; 

8) using natural gas or electric engines rather than diesel engines; 

9) using alternative energy (solar power, wind power, or both) to power new 

water source developments; and

10) converting power sources at existing water well developments to alternative 

energy sources.

d) Fugitive volatile organic compound (VOC), hazardous air pollutant (HAP), and/or 

methane (a greenhouse gas [GHG]) emissions from oil and gas activities can be 

reduced by the following BMPs when feasible:

1) using green completion technology to capture methane (and some VOC and 

HAP) emissions during completion and place the gas in sales pipelines;

2) using flaring rather than venting during completion activities, but only in 

cases where product capture is not feasible;

3) using closed tanks rather than open tanks or pits;

4) installing vapor recovery units on storage tanks;

5) using vapor balancing during condensate and oil tanker truck loading;

6) using closed-loop drilling;

7) replacing pneumatic (natural gas) pumps with electric or solar pumps;

8) optimize glycol circulation rates on glycol dehydrators;

9) replacing wet seals with dry seals in centrifugal compressors;

10) replacing worn rod packing in reciprocating compressors;

11) installing automated plunger lift systems in natural gas wells; and 

monitoring equipment leaks and repairing equipment leaks.

Soil

 Surface disturbance on sustained slopes over 25%, would require reclamation and 

mitigation planning that demonstrates how site productivity will be restored.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 17

 Surface runoff will be adequately controlled using mitigations such as: water bars, 

fiber mats, contour felling, and vegetative filters. 

 Off-site areas will be protected from accelerated erosion, such as rilling, gullying, 

piping, and mass wasting. 

 Surface-disturbing activities will not be conducted during extended wet periods.

 Construction will not be allowed when soils are frozen. 

 Construction activities will be restricted during wet or muddy conditions and will 

be designed following BMPs to control erosion and sedimentation. 

 Surface disturbing activities are to be avoided in areas of active mass movements 

(landslides and slumps) (MT-11-2)

 Erosion control and sited restoration measures will be initiated within one year of 

completion of a project. Disturbed areas will be re-contoured to provide proper 

drainage.

 Interim reclamation for long-term projects would be considered at the project 

level plan and could include seeding with BLM-approved seed mixtures.

 All surface disturbances are to be reseeded/re-vegetated with native plant species 

common to the site’s natural plant community. Site specific planning may warrant 

the use, on a case by case basis, of introduced species where difficult site 

stabilization or wildlife concerns prevail.

 Require a temporary protection surface treatment such as mulch, matting and 

netting for the reclamation of all mechanically-disturbed areas (this excludes 

wildland fire).

 Speed restrictions for areas susceptible to wind erosion i.e., 25 mph, limited travel 

 Use of saline dust inhibitors

 Areas with steep topography will be developed in accordance with the BLM Gold 

Book (United States Department of the Interior and United States Department of 

Agriculture 2007) requirements. Lease roads and constructed facilities will be 

located in accordance with the approved APD. In areas of construction, topsoil 

will be stockpiled separately from other material, and be reused in reclamation of 

the disturbed areas. Unused portions of the producing well site will have topsoil 

spread over it and will be reseeded

 Construction activities will be restricted during wet or muddy conditions and will 

be designed following BMPs to control erosion and sedimentation. If porous 

subsurface materials are encountered during pit construction, all onsite fluid pits 

will be lined. During road and utility ROW construction, surface soils will be 

stockpiled adjacent to the cuts and fills. 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 18

 Stream crossings will be designed to minimize impacts and not impede stream 

flow. Erosion control measures will be maintained and continued until adequate 

vegetation cover (as defined by BLM on a case-by-case basis) is reestablished.

Vegetation will be removed only when necessary. Water bars will be constructed 

on slopes of 3:1 or steeper. 

 Erosion control and site restoration measures will be initiated as soon as a 

particular area is no longer needed for exploration, production, staging, or access.

Disturbed areas will be recontoured to provide proper drainage. 

 The road ditches would be flat bottomed and “V” ditches not allowed. Place water 

turn outs where appropriate to lessen the water impacts upon the ditches.

 Topsoil piles may be required to be seeded following the BLM seeding policy. 

 Displaced farmland, whether in crop production or not, will be reclaimed to 

original soil productivity through adoption of standard reclamation procedures. 

 Require the use of specialized low-surface impact equipment (e.g. balloon tired 

vehicles) or helicopters, as determined by the BLM Authorized Officer, for 

activities in off-road areas where it is deemed necessary to protect fragile soils 

and other resources.

 During periods of adverse soil moisture conditions caused by climatic factors 

such as thawing, heavy rains, snow, flooding, or drought, suspend activities on 

existing roads that could create excessive surface rutting. When adverse 

conditions exist, the operator/permittee would contact the BLM Authorized 

Officer for an evaluation and decision based on soil types, soil moisture, slope, 

vegetation, and cover.

 When preparing the site for reclamation, include contour furrowing, terracing, 

reduction of steep cut and fill slopes, and the installation of water bars, as 

determined appropriate for site-specific conditions.

 Restoration requirements include reshaping, re-contouring, and/or resurfacing 

with topsoil, installation of water bars, and seeding on the contour. Removal of 

structures such as culverts, concrete pads, cattle guards, and signs would usually 

be required. Fertilization and/or fencing of the disturbance may be required.

Additional erosion control measures (e.g. fiber matting and barriers) to discourage 

road travel may be required.

Climate:

 Reduce CO2 emissions by reducing vehicle miles traveled and using fuel-efficient 

vehicles.

 Reduce CO2 emissions by using renewable energy to power equipment.

 Reduce CO2 emissions by using energy-saving techniques.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 19

 Identify and implement methods to sequester CO2.

 Reduce methane emissions from oil and gas activities by:

► capturing methane using green completion, when feasible, and beneficially 

using the gas by placing it in sales pipeline;

► flaring methane during well completion activities for which green completion 

is infeasible;

► replacing natural gas driven pneumatic equipment with solar or electrically 

powered equipment;

► optimizing glycol recirculation rates for glycol dehydrators;

► operating flash tank separators on glycol dehydrators; 

► identifying fugitive emissions from equipment leaks and repairing or 

replacing seals, valves, compressor rod packing systems, and pneumatic 

devices; and

► implementing additional GHG emission reduction strategies from the oil and 

gas BMPs located at 

http://www.blm.gov/style/medialib/blm/wo/MINERALS__REALTY__AND_

RESOURCE_PROTECTION_/bmps.Par.60203.File.dat/WO1_Air%20Resour

ce_BMP_Slideshow%2005-09-2011.pdf and the EPA Natural Gas Star 

website at http://www.epa.gov/gasstar/tools/recommended.html.

Water/Wetlands/Riparian etc.

 Avoid locating roads, trails, and landings in wetlands.

 Locate, identify, and mark riparian management areas during design of projects 

that may cause adverse impacts to riparian management areas.

 Keep open water free from slash.

 Avoid equipment operation in areas of open water, seeps, and springs.

 Use low ground pressure equipment (flotation tires or tracked) as necessary to 

minimize rutting and compaction.

 All linear and underground facilities crossing riparian areas or wetlands would be 

bored, unless an approved mitigation plan illustrates a maintenance or 

improvement to the riparian area or wetland.(alt table)

 If riparian zones are fenced to exclude grazing, fences will be 100’ from the 

stream banks, unless site-specific circumstances dictate otherwise. 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 20

 Water well and spring mitigation agreements will be used to facilitate the 

replacement of groundwater that may be lost to drawdown. Replacement water 

may require supply from offsite sources. 

 Avoid the application of fire retardant or foam within 300 feet of a stream channel 

or waterway, when possible, except for the protection of life and property. Aerial 

application and use of retardants and foams would be consistent with national 

policy guidelines established by the National Office of Fire and Aviation, as 

amended.

 Fire engines that have surfactant foam mixes in tanks must be fitted with an antisiphon (back flow protection valve) if filled directly from a stream channel.

 Construct a containment barrier around all pumps and fuel containers utilized 

within 100 feet (30.5 meters) of a stream channel. The containment barrier would 

be sufficient size to contain all fuel being stored or used on site.

 Prior to use on lands administered by the Billings Field Office, all fire suppression 

equipment from outside the planning area utilized to extract water from lakes, 

streams, ponds, or spring sources (e.g. helicopter buckets, draft hoses, and 

screens) will be thoroughly rinsed to remove mud and debris and then disinfected 

to prevent the spread of invasive aquatic species. Rinsing equipment with 

disinfectant solution will not occur within 100 feet of natural water sources (i.e. 

lakes, streams, or springs). Suppression equipment utilized to extract water from 

water sources known to be contaminated with invasive aquatic species, as 

identified by the U.S. Fish and Wildlife Service and Montana Fish, Wildlife, and 

Parks, also will be disinfected prior to use elsewhere on lands administered by the 

Billings Field Office.

 Do not dump surfactant foam mixes from fire engines within 600 feet of a stream 

channel.

 Do not conduct fire retardant mixing operations within 600 feet of a stream 

channel.

 Remove all modifications made to impound or divert stream flow by mechanical 

or other means to facilitate extraction of water from a stream for fire suppression 

efforts when suppression efforts are completed.

 When drafting or dipping water during fire operations, continuously monitor 

water levels at the site that water is being removed from. Do not allow water 

extraction to exceed the ability of the recharge inflow to maintain the water levels 

that exist at the time initial attach efforts began. If the water level drops below this 

predetermined level, all water removal would cease immediately until water 

levels are recharged.

 When possible, do not cross or terminate fire control lines at the stream channel.

Terminate control lines at the edge of the riparian zone at a location determined 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 21

appropriate to meet fire suppression objectives based on fire behavior, 

vegetation/fuel types, and fire fighter safety.

 Do not construct new roads or mechanical fire control lines or improve existing 

roads within 300 feet of a stream channel unless authorized by the BLM Field 

Manager or Authorized Officer.

 Limit stream crossings on travel routes and trails to the minimal number 

necessary to minimize sedimentation and compaction. The BLM Authorized 

Officer will determine if any impacts need to be rehabilitated by the permittee.

 Conduct mixing of herbicides and rinsing of herbicide containers and spray 

equipment only in areas that are a safe distance from environmentally sensitive 

areas and points of entry to bodies of water (storm drains, irrigation ditches, 

streams, lakes, or wells).

 When used to pump water from any pond or stream, screen the intake end of the 

draft hose to prevent fish from being ingested. Screen opening would be a 

minimum of 3/16 inch (4.7 mm).

Vegetation

 Where seeding is required, use appropriate seed mixture and seeding techniques 

approved by the BLM Authorized Officer.

 Keep removal and disturbance of vegetation to a minimum through construction 

site management (e.g. using previously disturbed areas and existing easements, 

limiting equipment/materials storage and staging sites, etc.).

 Generally conduct reclamation with native seeds that are representative of the 

indigenous species present in the adjacent habitat. Document rationale for 

potential seeding with selected nonnative species. Possible exceptions would 

include use of nonnative species for a temporary cover crop to out-compete 

weeds. In all cases, ensure seed mixtures are approved by the BLM Authorized 

Officer prior to planting.

 Certify that all interim and final seed mixes, hay, straw, and hay/straw products 

are free of plant species listed on the Montana noxious weed list.

 An area is considered to be satisfactorily reclaimed when all disturbed areas have 

been recontoured to blend with the natural topography, erosion has been 

stabilized, and an acceptable vegetative cover has been established. Use 

established guidelines to determine if revegetation has been successful.

