United States Department ofthe Interior

BUREAU OF LAND MANAGEMENT

Billings Field Office

5001 Southgate Drive

Billings, Montana 59101-4669

In Reply Refer To: www.blm.gov/mt

1610(MT010.CSB)

June 1,2015

Dear Reader:

Enclosed is the Proposed Resource Management Plan (PRMP) and Final Environmental Impact

Statement (FEIS) for Billings and Pompeys Pillar National Monument. The Bureau ofLand

Management (BLM) prepared the PRMP^EIS inconsultation with cooperating agencies, taking

into account public comments received during this planning effort. The PRMP provides a

framework for the future management direction and appropriate use ofthe Billings Field Office

planning area, located in Big Horn (portions). Carbon, Golden Valley, Musselshell, Stillwater,

Sweet Grass, Wheatland, and Yellowstone Counties, Montana, and 4,298 acres in Big Horn

County, Wyoming. The document contains both land use planning decisions and implementation

decisions to guide the BLM's management ofthe Billings Field Office planning area.

This PRMP/FEIS is one of 15 sub-regional planning efforts being conducted as part ofthe BLM's

National Greater Sage-Grouse Planning Strategy. The PRMP identifies conservation measures to

conserve, enhance and/or restore Greater Sage-Grouse (GRSG) habitat in response to the U.S.

Fish and Wildlife Service's (USFWS) March 2010 "warranted, but precluded" Endangered

Species Act listing petition. The USFWS found that the inadequacy ofregulatory mechanisms

was identified as a significant threat to GRSG in their finding on the petition to list the GRSG.

The RMP conservation measures were identified as the BLM's principal regulatory mechanism.

This PRMP and FEIS have been developed in accordance with the National Environmental

Policy Act of 1969, as amended, and the Federal Land Policy and Management Act of 1976, as

amended. The PRMP is largely based on Alternative D, the preferred alternative in the Draft

Resource Management Plan/Environmental Impact Statement (DRMP/DEIS), which was

released on March 29,2013. The PRMP/FEIS contains the Proposed Plan, a summary of

changes made between the DRMP/DEIS and PRMP/FEIS, impacts ofthe Proposed Plan, a

summaryof the written and verbal commentsreceivedduring the public review period for the

DRMP/DEIS, and responses to the comments.

Pursuant to BLM's planning regulations at 43 CFR 1610.5-2, any person who participated in the

planningprocess for this PRMP, and has an interest which is or may be adversely affectedby the

planning decisions, mayprotestapproval of the planning decisions within30 daysfrom datethe

Environmental ProtectionAgency (EPA) publishesthe Notice ofAvailabilityofthe FEIS in the

Federal Register. For further information on filing a protest, please see the accompanying

protest regulations in the pagesthatfollow (labeled as Attachment 1). The regulations specify

the required elements of your protest. Takecareto document all relevant facts. As much as

possible, reference or cite the planning documents or available planning records (e.g. meeting

minutes or summaries, correspondence, etc.).

Emailed protests will notbe accepted as valid protests unless theprotesting party also provides

theoriginal letter by either regular mail or overnight delivery postmarked bythe close ofthe

protest period. Under these conditions, the BLM will consider theemailed protest as anadvance
copy and will afford it fiill consideration. If you wish to provide the BLM with such advance

notification, please direct emailed protests to protest@blm.gov.

All protests must be in writing and mailed to one ofthe following addresses:

Regular Mail: Overnight Deliverv:

Director (210) Director (210)

Attn: Protest Coordinator Attn: Protest Coordinator

P.O. Box 71383 20 M Street SE, Room 2134LM

Washington, D.C. 20024-1383 Washington, D.C. 20003

Before including your address, phone number, email address, or other personal identifying

information in your protest, be advised that your entire protest - including your personal

identifying information - may be made publicly available at any time. While you can ask us in

your protest to withhold from public review your personal identifying information, we cannot

guarantee that we will be able to do so.

The BLM Director will make every attempt to promptly render a decision on each protest. The

decision will be in writing and will be sent to the protesting party by certified mail, return receipt

requested. The decision ofthe BLM Director shall be the final decision ofthe Department ofthe

Interior on each protest. Responses to protest issues will be compiled and formalized in a

Director's Protest Resolution Report made available following issuance ofthe decisions.

Upon resolution of all land use plan protests, the BLM will issue an Approved RMP and Record

ofDecision (ROD). The Approved RMP and ROD will be mailed or made available

electronically to all who participated in the planning process and will be available on the BLM

website at http://on.doi.gov/lEJBdaE.

Unlike land use planning decisions, implementation decisions included in this PRMP/FEIS are

not subject to protest under the BLM planning regulations, but are subject to an administrative

review process, through appeals to the Office of Hearings and Appeals (OHA), Interior Board of

Land Appeals (IBLA) pursuant to 43 CFR, Part 4 Subpart E. Implementation decisions

generally constitute the BLM's final approval allowing on-the-ground actions to proceed. Where

implementation decisions are made as part of the land use planning process, they are still subject

to the appeals process or other administrative review as prescribed by specific resource program

regulations once the BLM resolves the protests to land use planning decisions and issues an

Approved RMP and ROD. The Approved RMP and ROD will, therefore, identify the

implementation decisions made in the plan that may be appealed to the Office ofHearing and

Appeals.