Vegetation - Rangelands

 The perennial plant cover of the reclaimed area would equal or exceed perennial 

cover of selected comparison areas normally, adjacent habitat. If the adjacent 

habitat is severely disturbed, an ecological site description may be used as a cover 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 22

standard. Selected cover can be determined using a method as described in 

Sampling Vegetation Attributes, Interagency Technical Reference, 1996, 

BLM/RS/ST-96/002+1730. The reclamation plan for the area project would 

identify the site-specific release criteria and associated statistical methods in the 

reclamation plan or permit.

 Surface disturbing exploration operations would be subject to site specific 

stipulations found in Appendix C.

 Disturbed areas resulting from any construction will be seeded in accordance with 

the BLM seeding policy (USDI BLM, 1999c) or surface owner‘s requirements.

Depending on surface ownership, seeding is usually required during the fall or 

spring.

 Should the reseeding of sagebrush be required, different seeding times and 

techniques will be required. To the extent practicable, vegetation will be 

preserved and protected from construction operations and equipment except 

where clearing operations are required to conduct oil and gas operations, such as 

for roads, well pads, pipelines, power lines, utility lines, and structures. Clearing 

of vegetation will be restricted to the minimum area needed for construction and 

equipment. 

 Cuts and fills for new roads will be sloped to minimize erosion and to facilitate 

re-vegetation. Riparian zones will be protected by federal lease stipulations and 

permit mitigation measures. The BLM seeding policy will be followed for all 

reclamation and reseeding activities. 

 During reclamation activities, early succession plants will be used for revegetation to provide a fast growing cover crop to minimize and compete against 

noxious weeds. 

 Operator reclamation plans will be developed in consultation with the surface 

owner. Reclaimed areas reseeded with native species will require a certified 

weed-free seed mix. The seed mix used on private surface will be developed in 

consultation with the surface owner. Successful revegetation will usually require 

at least two growing seasons to ensure a self-sustaining stand of seeded species. 

 Where seeding is required, use appropriate seed mixture and seeding techniques 

approved by the BLM Authorized Officer.

 Generally, conduct reclamation with native seeds that are representative of the 

indigenous species present in the adjacent habitat. Document rationale for 

potential seeding with selected nonnative species. Possible exceptions would 

include use of nonnative species for a temporary cover crop to out-complete 

weeds. In all cases, ensure seed mixes are approved by the BLM Authorized 

Officer prior to planting

 Certify that all interim and final seed mixes, hay, straw, and hay/straw products 

are free of plant species listed on the Montana noxious weed list.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 23

 Displaced farmland, whether in crop production or not, will be reclaimed to 

original soil productivity through adoption of standard reclamation procedures. 

Vegetation - Invasive Species and Noxious Weeds

 To reduce the potential for the introduction of noxious weeds, clean off all 

equipment with pressure washing prior to operating on BLM lands. Removal of 

all dirt, grease, and plant parts that may carry noxious weed seeds or vegetative 

parts is required and may be accomplished with a pressure hose.

 Ensure all seed, hay, straw, mulch, or other vegetation material transported and 

used on public land for site stability, rehabilitation, or project facilitation is free of 

noxious weeds and noxious weed seed as certified by a qualified federal, state, or 

county officer.

 Operators will monitor noxious weed occurrence on all project areas and 

implement a noxious weed control program in cooperation with the BiFO to 

ensure noxious weed invasion does not become a problem. Reclamation 

/stabilization and maintenance materials used would be from weed seed free 

source to the extent practicable. 

 The operator, grantee, or lessee will be responsible for the control of all noxious 

weed infestations on surface disturbances. Prior to any treatment, the operator, 

grantee, or lessee will be responsible for submission of Pesticide Use Proposals 

and subsequent Pesticide Use Reports. Control measures will adhere to those 

allowed in the Final Vegetation Treatments Using Herbicides on BLM in 17 

Western States Programmatic EIS (June 2007) and ROD (September 2007).

Herbicide approvals and treatments will be monitored by BiFO. Vehicle and hand 

application of herbicides near specials status plant species would be determined 

on a case-by-case basis and allowed only when the treatment would benefit 

special status plant species. Aerial application of herbicides is prohibited within

one-half mile of special status plant locations, or other distance deemed safe by 

the Billings Field Office. 

 It is the responsibility of the operator to develop a noxious weed prevention plan 

outlining ways to control noxious weeds on lands disturbed in association with oil 

and gas lease operations. Lease-associated weed control strategies are to be 

coordinated with any involved surface owners and local weed control boards. A 

pesticide-use proposal must be reviewed and approved by BLM prior to any 

herbicide application on lands disturbed by federal oil and gas lease operations. A 

pesticide application record must be made within 24 hours after completion of 

application of herbicides. Additional measures may be required to prevent the 

spread of noxious weeds. 

 The noxious weed prevention plan must include measures to prevent the spread of 

weed seeds from any vehicles and equipment traveling from or prior to mobilizing 

it to, the project area. 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 24

 When managing weeds in areas of special status species, carefully consider the 

impacts of the treatment on such species. Whenever possible, hand spraying of 

herbicides is preferred over other methods.

 Do not conduct noxious and invasive weed control within 0.5 mile of nesting and 

brood rearing areas for special status species during the nesting and brood rearing 

season.

 Consider nozzle type, nozzle size, boom pressure, and adjuvant use and take 

appropriate measures for each herbicide application project to reduce the chance 

of chemical drift.

 All applications of approved pesticides will be conducted only by certified 

pesticide applicators or by personnel under the direct supervision of a certified 

applicator.

 Prior to commencing any chemical control program, and on a daily basis for the 

duration of the project, the certified applicator will provide a suitable safety 

briefing to all personnel working with or in the vicinity of the herbicide 

application. This briefing will include safe handling, spill prevention, cleanup, 

and first aid procedures.

 Do not apply pesticides within 440 yards (0.25 mile) of residences without prior 

notification of the resident.

 Areas treated with pesticides will be adequately posted to notify the public of the 

activity and of safe re-entry dates, if a public notification requirement is specified 

on the label of the product applied. The public notice signs will be at least 81⁄2” x 

11” in size and will contain the date of application and the date of safe re-entry. 

Wildlife Habitat and Special Status Species

 Where effective, water developments would be managed to reduce the spread of 

West Nile virus.

 Well locations and associated road and pipeline routes would be selected and 

designed to avoid disturbances to areas of high wildlife value (e.g., raptor nest 

sites, wetland areas). 

 Avoid activities and facilities that create barriers to the seasonal movements of 

big game and livestock. 

 Reserve, workover, and production pits potentially hazardous to wildlife would be 

adequately protected (e.g., fencing, netting) to prohibit wildlife access as directed 

by the BLM. 

 Install wildlife escape ramps in all watering troughs, including temporary water 

haul facilities, and open storage tanks. Pipe the overflow away from the last water 

trough on an open system to provide water at ground level.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 25

 As appropriate, mark certain trees on BLM administered lands for protection as 

wildlife trees.

 Consider seasonal distribution of large wildlife species when determining 

methods used to accomplish weed and insect control objectives.

 Temporary and permanent access roads will be avoided on south-facing slopes 

within designated crucial big game winter range, where practicable. 

 The planting of grasses, forbs, trees, or shrubs beneficial to wildlife will follow 

the BLM seeding policy. When needed, BLM will require installation of erosion 

and sedimentation control measures, such as riprap, erosion mats, mulch, bales, 

dikes or water bars. Riprap material and placement must be approved by the 

appropriate agency.

 All above-ground electrical poles and lines will be raptor-proofed to avoid 

electrocution following the criteria outlined in the Avian Power Line Interaction 

Committee (2006). ROW fencing would be kept to a minimum; if necessary, 

fences would consist of four-strand barbed wire meeting BLM Fencing Handbook 

1741-1 standards for facilitating wildlife movement. Bottom wire would be 

smooth.

 For all breeding birds (sage grouse) observed, additional surveys would be 

conducted immediately prior to construction activities to search for active nest 

sites. 

 To avoid potentially significant noise impacts, compressor engines would be 

located 2,500 feet or more from a dwelling or residence and from sage-grouse 

leks. Activities in crucial habitats would be avoided when practicable. 

 Wildlife habitat mitigation would be carried out as quickly as possible or at the 

same time as the disturbance. 

 Locatable mineral development activities would not be allowed within identified 

big game parturition areas between May 1 and June 30 or within raptor nesting 

areas from February 1 to July 31. 

 Powerlines would be buried or otherwise constructed or modified to reduce 

impacts to wildlife where possible. 

 Wildlife-proof fencing would be used on reclaimed area, in accordance with 

standards specified in BLM Fencing Handbook 1741-1, if it is determined that

wildlife species are impeding successful vegetation establishment.

 Waste water / West Nile 

► Avoiding shallow depths in the pools. Depths should be sufficient to prevent 

the growth of wetland vegetation.

► Provide steep slopes to micropool banks
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 26

► Consider mechanical aeration of permanent pools 

► Make the micropool accessible to remove silt, vegetation, and maintain the 

outlet structure

► Make the micropool accessible to treat with larvicide

► Avoid rock at the outlet structures

Fisheries Habitat and Special Status Species

 Habitat improvement techniques: including stream bank stabilization, riparian 

management, enhancing in-stream cover, providing fish passage, and preventing 

entrainment. All reasonable alternatives for maintaining adequate in-stream flows, 

physical habitat, and water quality would be used, along with purchase of private 

water rights and negotiations on timing, duration and volume of flows and drawdowns where possible.

 If riparian zones are fenced to exclude grazing, fences will be 100’ from the 

stream banks, unless site-specific circumstances dictated otherwise.

 Habitat-improvement techniques will be used where appropriate to provide 

missing habitat components or improve existing habitats: Examples of these 

techniques include stream bank stabilization, riparian management, enhancement 

of in-stream cover, provisions for fish passage, and prevention of entrainment. All 

reasonable alternatives for maintaining adequate in-stream flows, physical habitat, 

and water quality will be used, along with the purchase of private water rights and 

negotiations on timing, duration and volume of flows and draw-downs where 

possible. 

 At the project level, dead and down woody material would be retained in amounts 

that are within the range of natural variability for the plant community, to the 

extent compatible with reforestation objectives, fire hazard reduction standards, 

and public safety. 

 For stream currently occupied by any special status species, do not allow 

extraction of water from ponds or pools if stream inflow is minimal (i.e. during 

drought situations) and extraction of water would lower existing pond or pool 

level.

 Activities such as stream crossings that could directly impact sensitive or 

protected fish species will be undertaken during non-spawning periods for these 

species. In the unlikely event that multiple, sensitive, or protected fish species 

with back-to-back spawning periods are present in the same stream reach, one of 

the following options will be exercised: selecting a nearby, alternative stream 

crossing site that does not provide suitable spawning habitat for the fish species of 

concern; using a nearby, existing stream crossing over the channel to avoid 

instream disturbances; or using shore-based equipment to position and extend the 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 27

pipeline or other item (e.g., temporary bridge) across the stream, thereby avoiding 

in-channel activities.

 Habitat-improvement techniques will be used where appropriate to provide 

missing habitat components or improve existing habitats. Examples of these 

techniques include stream bank stabilization, riparian management, enhancing instream cover, provide fish passage, and prevent entrainment. All reasonable 

alternatives for maintaining adequate in-stream flows, physical habitat, and water 

quality will be used, along with purchase of private water rights and negotiations 

on timing, duration and volume of flows and draw-downs where possible.

Cultural and Heritage Resources

 Ensure a Class III cultural inventory will be conducted prior to surface 

disturbance commencement

 Ensure that all activities associated with the undertaking, within 100 meters of the 

discovery, are halted and the discovery is appropriately protected, until the BLM 

Authorized Officer issues a Notice to Proceed. A Notice to Proceed may be issued 

by the BLM under any of the following conditions:

o Evaluation of potentially eligible resource(s) results in a determination 

that the resource(s) are not eligible;

o The fieldwork phase of the treatment option has been completed; and

o The BLM has accepted a summary description of the fieldwork performed 

and a reporting schedule for that work

 The operator/permittee will inform all persons associate with the 

project/undertaking that knowingly disturbing cultural resources (historic or 

archaeological) or collecting artifacts is illegal.

 Perform viewshed reclamation when the setting of a site contributes to the 

significance of the property.

 Implement protection measures to stop, limit, or repair damage to sites. A variety 

of protection measures described in BLM Manual 8140 may be used to protect the 

integrity of sites at risk , such as signs, fencing or barriers, trash removal, target 

shooting closures, erosion control, backfilling, repairing, shoring up, or stabilizing 

structures, restricting uses and access, and closures.

 Nominate eligible sites, districts, landscapes and traditional cultural properties for 

inclusion on the National Register of Historic Places

 Encourage public/volunteer involvement in the management of cultural resources 

through participation of established site steward programs and other programs.

 Specific plans would be developed for each site type unless included in other 

integrated activity plans. Such plans would include protective measures, Native 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 28

American consultation, and regulatory compliance. These plans would also 

include but not be limited to developing a site monitoring system; identifying sites 

in need of stabilization, restoration, and protective measures (e.g. fences, 

surveillance equipment, etc.); developing research designs for selected areas/sites; 

designating sites/areas for interpretative development; identifying areas for 

cultural inventory where federal undertaking are expected to occur; and 

developing specific mitigation measures. The plan would designate sites, districts, 

and landmarks that would be nominated for inclusion in the National Register of 

Historic Places. 

 Conduct inventory according to professional standards commensurate with the 

land-use activity, environmental conditions, and the potential for cultural 

resources

 Pro-actively reduce hazardous fuels or mitigate the potential hazard around 

archaeological and cultural sites that are susceptible to destruction by fire

 Reduce or eliminate imminent threats from natural or human caused deterioration 

or conflict with other resource uses

 Identify priority geographic areas for Section 110 cultural inventories based on a 

probability for unrecorded significant resources and/or resource need

 Ensure that all authorizations for land and resource use would comply with 

Section 106 of the National Historic Preservation Act, consistent with and subject 

to the objectives established in the RMP for the proactive use of cultural 

properties in the public interest

 Provide for legitimate field research by qualified scientists and institutions

 Allow for reconstruction, stabilization, maintenance, and interpretation of selected 

sites for public enjoyment and education

 Should National Register eligible cultural resources be found during an inventory, 

impacts to them would be mitigated, generally through avoidance. Should it be 

determined the cultural resources cannot be avoided; consultation with the State 

Historic Preservation Officer would be initiated. A program on mitigation would 

be developed via consultation between the Billings Field Office, the SHPO, and 

the Advisory Council on Historic Preservation

 Conduct regular monitoring of at-risk cultural sites to protect sites from conflicts 

with other resources uses and to document natural and human caused 

deterioration 

 Establish and implement protective measures for sites, structures, objects, and 

traditional use areas that are important to Native American tribes with historical 

and cultural connections to the land, in order to maintain the viewshed, intrinsic 

values, and the auditory, visual, and aesthetic settings of the resources. Protection 

measures for undisturbed cultural resources and their natural setting would be 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 29

developed in compliance with regulatory mandates and Native American 

consultation

 Conduct consultation process to identify both the resource management concerns 

and the strategies for addressing them through an interactive dialogue with Native 

American tribes with affinity to the project area

 Consult with affiliated Native American tribes for the protection of areas and 

items of traditional life-ways and religious significance that includes, but is not 

limited to burials, rock art, traditional use areas, religious active areas, and sacred 

sites

 Limit surface disturbing activities within selected Native American traditional 

cultural and religious sites for continued use by tribes. Traditional cultural sites 

would be identified in consultation with affiliated Native American tribes 

 Protect burial sites, associated burial goods, and sacred items in accordance with 

the Native American Graves Protection and Repatriation Act and the 

Archaeological Resources Protection Act

Paleontological Resources 

 Ensure a paleontological inventory will be conducted prior to surface disturbance 

commencement in areas with a PFYC rating of 3 or higher.

 When paleontological resources of potential scientific interest are encountered 

(including all vertebrate fossils and deposits of petrified wood), leave them intact 

and immediately bring them to the attention of the BLM Authorized Officer.

 BLM APD COAs provide guidance for notifying BLM and mitigating damage to 

paleontological resources discovered during oil and gas construction activities.

Limitations include restricted use of explosives for geophysical exploration, 

monitoring requirements, and work stoppages for discovered resources. 

 Reports of theft or damage to fossil resources would be responded to by 

appropriate BLM personnel

 Conduct regular monitoring to protect areas where unauthorized use may occur

 Where scientifically significant fossils are threatened by natural hazards or 

unauthorized collection, the BLM would work with permittees and other partners 

to salvage specimens and reduce future threats to resources at risk

 The BLM would work with local communities, interest groups, individuals, and 

other agencies to enhance the public’s understanding and enjoyment of 

paleontological resources

 In areas where surface disturbance, either initiated by BLM or other land users, 

may threaten significant fossils, the BLM would follow its policy (see Manual 

and Handbook 8270-1) to assess any threat and mitigate damage.
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Proposed Resource Management Plan and Final Environmental Impact Statement

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Wildfire Ecology and Management 

 Operators are required to comply with BLM-imposed conditions during times of 

high fire danger. Such conditions may include restrictions on types of activities 

allowed, hours of operation, and requirements for maintaining certain fire 

suppression equipment at the work site. Operators must maintain a current fire 

suppression plan.

 Use appropriate management after wildland fire, including re-planting, to promote 

reforestation on forested lands which are not expected to regenerate or have not 

shown regeneration within 15 years.

 Notify valid existing land users (such as mine claimants, oil and gas lessees, 

holders of rights-of-way, livestock permittees, and other BLM permitted users of 

the area, etc.) prior to implementation of prescribed fires that may affect their 

investments.

 Remove vegetation, where appropriate, to protect BLM facilities (e.g. range 

improvements, communication sites, recreation sites, etc.)

Fire Management for Sage-Grouse Conservation

 Develop field office-specific sage-grouse tool boxes containing maps, a list of 

resource advisors, contact information, local guidance, and other relevant 

information

 Provide localized maps to dispatch offices and extended attack incident 

commanders for use in prioritizing wildlife suppression resources and designing 

suppression tactics.

 Assign a sage-grouse resource advisor to all extended attack fires in or near key 

sage-grouse habitat areas. Prior to the fire season, provide training to sage-grouse 

resource advisors on wildfire suppression organization, objectives, tactics, and 

procedures to develop a cadre of qualified individuals.

 On critical fire weather days, pre-position additional fire suppression resources to 

optimize a quick and efficient response in sage-grouse habitat areas.

 During periods of multiple fires, ensure line officers are involved in setting 

priorities.

 To the extent possible locate wildfire suppression facilities (i.e. base camps, spike 

camps, drop points, staging areas, heli-bases, etc.) in areas where physical 

disturbance to sage-grouse habitat can be minimized. These include disturbed 

areas, grasslands, near roads/trails or in other areas where there is existing 

disturbance or minimal sagebrush cover.

 Power-wash all firefighting vehicles, to the extent possible, including engines, 

water tenders, personnel vehicles, and ATVs prior to deploying in or near sagegrouse habitat areas to minimize noxious weed spread.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 31

 Minimize unnecessary cross-country vehicle travel during fire operations in sagegrouse habitat.

 Minimize burnout operations in key sage-grouse habitat areas by constructing 

direct fireline whenever safe and practical to do so.

 Utilize retardant and mechanized equipment to minimize burned acreage during 

initial attack.

 As safety allows, conduct mop-up where the black adjoins unburned islands, dog 

legs, or other habitat features to minimize sagebrush loss.

Fuels Management for Sage-Grouse Conservation

 Where applicable, design fuels treatment objectives to protect existing sagebrush 

ecosystems, modify fire behavior, restore native plants, and create landscape 

patterns which most benefit sage-grouse habitat.

 Provide training to fuels treatment personnel on sage-grouse biology, habitat 

requirements, and identification of areas utilized locally.

 Use fire prescriptions that minimize undesirable effects on vegetation or soils 

(e.g. minimize mortality of desirable perennial plant species and reduce risk of 

hydrophobicity). 

 Ensure proposed sagebrush treatments are planned with interdisciplinary input 

from BLM and/or state wildlife agency biologists and that treatment acreage is 

conservative in the context of surrounding sage-grouse seasonal habitats and 

landscape.

 Where appropriate, ensure that treatments are configured in a manner (e.g., strips) 

that promotes use by sage-grouse (See Connelly et al. 2000).

 Where applicable, incorporate roads and natural fuel breaks into fuel break 

design.

 Power-wash all vehicles and equipment involved in fuels management activities 

prior to entering the area to minimize the introduction of undesirable and/or 

invasive plants species.

 Design vegetation treatments in areas of high fire frequency to facilitate 

firefighter safety, reduce the risk of extreme fire behavior, and to reduce the risk 

and rate of fire spread to key and restoration habitats.

 Give priority for implementing specific sage-grouse habitat restoration projects in 

annual grasslands first to sites which are adjacent to or surrounded by sage-grouse 

key habitats. Annual grasslands are a second priority for restoration when the sites 

are not adjacent to key habitat but within two miles of key habitat. The third 

priority for annual grassland habitat restoration projects are sites beyond the two 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 32

miles of key habitat. The intent is to focus restoration outward from existing, 

intact habitat.

 As funding and logistics permit, restore annual grasslands to a species 

composition characterized by perennial grasses, forbs, and shrubs.

 Emphasize the use of native plant species, recognizing that non-native species 

may be necessary depending on the availability of native seed and prevailing site 

conditions.

 Remove standing and encroaching trees within at least 100 meters of occupied 

sate-grouse leks and other habitats (e.g., nesting, wintering, and brood rearing) to 

reduce the availability of perch sites for avian predators as appropriate, and 

resources permit.

 Protect wildland areas from wildfire originating on private lands, infrastructure 

corridors, and recreational areas.

 Reduce the risk of vehicle or human-caused wildfires and the spread of invasive 

species by planting perennial vegetation (e.g. green strips) paralleling road rightsof-way. 

 Strategically place and maintain pre-treated strips/areas (e.g., mowing, herbicide 

application and strictly managed grazed strips) to aid in controlling wildfire 

should wildfire occur near key habitat or important restoration areas (such as 

where investments in restoration have already been made).

Visual Resource Management 

 Camouflage of all structures/facilities (e.g. wellheads, com sites, etc.) constructed 

as a result of a BLM authorized undertaking in Class II and Class III Visual 

Resource Management Areas will be required to preserve the viewshed.

Camouflage will consist of placement of wellheads to reduce visual intrusions and 

painting of above-ground structures not requiring safety coloration an 

environmental color two shades darker than the surrounding environment.

 During implementation of vegetation treatments, create irregular margins around 

treatment areas to better maintain existing scenic character of the landscape.

 When feasible, bury utility lines on public lands when in the viewshed of 

residential or community development.

 Bury distribution powerlines or flow lines in or adjacent to access roads

 Use repetition of form, line, color, and texture to blend facilities with the 

surrounding landscape.

 Reclaim and recontour all disturbed areas, including access roads, to the original 

contour or a contour that blends with the surrounding topography.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 33

 Avoid facility placement on steep slopes, ridge tops, and hilltops.

 Reclaim unused well pads within 1 year.

Fluid Mineral Exploration and Development

 Reduce impacts to wildlife and visual resources by applying the following, as 

appropriate:

► Directional drilling of oil and gas wells

► Drilling of multiple wells from a single pad

► Closed drilling systems

► Cluster development

► Below-ground wellheads

► Remote well monitoring

► Piping of produced liquids to centralized tank batteries off site to reduce 

traffic to individual wells

► Transportation planning (e.g. to reduce road density and traffic volumes)

► Compensatory mitigation

► Noise reduction techniques and designs

► Installation of raptor anti-perch devices in greater sage-grouse habitat

► Avoidance of human activity between 8 pm and 8 am from March 1 through 

May 15 within 1⁄4 mile of the perimeter of occupied greater sage-grouse leks

► Onsite bioremediation of oil field wastes and spills

► Removal of trash, junk, waste, and other materials not in current use

 Reclaim all disturbed surface areas promptly, performing concurrent reclamation 

as necessary, and minimize the total amount of all surface disturbance.

 Ensure all surface soil is stripped prior to conducting operations, stockpiled, and 

reapplied during reclamation, regardless of soil quality. Minimize the length of 

time soil remains in stockpiles and the depth or thickness of stockpiles.

 Strip and separate soil surfaces horizons where feasible and reapply in proper 

sequence during reclamation.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 34

 Establish vegetation cover on soil stockpiles that are to be in place longer than 1 

year.

 Construct and rehabilitate temporary roads to minimize total surface disturbance, 

consistent with intended use.

 Consider temporary measures such as silt fences, straw bales, or mulching to trap 

sediment in sensitive areas until reclaimed areas are stabilized with vegetation.

 Reshape to the approximate original contour all areas to be permanently 

reclaimed, providing for proper surface drainage.

Fluid Mineral Extraction

 Applications for permit to drill would follow the best management practices as 

outlines in the BLM oil and gas Gold Book 

(http://www.blm.gov/wo/st/en/prog/energy/oil_and_gas/best_management_practi

ces/gold_book.html), as well as on-shore regulations, individual surface use plans, 

and conditions for approval that may be part of the Record of Decision for EISs or 

Decision Records for environmental assessments/Findings of No Significant 

Impacts, Documentations of NEPA Adequacy, and Categorical Exclusions 

prepared for site-specific projects.

 Notify the BLM Authorized Officer within 5 days of completion of reclamation 

work so that timely compliance inspections can be completed. 

 The operator will work with the BLM Authorized Officer on the containment of 

drilling fluids and drill hole cuttings. Adequately fence, post, or cover mud and 

separation pits, and hazardous material storage areas.

Fluid Minerals: Best Management Practices

 BMPs and standard operating procedures specific to coal bed natural gas (CBNG) 

can be found on pages 24 through 27 of the rod. Cited references are from the 

final SES

 Other more general oil and gas BMPs may be found at the following website:

http://www.blm.gov/wo/st/en/prog/energy/oil_and_gas/best_management_practic

es.html. This location is subject to periodic updates and should be reviewed as 

needed. These measures are not lease stipulations and can be added to permits for 

new activities.

Solid Minerals: Best Management Practices

BLM’s long term reclamation goals are to shape, stabilize, revegetate, or otherwise treat 

disturbed areas in order to provide a self-sustaining and productive use of the land in 

conformance with the land-use plan. Short-term reclamation goals are to stabilize disturbed areas 

and protect both disturbed and adjacent areas from unnecessary or undue degradation.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 35

Reclamation for operations conducted under 43 CFR Group 3500 for the solid leasable minerals 

other than coal and oil shale; 43 CFR Group 3600 for mineral materials; and 43 CFR Parts 3802 

and 3809 for locatable minerals. The authority for regulating surface coal mine reclamation was 

given to the Office of Surface Mining Reclamation and Enforcement when Congress enacted the 

Surface Mine Control and Reclamation Act of 1977.

The Federal Land Policy Management Act of 1976 (FLPMA) mandates that "the public lands be 

managed in a manner that will protect the quality of scientific, scenic, historical, ecological, 

environmental, air and atmospheric, water resource, and archeological values." Multiple-use 

management is defined in FLPMA (43 U.S.C. 1702(c)) and in regulations (43 CFR 1601.0-5(f)) 

as, in part, the "harmonious and coordinated management of the various resources without 

permanent impairment of the productivity of the lands and the quality of the environment with 

consideration being given to the relative values of the resources and not necessarily to the 

combination of uses that will give the greatest economic return or the greatest unit output." In 

addition, FLPMA mandates that activities be conducted so as to prevent "unnecessary or undue 

degradation of the lands" (43 U.S.C. 1732(b)).

The Mining and Minerals Policy Act of 1970 (30 U.S.C. 21a) established the policy for the 

Federal Government relating to mining and mineral development. The Act states that it is policy 

to encourage the development of “economically sound and stable domestic mining, minerals, 

metal and mineral reclamation industries.” The Act also states, however, that the Government 

should also promote the “development of methods for the disposal, control, and reclamation of 

mineral waste products, and the reclamation of mined land, so as to lessen any adverse impact of 

mineral extraction and processing upon the physical environment that may result from mining or 

mineral activities.”

BLM exercises the authority to supervise exploration, mining, and reclamation activities on 

Indian lands pursuant to 25 U.S.C. 396d and 25 CFR Parts 211, 212, and 216. The standards 

developed for reclamation and closure on Federal lands will apply to operations conducted on 

Indian lands. The Government's trust responsibilities for the various Indian tribes and entities 

require that BLM ensure proper reclamation and closure practices. The regulations governing 

operations on Indian lands require that "adequate measures be taken to avoid, minimize, or 

correct damage to the environment--land, water, and air--and to avoid, minimize, or correct 

hazards to the public health and safety" (25 CFR 216.1).

The reclamation plan shall guide both the operator and the BLM toward a planned future 

condition of the disturbed area. This requires early coordination with the operator to produce a 

comprehensive plan. The reclamation plan will serve as a binding agreement between the 

operator and the regulatory agencies for the expected reclamation condition of the disturbed 

lands and must be periodically reviewed and modified as necessary. Because this is a binding 

agreement between the operator and the regulatory agency it must be monitored on a regular 

basis to ensure the reclamation plan is current. New information concerning the ore body, use of 

different mining methods than originally planned, etc., will require the review of the previous 

NEPA analysis to determine whether additional environmental documentation is warranted.

Although the operator will usually develop the reclamation plan, appropriate pre-planning, data 

inventory, and involvement in the planning process by the regulatory agencies, is essential to 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 36

determine the optimum reclamation proposal. Most determinations as to what is expected should 

be made before the reclamation plan is approved and implemented. However, the regulations 

provide that plans can be modified to adjust to changing conditions or to correct for an oversight. 

The operator should not conduct surface disturbing activities without an approved plan. For 

notice level activities, the notice must contain an agreement to adhere to the reclamation 

requirements of the regulations and a proposal comprehensive enough for the BLM to ensure that 

unnecessary or undue degradation will not result. A reclamation plan should provide the 

following:

1. A logical sequence of steps for completing the reclamation process.

2. The specifics of how reclamation standards will be achieved.

3. An estimate of specific costs of reclamation.

4. Sufficient information for development of a basis of inspection and enforcement of 

reclamation and criteria to be used to evaluate reclamation success and reclamation 

bond release.

5. Sufficient information to determine if the reclamation plan is in conformance with the 

applicable BLM land-use plans, activity plans, and/or coastal zone management plans 

as appropriate.

In preparing and reviewing reclamation plans, the BLM and the operator must set reasonable, 

achievable, and measurable reclamation goals which are not inconsistent with the established 

land-use plans. Achievable goals will ensure reclamation and encourage operators to conduct 

research on different aspects of reclamation for different environments. These goals should be 

based on available information and techniques, should offer incentives to both parties, and 

should, as a result, generate useful information for future use.

The purposes of the reclamation plan are as follows:

1. Reclamation plans provide detailed guidelines for the reclamation process and fulfill 

Federal, State, County and other local agencies requirements. They can be used by 

regulatory agencies in their oversight roles to ensure that the reclamation measures 

are implemented, are appropriate for the site, and are environmentally sound.

2. Reclamation plans will be used by the operator throughout the operational period of 

the project and subsequent to cessation of exploration, mining, and processing 

activities. In turn, responsible agencies, including the BLM, will use the reclamation 

plan as a basis to review and evaluate the success of the reclamation program.

3. Reclamation plans should provide direction and standards to assist in monitoring and 

compliance evaluations.

Surface Disturbing Activities

For the purposes of this Handbook, surface-disturbing activities will be separated into three

broad categories.
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 Prospecting is the search for new deposits or mineral commodities. Prospecting 

activities may include: geophysical/ geochemical studies, and hand sampling of 

mineral specimens.

 Exploration includes efforts to determine the presence of economic deposits of 

mineral commodities. Exploration activities may include: road-building, drilling, 

trenching, bulk sampling, as well as any of the activities cited for prospecting.

 Development and mining or mineral processing is the process of extracting 

valuable minerals from the earth and removing impurities from these minerals. 

These activities may include: developmental drilling, road-building, underground 

mining (including shafts, portals, and adits), surface mining (including trenching, 

open pits, and strip mines), dredging, placer mining, construction of buildings and 

facilities, use of leaching solutions or other chemicals, and the creation of tailings 

disposal sites and waste dumps.

See Table II-1 for a summary of activities and mineral categories/mine status.

National Environmental Policy Act

In accordance with the NEPA (NEPA), an environmental document will be prepared for those 

mineral actions which propose surface disturbance and have not been categorically excluded for 

the purpose of identifying and mitigating the impacts to the environment. Notices under 43 CFR 

3809 are not Federal actions subject to the provisions of NEPA. The requirements and mitigation 

measures recommended in an Environmental Assessment (EA) or Environmental Impact 

Statement (EIS) shall be made a part of the reclamation plan.

Requirements for Reclamation Plan Content

The reclamation plan should be a comprehensive document submitted with the plan of 

operations, notice, exploration plan, or mining plan. It is expected that there will be changes to 

planned reclamation procedures over the life of the project. Any changes will generally be 

limited to techniques and methodology needed to attain the goals set forth in the plan. These 

changes to the plan may result from oversights or omissions from the original reclamation plan, 

permitted alterations of project activities, procedural changes in planned reclamation as a result 

of information developed by on-site revegetation research undertaken by the operator, results of 

monitoring data which indicates a new concern at the site and studies performed elsewhere, 

and/or changes in Federal/State regulations. Specific requirements are given in Manual Section 

3042.

BLM Review of the Reclamation Plan

When reviewing the reclamation plan, the AO should:

1. Immediately upon its receipt, conduct a completeness review to determine whether 

the reclamation plan is technically and administratively complete.

2. Review the plan for content, both in the office and on-site with the operator, as 

necessary.
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3. Recommend revisions, if necessary, as a result of the on-site review, NEPA 

documentation, and consultation with appropriate BLM personnel and other SMA's.

4. Ensure that the plan conforms to applicable State and Federal requirements.

5. Approve or accept the reclamation plan within the appropriate timeframes.

6. Set a schedule for inspection of operations and reclamation activities. Inspections 

must be scheduled at key points in the reclamation process, as well as at regular 

intervals.

7. Establish criteria for evaluating the success of reclamation.

When administering a reclamation plan, the AO should:

1. Conduct scheduled inspections and other inspections as necessary to ensure 

compliance with the reclamation plan. It is important to inspect work while it is in 

progress and before it is concealed by further work.

2. Document inspections in an established case file and discuss needed changes with the 

operator. These discussions with the operator should also be documented in the case 

file.

3. Ensure that required interim reclamation is current and in accordance with the plan.

4. Take appropriate action in the event of noncompliance.

5. Require revisions of the reclamation plan as necessary.

6. Monitor completed projects and evaluate the success of reclamation.

7. Accept final reclamation after a reasonable monitoring period and issue a decision. A 

reasonable monitoring period should not be less than 5 years for determining 

vegetation and erosion control success.

Mineral Material Sites: Standard Operating Procedures

Before establishing a new community pit, free use area, collection area or exclusive sale, a Plan 

of Operation and a Reclamation Plan will be prepared. The appropriate NEPA analysis will also 

be completed.

When appropriate and necessary a reclamation bond will be collected. Reclamation and 

management of the site will when appropriate consist of the following:

 Suitable topsoil, subsoil, or underlying soil parent material that is suitable for 

plant growth will be removed and stored for site restoration.

 Topcover stockpiles will be stabilized in order to prevent erosion and dust.

 The area will be fenced to exclude livestock, promote revegetation, increase 

safety and reduce theft.

 A weed control plan will be developed or weed control will be addressed in the 

Plan of Operation.

 Purchasers of material will be warned of potential weed seeds.
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 The pit walls will not exceed a safe working angle.

 Reclaimed slopes will not exceed 2.5:1 (h:v).

 Disturbed areas will be reclaimed to blend as closely as possible with natural 

contours.

 Final blending to natural contours should be considered and incorporated into the 

Plan of Operation.

 Stockpiled topcover will be replaced as soon as practically possible.

 Disturbed areas will be scarified (where necessary) and reseeded as soon as 

possible in order to reduce erosion, dust and visual effects.

 Measures may need to be taken to reduce visual effects. Visual effects should be 

considered and incorporated into the Plan of Operation.

 A seed mix approved by BLM and appropriate for the area will be used.

 Erosion controls will be incorporated into the Plan of Operation.

 If dust becomes excessive, measures will be taken to reduce the hazard.

 The site will be returned to as close as possible to the “Post Mining Land Use”

 All remaining litter or trash shall be removed from the site. 

Realty, Cadastral Survey, and Lands

 Corridors will be required for placement of roads, pipelines, and utility lines in a 

common area of disturbance wherever possible.

 Utility companies will manage vegetation in their rights-of-way, permit area or 

lease area for safe and reliable operation while minimizing impacts to vegetation 

and wildlife habitat.

 Keep removal and disturbance of vegetation to a minimum through construction 

site management e.g., using previously disturbed areas and existing easements, 

limiting equipment/materials storage and staging area sites, etc.

 Re-spread weed-free vegetation removed from the right-of-way to provide 

protection, nutrient recycling, and seed source.

 Ensure rights-of-way (ROW) and utility corridors use areas adjoining or adjacent 

to previously disturbed areas whenever possible.

 Stabilize disturbed areas within road ROWs and utility corridors with vegetation 

practices designed to hold soil in place and minimize erosion. Reestablish 

vegetation cover to increase infiltration and to provide additional protection from 

erosion.
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Proposed Resource Management Plan and Final Environmental Impact Statement

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 Construct sediment barriers when needed to slow runoff, allow deposition of 

sediment, and prevent transport from the site. Straining or filtration mechanisms 

may also be employed for the removal of sediment from runoff.

 Property boundaries and jurisdictional boundaries will be determined in their 

correct location before they are marked and posted. Land management activities 

will not be conducted to an approximate or unknown property or jurisdictional 

boundary line.

Management of Land Boundaries

1. Billings and Pompeys Pillar National Monument RMP and Cadastral Survey and Lands 

Program Background:

a. In the area covered by this RMP is the Yellowstone River. In some townships 

significant river movement has taken place. This adds a layer of complexity in 

sorting out ownership. In reaches of the river with significant river movement the 

ownership and boundary lines between public lands and adjoining lands, and 

between BLM's special areas, are ill-defined and ripe for unintentional trespass or 

encroachment. Before ownership and the boundaries of the uplands (riparian 

areas, flood plain areas, access areas), islands, and the riverbed can be determine a 

river study is required. This are complex, requires the scare skills of a riparian 

specialist, and expensive. Tools available to enable the scheduling and funding of 

such river studies are (1) for long stretches of the river, Management of Land 

Boundary Plans to identify high risk high priority areas, set priorities, develop the 

workforce plan, and formulate necessary budget planning. and (2) for individual 

action areas, Standards for Boundary Evidence Certificates. The river that is 

becoming increasingly more popular for recreational activities such as rafting, 

fishing and hunting, and significant vegetative and habitat adjustments.

2. The BLM currently monitor boundaries of special areas through development of 

Management of Land Boundary (MLB) Plans.

3. MLB Plans are multi-scale; dependent on the issue(s) monitored,

4. MLB Plans are used on special areas as (a) a risk assessment tool for unit managers to 

protect and monitor land and resources and (b) for workforce planning and out year 

budget planning.

5. MLB Plans identifies the risk to resources and/or land from antiquated surveys, and 

errors and misrepresentations in the land tenure records, e.g., river movement, island 

formation, fraudulent or obliterated surveys.

6. The Director and ASLM have pledged to develop and utilize MLB Plans as a response to 

a recent OIG Audit Report.

7. It is recommended the first iteration MLB Plan for each Planning Area be first order 

(broad scale).

8. Individual actions can be review using the Standards for Boundary Evidence process, 

fourth order (site specific).
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Livestock Grazing 

1. Water developments:

 Place water troughs off-site from springs, streams and riparian zones. To protect 

this type of water source, fence source (when possible) with wildlife friendly 

fencing materials.

 Place wildlife escape ramps in all water tanks and troughs.

 Trough height should not exceed twenty two (22) inches.

 Completely drain troughs and tanks at the end of the grazing season.

 Actual work in springs and stream beds will be done by hand where possible. If 

machinery is needed in these areas, it will be selected to minimize disturbance

 After construction of spring head boxes, troughs, pipelines, and well sites, the 

areas will be cleaned up and refuse removed.

 Cuts, fills, and excavation will be dressed and seeded to blend with surroundings.

Pipelines will be buried where possible.

 Original water sources will be protected, fenced if required, and an off-stream 

watering supply will be provided near the site.

 Size of storage tanks and troughs will be designed to accommodate expected 

needs of livestock and wildlife using each water source.

 Water will be left at the sight for wildlife. Wells will be cased to prevent cave-ins 

and well sites will be fenced.

 Storage structures will be designed to provide water for wildlife. Drinking ramps 

(wildlife ramps) will be installed and storage structure heights will not prohibit 

young wildlife from obtaining water.

2. Fences:

 Property and allotment fences will be determined in their correct location before 

they are constructed. No fence will be constructed to an approximate or unknown 

property or allotment boundary line.

 Ensure that local wildlife needs are incorporated into any construction 

specifications on contract built fence projects.

 Before removing, replacing, or modifying existing fences, cadastral survey will be 

consulted to assure property boundary or evidence of ownership will not be 

destroyed.

 Consider removing, replacing, or modifying existing fences in sage grouse 

habitat. 
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Proposed Resource Management Plan and Final Environmental Impact Statement

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 In critical sage grouse habitat, mark top wire with high-visibility marking 

material.

 Damaged gates and fences will be repaired or replaced according to landowner 

requirements at the operator‘s expense. When working on or near grazing lands, 

project-related construction equipment and vehicle movement will be minimized 

to avoid disturbance of grazing lands. Responsibilities for fence, gate, and cattle 

guard maintenance and noxious weed control will be defined in APDs, BLM 

approvals, or right-of-way (ROW) grants. Facilities will be placed to avoid or 

minimize impacts on livestock water. 

Recreation 

 For developed recreation, construct recreation sites and provide appropriate 

sanitation facilities to minimize impacts to resource values, maximize public 

health and safety, and minimize user conflicts related to approved activities and 

access within an area as appropriate.

 Use public education and/or physical barriers (such as rocks, posts, and 

vegetation) to direct or preclude uses and to minimize impacts to resource values.

 Oil and gas exploration activities will be coordinated for timing to minimize 

conflicts during recreation peak use periods.

 Dispersed recreation activity would be monitored to identify where this use may 

be impacting the vegetation resource.

 Seasonal restrictions on public vehicular access will be evaluated where there are 

wildlife habitat conflict and/or conflicts with wild horses and or wild horse habitat 

or road damage/maintenance issues.

 Do not allow surface or underground disturbance to occur within 100 yards 

(horizontally or vertically) of known cave resources.

 Where appropriate, do not allow ground disturbing activities within 100 yards of 

cave entrances, drainage areas, subsurface passages, and developed recreation 

sites. Do not dispose of waste material or chemicals in sinkholes or gates by cave 

entrances. If during construction activities any sinkholes or cave openings are 

discovered, case construction activities and notify the BLM Authorized Officer.

 The recreation permittee will assume liability for and clean up any and all releases 

of hazardous substances or oil (more than one quart) disposed on public lands as 

defined in the National Oil and Hazardous Substances Contingency Plan (40 CFR 

§ 300). The permittee will immediately notify the BLM Authorized Officer of any 

and all releases of hazardous substances or oil (more than one quart) on public 

land.
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Health and Safety

 Hazardous waste site clearance surveys will be conducted prior to surface 

disturbance commencement.

 Solid and hazardous wastes generated as a result of oil and gas lease operations 

will be disposed of in a manner and at a site approved by the appropriate 

regulating agency.

 Areas with steep topography will be developed in accordance with the BLM Gold 

Book (United States Department of the Interior and United States Department of 

Agriculture 2007) requirements. Lease roads and constructed facilities will be

located in accordance with the approved APD. In areas of construction, topsoil 

will be stockpiled separately from other material, and be reused in reclamation of 

the disturbed areas. Unused portions of the producing well site will have topsoil 

spread over it and will be reseeded.

 Construction activities will be restricted during wet or muddy conditions and will 

be designed following BMPs to control erosion and sedimentation. If porous 

subsurface materials are encountered during pit construction, all onsite fluid pits 

will be lined. During road and utility ROW construction, surface soils will be 

stockpiled adjacent to the cuts and fills. 

 Stream crossings will be designed to minimize impacts and not impede stream 

flow. Erosion control measures will be maintained and continued until adequate 

vegetation cover (as defined by BLM on a case-by-case basis) is reestablished.

Vegetation will be removed only when necessary. Water bars will be constructed 

on slopes of 3:1 or steeper. 

 Erosion control and site restoration measures will be initiated as soon as a 

particular area is no longer needed for exploration, production, staging, or access.

Disturbed areas will be re-contoured to provide proper drainage. 

 The road ditches would be flat bottomed and “V” ditches not allowed. Place water 

turn outs where appropriate to lessen the water impacts upon the ditches.

 Topsoil piles may be required to be seeded following the BLM seeding policy. 

 Take measures to isolate, control, and properly dispose of toxic and hazardous 

materials.

Transportation– Travel Management (Road design and maintenance)

 Keep access roads to a minimum and use only when necessary.

 Design roads to minimize total disturbance, conform with topography, and 

minimize disruption of natural drainage patterns.

 Locate roads on stable terrain, such as ridgetops; natural benches; and flatter 

transitional slopes near ridges, valley bottoms, and moderate sideslopes, and away 
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Proposed Resource Management Plan and Final Environmental Impact Statement

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from slumps, slide-prone areas, concave slopes, clay beds, and where rock layers 

dip parallel to the slope. Locate roads on well-drained soil types; avoid wet areas.

 Construct roads for surface drainage by using outslopes, crowns, grade changes, 

drain dips, waterbars, and /or insloping, as appropriate, during road maintenance.

Grade roads only as necessary. 

 Sloping the road base to the outside edge for surface drainage is normally 

recommended for local spurs or minor collector roads where low traffic volume 

and lower traffic speeds are anticipated. This is also recommended in situations 

where long intervals between maintenance will occur and where minimum 

excavation is wanted. Outsloping is not recommended on steep slopes. Sloping 

the road base to the inside is an acceptable practice with steep sideslopes and 

where the underlying soil formation is very rocky and not subject to appreciable 

erosion or failure.

 Crown and ditching is recommended for arterial and collector roads where traffic 

volume, speed, intensity, and user comfort are considerations. Recommended 

gradients range from 0 percent (0%) to 15 percent (15%) where crown and 

ditching may be applied, as long as adequate drainage away from the road surface 

and ditch lines is maintained.

 Retain vegetation between roads and streams to filter runoff caused by roads.

 Use culverts that pass, at a minimum, a 50 year storm event and/or have a 

minimum diameter of 13 inches for permanent stream crossings and a minimum 

diameter of 18 inches for road crossdrains.

 Strip and stockpile topsoil ahead of construction of new roads, if feasible.

Reapply soil to cut and fill slopes prior to revegetation.

 Use existing roads whenever possible rather than constructing new road systems.

B.12 BLM Wind Energy Development Program 

Policies and Best Management Practices (BMPs)

The BLM's Wind Energy Development Program will establish a number of policies and BMPs, 

provided below, regarding the development of wind energy resources on BLM administered 

public lands. The policies and BMPs will be applicable to all wind energy development projects 

on BLM-administered public lands. The policies address the administration of wind energy 

development activities, and the BMPs identify required mitigation measures that would need to 

be incorporated into project-specific Plans of Development (PODs) and right-of-way (ROW) 

authorization stipulations. Additional mitigation measures will be applied to individual projects, 

in the form of stipulations in the ROW authorization as appropriate, to address site-specific and 

species-specific issues. 

These policies and BMPs were formulated through preparation of the Final Wind Energy PElS 

(BLM 2005). The PElS included detailed, comprehensive analysis of the potential impacts of 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 45

wind energy development and relevant mitigation measures; reviews of existing, relevant 

mitigation guidance; and reviews of comments received during scoping and public review of the 

Draft PElS. Also available online at: http://windeis.anl.gov/

A.1 Policies 

 The BLM will not issue ROW authorizations for wind energy development on 

lands on which wind energy development is incompatible with specific resource 

values. Lands that will be excluded from wind energy site monitoring and testing 

and development include designated areas that are part of the National Landscape 

Conservation System (NLCS) (e.g., Wilderness Areas, Wilderness Study Areas, 

National Monuments, NCAs,1 Wild and Scenic Rivers, and National Historic and 

Scenic Trails) and Areas of Critical Environmental Concern (ACECs).2

Additional areas of land may be excluded from wind energy development on the 

basis of findings of resource impacts that cannot be mitigated and/or conflict with 

existing and planned multiple-use activities or land use plans. 

 To the extent possible, wind energy projects shall be developed in a manner that 

will not prevent other land uses, including minerals extraction, livestock grazing, 

recreational use, and other ROW uses. 

 Entities seeking to develop a wind energy project on BLM-administered lands 

shall consult with appropriate federal, state, and local agencies regarding specific 

projects as early as in the planning process as appropriate to ensure that all 

potential construction, operation, and decommissioning issues and concerns are 

identified and adequately addressed.

 The BLM will initiate government-to-government consultation with Indian Tribal 

governments whose interests might be directly and substantially affected by 

activities on BLM-administered lands as early in the planning process as 

appropriate to ensure that construction, operation, and decommissioning issues 

and concerns are identified and adequately addressed. 

 Entities seeking to develop a wind energy project on BLM-administered lands, in 

conjunction with BLM Washington Office (WO) and Field Office (FO) staff, 

shall consult with the U.S. Department of Defense (DoD) regarding the location 

of wind power projects and turbine siting as early in the planning process as 

appropriate. This consultation shall occur concurrently at both the 

installation/field level and the Pentagon/BLM WO level An interagency protocol 

agreement is being developed to establish a consultation process and to identify 

the scope of issues for consultation. Lands withdrawn for military purposes are 

under the administrative jurisdiction of the DoD or a military service and are not 

available for issuance of wind energy authorizations by the BLM. 

 

1 Wind energy development is permitted in one NCA, the California Desert Conservation Area (COCA), in accordance with the 

provisions of the California Desert Conservation Area Plan 1980. As Amended (BLM 1999).

2 Although the MPDS developed for this PElS (Section 2.2.1 and Appendix 8) did not exclude all of these lands at the screening 

level, they will be excluded from wind energy development.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 46

 The BLM will consult with the U.S. Fish and Wildlife Service (USFWS) as 

required by Section 7 of the Endangered Species Act of 1973 (ESA). The specific 

consultation requirements will be determined on a project-by-project basis. 

 The BLM will consult with the State Historic Preservation Office (SHPO) as 

required by Section 106 of the National Historic Preservation Act of 1966 

(NHPA). The specific consultation requirements will be determined on a projectby-project basis. If programmatic Section 106 consultations have been conducted 

and are adequate to cover a proposed project, additional consultation may not be 

needed.

 Existing land use plans wi1l be amended, as appropriate, to (1) adopt provisions 

of the BLM's Wind Energy Development Program, (2) identify land considered to 

be available for wind energy development, and (3) identify land that will not be 

available for wind energy development. 

 The level of environmental analysis to be required under NEPA for individual 

wind power projects will be determined at the FO level. For many projects, it may 

be determined that a tiered environmental assessment (EA) is appropriate in lieu 

of an EIS. To the extent that the PElS addresses anticipated issues and concerns 

associated with an individual project, including potential cumulative impacts, the 

BLM will tier off of the decisions embedded in the PElS and limit the scope of 

additional project-specific NEPA analyses. The site specific NEPA analyses will 

include analyses of project site configuration and micrositing considerations, 

monitoring program requirements, and appropriate mitigation measures. In 

particular, the mitigation measures discussed in Chapter 5 of the PElS may be 

consulted in determining site-specific requirements. Public involvement will be 

incorporated into all wind energy development projects to ensure that all concerns 

and issues are identified and adequately addressed. In general, the scope of the 

NEPA analyses will be limited to the proposed action on BLM-administered 

public lands; however, if access to proposed development on adjacent non-BLMadministered lands is entirely dependent on obtaining ROW access across BLMadministered public lands and there are no alternatives to that access, the NEPA 

analysis for the proposed ROW may need to assess the environmental effects 

from that proposed development. The BLM's analyses of ROW access projects 

may tier off of the PElS to the extent that the proposed project falls within the 

scope of the PElS analyses. 

 Site-specific environmental analyses will tier from the PElS and identity and 

assess any cumulative impacts that are beyond the scope of the cumulative 

impacts addressed in the PElS.

 The Categorical Exclusion (CX) applicable to the issuance of short-term ROWs 

or land use authorizations may be applicable to some site monitoring and testing 

activities. The relevant CX, established for the BLM in the DOI Departmental 

Manual 516, Chapter 11, Sec. 11.5, E(l9) (DOI 2004), encompasses "issuance of 

short-term (3 years or less) rights-of-way or land use authorizations for such uses 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 47

as storage sites, apiary sites, and construction sites where the proposal includes 

rehabilitation to restore the land to its natural or original condition." 

 The BLM will require financial bonds for all wind energy development projects 

on BLM-administered public lands to ensure compliance with the terms and 

conditions of the rights-of-way authorization and the requirements of applicable 

regulatory requirements, including reclamation costs. The amount of the required 

bond will be determined during the rights-of-way authorization process on the 

basis of site-specific and project-specific factors. The BLM may also require 

financial bonds for site monitoring and testing authorizations. 

 Entities seeking to develop a wind energy project on BLM-administered public 

lands shall develop a project-specific Plan of Development (POD) that 

incorporates all BMPs and, as appropriate, the requirements of other existing and 

relevant BLM mitigation guidance, including the BLM's interim off-site 

mitigation guidance (BLM 2005a). Additional mitigation measures will be 

incorporated into the POD and into the ROW authorization as project stipulations, 

as needed, to address site-specific and species-specific issues. The POD will 

include a site plan showing the locations of turbines, roads, power lines, other 

infrastructure, and other areas of short-and long-term disturbance. 

 The BLM will incorporate management goals and objectives specific to habitat 

conservation for species of concern (e.g., sage-grouse), as appropriate, into the 

POD for proposed wind energy projects. 

 The BLM will consider the visual resource values of the public lands involved in 

proposed wind energy development projects, consistent with BLM Visual 

Resource Management (VRM) policies and guidance. The BLM will work with 

the ROW applicant to incorporate visual design considerations into the planning 

and design of the project to minimize potential visual impacts of the proposal and 

to meet the VRM objectives of the area. 

 Operators of wind power facilities on BLM-administered public lands shall 

consult with the BLM and other appropriate federal, state, and local agencies 

regarding any planned upgrades or changes to the wind facility design or

operation. Proposed changes of this nature may require additional environmental 

analysis and/or revision of the POD. 

 The BLM's Wind Energy Development Program will incorporate adaptive 

management strategies to ensure that potential adverse impacts of wind energy 

development are avoided (if possible), minimized, or mitigated to acceptable 

levels. The programmatic policies and BMPs will be updated and revised as new 

data regarding the impacts of wind power projects become available. At the 

project-level, operators will be required to develop monitoring programs to 

evaluate the environmental conditions at the site through all phases of 

development, to establish metrics against which monitoring observations can be 

measured, to identify potential mitigation measures, and to establish protocols for 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 48

incorporating monitoring observations and additional mitigation measures into 

standard operating procedures and project-specific stipulations. 

A.2 Best Management Practices (BMPs) 

The BMPs will be adopted as required elements of project-specific PODs and/or as ROW 

authorization stipulations. They are categorized by development activity: site monitoring and 

testing, development of the POD, construction, operation, and decommissioning. The BMPs for 

development of the POD identify required elements of the POD needed to address potential 

impacts associated with subsequent phases of development. 

A.2.1 Site Monitoring and Testing 

 The area disturbed by installation of meteorological towers (i.e., footprint) shall 

be kept to a minimum. 

 Existing roads shall be used to the maximum extent feasible. If new roads are 

necessary, they shall be designed and constructed to the appropriate standard. 

 Meteorological towers shall not be located in sensitive habitats or in areas where 

ecological resources known to be sensitive to human activities (e.g., prairie 

grouse) are present. Installation of towers shall be scheduled to avoid disruption 

of wildlife reproductive activities or other important behaviors. 

 Meteorological towers installed for site monitoring and testing shall be inspected 

periodically for structural integrity. 

A.2.2 Plan of Development Preparation 

General 

 The BLM and operators shall contact appropriate agencies, property owners, and 

other stakeholders early in the planning process to identify potentially sensitive 

land uses and issues, rules that govern wind energy development locally, and land 

use concerns specific to the region. 

 Available information describing the environmental and sociocultural conditions 

in the vicinity of the proposed project shall be collected and reviewed as needed 

to predict potential impacts of the project. 

 The Federal Aviation Administration (FAA)-required notice of proposed 

construction shall be made as early as possible to identity any air safety measures 

that would be required. 

 To plan for efficient use of the land, necessary infrastructure requirements shall 

be consolidated wherever possible, and current transmission and market access 

shall be evaluated carefully. 
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 The project shall be planned to utilize existing roads and utility corridors to the 

maximum extent feasible, and to minimize the number and length/size of new 

roads, lay-down areas, and borrow areas. 

 A monitoring program shall be developed to ensure that environmental conditions 

are monitored during the construction, operation, and decommissioning phases. 

The monitoring program requirements, including adaptive management strategies, 

shall be established at the project level to ensure that potential adverse impacts of 

wind energy development are mitigated. The monitoring program shall identify 

the monitoring requirements for each environmental resource present at the site, 

establish metrics against which monitoring observations can be measured, identify 

potential mitigation measures, and establish protocols for incorporating 

monitoring observations and additional mitigation measures into standard 

operating procedures and BMPs.

 "Good housekeeping" procedures shall be developed to ensure that during 

operation the site will be kept clean of debris, garbage, fugitive trash or waste, 

and graffiti; to prohibit scrap heaps and dumps; and to minimize storage yards. 

Wildlife and Other Ecological Resources 

 Operators shall review existing information on species and habitats in the vicinity 

of the project area to identify potential concerns. 

 Operators shall conduct surveys for federal and/or state-protected species and 

other species of concern (including special status plant and animal species) within 

the project area and design the project to avoid (if possible), minimize, or mitigate 

impacts to these resources. 

 Operators shall identify important, sensitive, or unique habitats in the vicinity of 

the project and design the project to avoid (if possible), minimize, or mitigate 

impacts to these habitats (e.g., locate the turbines, roads, and ancillary facilities in 

the least environmentally sensitive areas; i.e., away from riparian habitats, 

streams, wetlands, drainages, or critical wildlife habitats). 

 The BLM will prohibit the disturbance of any population of federal listed plant 

species. 

 Operators shall evaluate avian and bat use of the project area and design the 

project to minimize or mitigate the potential for bird and bat strikes (e.g., 

development shall not occur in riparian habitats and wetlands). Scientifically 

rigorous avian and bat use surveys shall be conducted; the amount and extent of 

ecological baseline data required shall be determined on a project basis. 

 Turbines shall be configured to avoid landscape features known to attract raptors, 

if site studies show that placing turbines there would pose a significant risk to 

raptors. 
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 Operators shall determine the presence of bat colonies and avoid placing turbines 

near known bat hibernation, breeding, and maternity/nursery colonies; in known 

migration corridors; or in known flight paths between colonies and feeding areas.

 Operators shall determine the presence of active raptor nests (i.e., raptor nests 

used during the breeding season). Measures to reduce raptor use at a project site 

(e.g., minimize road cuts, maintain either no vegetation or nonattractive plant 

species around the turbines) shall be considered. 

 A habitat restoration plan shall be developed to avoid (if possible), minimize, or 

mitigate negative impacts on vulnerable wildlife while maintaining or enhancing 

habitat values for other species. The plan shall identify revegetation, soil 

stabilization, and erosion reduction measures that shall be implemented to ensure 

that all temporary use areas are restored. The plan shall require that restoration 

occur as soon as possible after completion of activities to reduce the amount of 

habitat converted at any one time and to speed up the recovery to natural habitats. 

 Procedures shall be developed to mitigate potential impacts to special status 

species. Such measures could include avoidance, relocation of project facilities or 

lay-down areas, and/or relocation of biota. 

 Facilities shall be designed to discourage their use as perching or nesting 

substrates by birds. For example, power lines and poles shall be configured to 

minimize raptor electrocutions and discourage raptor and raven nesting and 

perching. 

Visual Resources 

 The public shall be involved and informed about the visual site design elements of 

the proposed wind energy facilities. Possible approaches include conducting 

public forums for disseminating information, offering organized tours of 

operating wind developments, and using computer simulation and visualization 

techniques in public presentations. 

 Turbine arrays and turbine design shall be integrated with the surrounding 

landscape. Design elements to be addressed include visual uniformity, use of 

tubular towers, proportion and color of turbines, nonreflective paints, and 

prohibition of commercial messages on turbines.

 Other site design elements shall be integrated with the surrounding landscape. 

Elements to address include minimizing the profile of the ancillary structures, 

burial of cables, prohibition of commercial symbols, and lighting. Regarding 

lighting, efforts shall be made to minimize the need for and amount of lighting on 

ancillary structures. 

Roads

 An access road siting and management plan shall be prepared incorporating 

existing BLM standards regarding road design, construction, and maintenance 
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such as those described in the BLM 9113 Manual (BLM 1985) and the Surface 

Operating Standards for Oil and Gas Exploration and Development (RMRCC 

1989) (i.e., the Gold Book). 

Ground Transportation 

 A transportation plan shall be developed, particularly for the transport of turbine 

components, main assembly cranes, and other large pieces of equipment. The plan 

shall consider specific object sizes, weights, origin, destination, and unique 

handling requirements and shall evaluate alternative transportation approaches. In 

addition, the process to be used to comply with unique state requirements and to 

obtain all necessary permits shall be clearly identified. 

 A traffic management plan shall be prepared for the site access roads to ensure 

that no hazards would result from the increased truck traffic and that traffic flow 

would not be adversely impacted. This plan shall incorporate measures such as 

informational signs, flaggers when equipment may result in blocked throughways, 

and traffic cones to identify any necessary changes in temporary lane 

configuration. 

Noise 

 Proponents of a wind energy development project shall take measurements to 

assess the existing background noise levels at a given site and compare them with 

the anticipated noise levels associated with the proposed project. 

Noxious Weeds and Pesticides 

 Operators shall develop a plan for control of noxious weeds and invasive species, 

which could occur as a result of new surface disturbance activities at the site. The 

plan shall address monitoring, education of personnel on weed identification, the 

manner in which weeds spread, and methods for treating infestations. The use of 

certified weed-free mulching shall be required. If trucks and construction 

equipment are arriving from locations with known invasive vegetation problems, 

a controlled inspection and cleaning area shall be established to visually inspect 

construction equipment arriving at the project area and to remove and collect 

seeds that may be adhering to tires and other equipment surfaces. 

 If pesticides are used on the site, an integrated pest management plan shall be 

developed to ensure that applications would be conducted within the framework 

of BLM and DOI policies and entail only the use of EPA-registered pesticides. 

Pesticide use shall be limited to nonpersistent, immobile pesticides and shall only 

be applied in accordance with label and application permit directions and 

stipulations for terrestrial and aquatic applications. 

Cultural/Historic Resources 

 The BLM will consult with Indian Tribal governments early in the planning 

process to identify issues regarding the proposed wind energy development, 
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including issues related to the presence of cultural properties, access rights, 

disruption to traditional cultural practices, and impacts to visual resources 

important to the Tribe(s). 

 The presence of archaeological sites and historic properties in the area of potential 

effect shall be determined on the basis of a records search of recorded sites and 

properties in the area and/or, depending on the extent and reliability of existing 

information, an archaeological survey. Archaeological sites and historic properties 

present in the area of potential effect shall be reviewed to determine whether they 

meet the criteria of eligibility for listing on the National Register of Historic 

Places (NRHP). 

 When any rights-of-way application includes remnants of a National Historic 

Trail, is located within the viewshed of a National Historic Trail's designated 

centerline, or includes or is within the viewshed of a trail eligible for listing on the 

NRHP, the operator shall evaluate the potential visual impacts to the trail 

associated with the proposed project and identify appropriate mitigation measures 

for inclusion as stipulations in the POD. 

 If cultural resources are present at the site, or if areas with a high potential to 

contain cultural material have been identified, a cultural resources management 

plan (CRMP) shall be developed. This plan shall address mitigation activities to 

be taken for cultural resources found at the site. Avoidance of the area is always 

the preferred mitigation option. Other mitigation options include archaeological 

survey and excavation (as warranted) and monitoring. If an area exhibits a high 

potential, but no artifacts were observed during an archaeological survey, 

monitoring by a qualified archaeologist could be required during all excavation 

and earthmoving in the high-potential area. A report shall be prepared 

documenting these activities. The CRMP also shall (1) establish a monitoring 

program, (2) identify measures to prevent potential looting/vandalism or erosion 

impacts, and (3) address the education of workers and the public to make them 

aware of the consequences of unauthorized collection of artifacts and destruction 

of property on public land. 

Paleontological Resources 

 Operators shall determine whether paleontological resources exist in a project 

area on the basis of the sedimentary context of the area, a records search for past 

paleontological finds in the area, and/or, depending on the extent of existing 

information, a paleontological survey. 

 If paleontological resources are present at the site, or if areas with a high potential 

to contain paleontological material have been identified, a paleontological 

resources management plan shall be developed. This plan shall include a 

mitigation plan for collection of the fossils; mitigation could include avoidance, 

removal of fossils, or monitoring. If an area exhibits a high potential but no fossils 

were observed during survey, monitoring by a qualified paleontologist could be 

required during all excavation and earthmoving in the sensitive area. A report 
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Appendix B B- 53

shall be prepared documenting these activities. The paleontological resources 

management plan also shall establish a monitoring program, (2) identify measures 

to prevent potential looting/vandalism or erosion impacts, and (3) address the 

education of workers and the public to make them aware of the consequences of 

unauthorized collection of fossils on public land. 

Hazardous Materials and Waste Management 

 Operators shall develop a hazardous materials management plan addressing 

storage, use, transportation, and disposal of each hazardous material anticipated to 

be used at the site. The plan shall identify all hazardous materials that would be 

used, stored, or transported at the site. It shall establish inspection procedures, 

storage requirements, storage quantity limits, inventory control, nonhazardous 

product substitutes, and disposition of excess materials. The plan shall also 

identify requirements for notices to federal and local emergency response 

authorities and include emergency response plans. 

 Operators shall develop a waste management plan identifying the waste streams 

that are expected to be generated at the site and addressing hazardous waste 

determination procedures, waste storage locations, waste-specific management 

and disposal requirements, inspection procedures, and waste minimization 

procedures. This plan shall address all solid and liquid wastes that may be 

generated at the site. 

 Operators shall develop a spill prevention and response plan identifying where 

hazardous materials and wastes are stored on site, spill prevention measures to be 

implemented, training requirements, appropriate spill response actions for each 

material or waste, the locations of spill response kits on site, a procedure for 

ensuring that the spill response kits are adequately stocked at all times, and 

procedures for making timely notifications to authorities. 

Storm Water 

 Operators shall develop a storm water management plan for the site to ensure 

compliance with applicable regulations and prevent off-site migration of 

contaminated storm water or increased soil erosion. 

Human Health and Safety 

 A safety assessment shall be conducted to describe potential safety issues and the 

means that would be taken to mitigate them, including issues such as site access, 

construction, safe work practices, security, heavy equipment transportation, traffic 

management, emergency procedures, and fire control. 

 A health and safety program shall be developed to protect both workers and the 

general public during construction, operation, and decommissioning of a wind 

energy project. Regarding occupational health and safety, the program shall 

identify all applicable federal and state occupational safety standards; establish 

safe work practices for each task (e.g., requirements for personal protective 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix B B- 54

equipment and safety harnesses; Occupational Safety and Health Administration 

[OSHA] standard practices for safe use of explosives and blasting agents; and 

measures for reducing occupational electric and magnetic fields [EMF] 

exposures); establish fire safety evacuation procedures; and define safety 

performance standards (e.g., electrical system standards and lightning protection 

standards). The program shall include a training program to identify hazard 

training requirements for workers for each task and establish procedures for 

providing required training to all workers. Documentation of training and a 

mechanism for reporting serious accidents to appropriate agencies shall be 

established. 

 Regarding public health and safety, the health and safety program shall establish a 

safety zone or setback for wind turbine generators from residences and occupied 

buildings, roads, rights-of-ways, and other public access areas that is sufficient to 

prevent accidents resulting from the operation of wind turbine generators. It shall 

identify requirements for temporary fencing around staging areas, storage yards, 

and excavations during construction or decommissioning activities. It shall also 

identify measures to be taken during the operation phase to limit public access to 

hazardous facilities (e.g. permanent fencing would be installed only around 

electrical substations and turbine tower access doors would be locked).

 Operators shall consult with local planning authorities regarding increased traffic 

during the construction phase, including an assessment of the number of vehicles 

per day, their size, and type. Specific issues of concern (e.g., location of school 

bus routes and stops) shall be identified and addressed in the traffic management 

plan. 

 If operation of the wind turbines is expected to cause significant adverse impacts 

to nearby residences and occupied buildings from shadow flicker, low-frequency 

sound, or EMF, site-specific recommendations for addressing these concerns shall 

be incorporated into the project design (e.g., establishing a sufficient setback from 

turbines). 

 The project shall be planned to minimize electromagnetic interference (EMI) 

(e.g., impacts to radar, microwave, television, and radio transmissions) and 

comply with Federal Communications Commission [FCC] regulations. Signal 

strength studies shall be conducted when proposed locations have the potential to 

impact transmissions. Potential interference with public safety communication 

systems (e.g., radio traffic related to emergency activities) shall be avoided. 

 The project shall be planned to comply with FAA regulations, including lighting 

regulations, and to avoid potential safety issues associated with proximity to 

airports, military bases or training areas, or landing strips. 

 Operators shall develop a fire management strategy to implement measures to 

minimize the potential for a human-caused fire. 
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Proposed Resource Management Plan and Final Environmental Impact Statement

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A.2.3 Construction 

General 

 All control and mitigation measures established for the project in the POD and the 

resource-specific management plans that are part of the POD shall be maintained 

and implemented throughout the construction phase, as appropriate.

 The number and size/length of roads, temporary fences, lay-down areas, and 

borrow areas shall be minimized. Topsoil from all excavations and construction 

activities shall be salvaged and reapplied during reclamation. 

 All areas of disturbed soil shall be reclaimed using weed-free native grasses, 

forbs, and shrubs. Reclamation activities shall be undertaken as early as possible 

on disturbed areas. 

 All electrical collector lines shall be buried in a manner that minimizes additional 

surface disturbance (e.g., along roads or other paths of surface disturbance). 

Overhead lines may be used in cases where burial of lines would result in further 

habitat disturbance. 

 Operators shall identify unstable slopes and local factors that can induce slope 

instability (such as groundwater conditions, precipitation, earthquake activities, 

slope angles, and the dip angles of geologic strata). Operators also shall avoid 

creating excessive slopes during excavation and blasting operations. Special 

construction techniques shall be used where applicable in areas of steep slopes, 

erodible soil, and stream channel crossings.

 Erosion controls that comply with county, state, and federal standards shall be 

applied. Practices such as jute netting, silt fences, and check dams shall be applied 

near disturbed areas.

Wildlife

 Guy wires on permanent meteorological towers shall be avoided, however, may 

be necessary on temporary meteorological towers installed during site monitoring 

and testing.

 In accordance with the habitat restoration plan, restoration shall be undertaken as 

soon as possible after completion of construction activities to reduce the amount 

of habitat converted at any one time and to speed up the recovery to natural 

habitats.

 All construction employees shall be instructed to avoid harassment and 

disturbance of wildlife, especially during reproductive (e.g. courtship and nesting) 

seasons. In addition, pets shall not be permitted on site during construction.
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Proposed Resource Management Plan and Final Environmental Impact Statement

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Visual Resources

 Operators shall reduce visual impacts during construction by minimizing areas of 

surface disturbance, controlling erosion, using dust suppression techniques, and 

restoring exposed soils as closely as possible to their original contour and 

vegetation. 

Roads 

 Existing roads shall be used, but only if in safe and environmentally sound 

locations. If new roads are necessary, they shall be designed and constructed to 

the appropriate standard and be no higher than necessary to accommodate their 

intended functions (e.g., traffic volume and weight of vehicles). Excessive grades 

on roads, road embankments, ditches, and drainages shall be avoided, especially 

in areas with erodible soils. Special construction techniques shall be used, where 

applicable. Abandoned roads and roads that are no longer needed shall be 

recontoured and revegetated. 

 Access roads and on-site roads shall be surfaced with aggregate materials, 

wherever appropriate. 

 Access roads shall be located to follow natural contours and minimize side hill 

cuts.

 Roads shall be located away from drainage bottoms and avoid wetlands, if 

practicable. 

 Roads shall be designed so that changes to surface water runoff are avoided and 

erosion is not initiated. 

 Access roads shall be located to minimize stream crossings. All structures 

crossing streams shall be located and constructed so that they do not decrease 

channel stability or increase water velocity. Operators shall obtain all applicable 

federal and state permits. 

 Existing drainage systems shall not be altered, especially in sensitive areas such 

as erodible soils or steep slopes. Potential soil erosion shall be controlled at 

culvert outlets with appropriate structures. Catch basins, roadway ditches, and 

culverts shall be cleaned and maintained regularly. 

Ground Transportation 

 Project personnel and contractors shall be instructed and required to adhere to 

speed limits commensurate with road types, traffic volumes, vehicle types, and 

site-specific conditions, to ensure safe and efficient traffic flow and to reduce 

wildlife collisions and disturbance and airborne dust. 

 Traffic shall be restricted to the roads developed for the project. Use of other 

unimproved roads shall be restricted to emergency situations. 
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 Signs shall be placed along construction roads to identify speed limits, travel 

restrictions, and other standard traffic control information. To minimize impacts 

on local commuters, consideration shall be given to limiting construction vehicles 

traveling on public roadways during the morning and late afternoon commute 

time. 

Air Emissions 

 Dust abatement techniques shall be used on unpaved, unvegetated surfaces to 

minimize airborne dust. 

 Speed limits (e.g., 25 mph [40 kph]) shall be posted and enforced to reduce 

airborne fugitive dust. 

 Construction materials and stockpiled soils shall be covered if they are a source of 

fugitive dust. 

 Dust abatement techniques shall be used before and during surface clearing, 

excavation, or blasting activities. 

Excavation and Blasting Activities 

 Operators shall gain a clear understanding of the local hydrogeology. Areas of 

groundwater discharge and recharge and their potential relationships with surface 

water bodies shall be identified. 

 Operators shall avoid creating hydrologic conduits between two aquifers during 

foundation excavation and other activities. 

 Foundations and trenches shall be backfilled with originally excavated material as 

much as possible. Excess excavation materials shall be disposed of only in 

approved areas or, if suitable, stockpiled for use in reclamation activities. 

 Explosives shall be used only within specified times and at specified distances 

from sensitive wildlife or streams and lakes, as established by the BLM or other 

federal and state agencies. 

 Borrow material shall be obtained only from authorized and permitted sites. 

Existing sites shall be used in preference to new sites. 

Noise

 Noisy construction activities (including blasting) shall be limited to the least 

noise-sensitive times of day (i.e., daytime only between 7 a.m. and 10 p.m.)

 All equipment shall have sound-control devices no less effective than those 

provided on the original equipment. All construction equipment used shall be 

adequately muffled and maintained.

 All stationary construction equipment (i.e. compressors and generators) shall be 

located as far as possible from nearby residences.
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 If blasting or other noisy activities are required during the construction period, 

nearby residents shall be notified in advance.

Cultural and Paleontological Resources 

 Unexpected discovery of cultural or paleontological resources during construction 

shall be brought to the attention of the responsible BLM authorized officer 

immediately. Work shall be halted in the vicinity of the find to avoid further 

disturbance to the resources while they are being evaluated and appropriate 

mitigation measures are being developed. 

Hazardous Materials and Waste Management

 Secondary containment shall be provided for all on-site hazardous materials and 

waste storage, including fuel. In particular, fuel storage (for construction vehicles 

and equipment) shall be a temporary activity occurring only for as long as is 

needed to support construction activities. 

 Wastes shall be properly containerized and removed periodically for disposal at 

appropriate off-site permitted disposal facilities.

 In the event of an accidental release to the environment, the operator shall 

document the event, including a root cause analysis, appropriate corrective actions 

taken, and a characterization of the resulting environmental or health and safety 

impacts. Documentation of the event shall be provided to the BLM authorized 

officer and other federal and state agencies, as required. 

 Any wastewater generated in association with temporary, portable sanitary 

facilities shall be periodically removed by a licensed hauler and introduced into an 

existing municipal sewage treatment facility. Temporary, portable sanitary 

facilities provided for construction crews shall be adequate to support expected 

on-site personnel and shall be removed at completion of construction activities. 

Public Health and Safety 

 Temporary fencing shall be installed around staging areas, storage yards, and 

excavations during construction to limit public access. 

A.2.4 Operation

General 

 All control and mitigation measures established for the project in the POD and the 

resource-specific management plans that are part of the POD shall be maintained 

and implemented throughout the operational phase, as appropriate. These control 

and mitigation measures shall be reviewed and revised, as needed, to address 

changing conditions or requirements at the site, throughout the operational phase. 

This adaptive management approach would help ensure that impacts from 

operations are kept to a minimum. 
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 Inoperative turbines shall be repaired, replaced, or removed in a timely manner. 

Requirements to do so shall be incorporated into the due diligence provisions of 

the rights-of-way authorization. Operators will be required to demonstrate due 

diligence in the repair, replacement, or removal of turbines; failure to do so could 

result in termination of the rights-of-way authorization. 

Wildlife 

 Employees, contractors, and site visitors shall be instructed to avoid harassment 

and disturbance of wildlife, especially during reproductive (e.g., courtship and 

nesting) seasons. In addition, any pets shall be controlled to avoid harassment and 

disturbance of wildlife. 

 Observations of potential wildlife problems, including wildlife mortality, shall be 

reported to the BLM authorized officer immediately. 

Ground Transportation

 Ongoing ground transportation planning shall be conducted to evaluate road use, 

minimize traffic volume, and ensure that roads are maintained adequately to 

minimize associated impacts.

Monitoring Program 

 Site monitoring protocols defined in the POD shall be implemented. These will 

incorporate monitoring program observations and additional mitigation measures 

into standard operating procedures and BMPs to minimize future environmental 

impacts. 

 Results of monitoring program efforts shall be provided to the BLM authorized 

officer. 

Public Health and Safety 

 Permanent fencing shall be installed and maintained around electrical substations, 

and turbine tower access doors shall be locked to limit public access. 

 In the event an installed wind energy development project results in EMI, the 

operator shall work with the owner of the impacted communications system to 

resolve the problem. Additional warning information may also need to be 

conveyed to aircraft with onboard radar systems so that echoes from wind 

turbines can be quickly recognized. 

A.2.5 Decommissioning 

General 

 Prior to the termination of the rights-of-way authorization, a decommissioning 

plan shall be developed and approved by the BLM. The decommissioning plan 

shall include a site reclamation plan and monitoring program. 
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Appendix B B- 60

 All management plans, BMPs, and stipulations developed for the construction 

phase shall be applied to similar activities during the decommissioning phase. 

 All turbines and ancillary structures shall be removed from the site.

 Topsoil from all decommissioning activities shall be salvaged and replied during 

final reclamation.

 All areas of disturbed soil shall be reclaimed using weed-free native shrubs, 

grasses, and forbs.

 The vegetation cover, composition, and diversity shall be restored to values 

commensurate with the ecological setting.