Sincerely,

James M.

// Field Man

Enclosure

1-Protest Regulations
Protest Regulations

[CITE: 43CFR1610.5-2]

TITLE 43-PUBLIC LANDS: INTERIOR

CHAPTER II-BUREAU OF LAND MANAGEMENT, DEPARTMENT OF THE INTERIOR

PART 1600-PLANNING, PROGRAMMING, BUDGETING-Table ofContents

Subpart 1610~Resource Management Planning

Sec. 1610.5-2 Protest Procedures.

(a) Any person who participated in the planning process and has an interest which is or may be

adversely affected by the approval or amendment of a resource management plan may protest

such approval or amendment. A protest may raise only those issues which were submitted

for the record during the planning process.

(1) The protest shall be in writing and shall be filed with the Director. The protest shall be

filed within 30 days ofthe date the Environmental Protection Agency published the

notice ofreceipt ofthe final environmental impact statement containing the plan or

amendment in the Federal Register. For an amendment not requiring the preparation of

an environmental impact statement, the protest shall be filed within 30 days ofthe

publication ofthe notice ofits effective date.

(2) The protest shall contain:

(i) The name, mailing address, telephone number and interest ofthe person filing

the protest;

(ii) A statement ofthe issue or issues being protested;

(iii) A statement ofthe part or parts ofthe plan or amendment being protested;

(iv) A copy of all documents addressing the issue or issues that were submitted

duringthe planningprocessby the protesting party or an indication of the date

the issue or issues were discussed for the record; and

(v) A concisestatementexplaining why the StateDirector's decisionis believed to

be wrong.

(3) The Director shall promptly render a decision on the protest.

(b) Thedecision shallbe in writing and shall setforth the reasons for the decision. Thedecision

shallbe sentto the protesting partyby certified mail, return receipt requested. Thedecision

ofthe Director shall be the final decision ofthe Department ofthe Interior.

Attachment 1
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Volume 1 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 
Abstract - 1 

Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan 

and 

Final Environmental Impact Statement 

1. Responsible Agency: 

U.S. Department of the Interior, Bureau of Land Management 

2. Draft ( ) Final (X ) 

3. Type of Action: Administrative (X) Legislative ( ) 

4. Abstract: This Proposed Resource Management Plan (RMP) and Final Environmental Impact 

Statement (EIS) describes and analyzes four alternatives for the planning and management of 

public lands and resources administered by the Bureau of Land Management (BLM), Billings 

Field Office located in south central Montana in Carbon, Golden Valley, Musselshell, Stillwater, 

Sweet Grass, Wheatland, and Yellowstone counties, Montana, and portions of Big Horn County, 

Montana, and portions of Big Horn County, Wyoming. These alternatives are Alternative A 

(continuation of current management or the No Action Alternative); Alternatives B and C, and 

Alternative D (Proposed Alternative). Major RMP issues include managing for desired plant 

communities; maintaining or improving wildlife and fisheries habitat and controlling invasive 

species; conservation and recovery of threatened, endangered, proposed and sensitive species; 

identifying availability of public lands for commercial activities and managing commercial 

activities while protecting the integrity of other resources; managing recreation activities to meet 

public demand while protecting natural and cultural resources and providing for visitor safety; 

resolving conflicts between motorized and non-motorized uses and addressing effects to 

resources from motorized use; identifying areas requiring special management and providing 

management direction for those areas; addressing social and economic conditions; protecting the 

cultural and historic values at Pompeys Pillar National Monument; and managing the recreation 

and visitor services at Pompeys Pillar National Monument. The Alternatives present a range of 

management actions to achieve goals and desired future conditions for the Billings Field Office 

and Pompeys Pillar National Monument. 

5. Protests on the Proposed Resource Management Plan and Final Environmental Impact 

Statement must be received within 30days from publication of the Notice of Availability in the 

Federal Register by the U.S. Environmental Protection Agency. The close of the protest period 

will be announced in a news release and on the Billings and Pompeys Pillar National Monument 

RMP website at: http://on.doi.gov/1EJBdaE

6. For further information, contact: 

Billings Field Office, Bureau of Land Management 

RMP Team Lead, Carolyn Sherve-Bybee 

5001 Southgate Drive 

Billings, MT 59101 

406-896-5234 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Table of Contents – Volume 1

Acronyms ...............................................................................................................1A 

Executive Summary ...................................................................................................ES-1 

Reader’s Guide .........................................................................................................RG-1 

Chapter 1: Purpose and Need for Action

1 Purpose and Need.............................................................................................................................. 1-1 

1.1 Introduction and Background.............................................................................................. 1-1 

1.1.1 Historical Overview.............................................................................................. 1-1 

1.1.2 Land Ownership within the Billings Field Office Planning Area ......................... 1-2 

1.1.3 Description of the Billings Field Office Planning Area........................................ 1-3 

1.2 Purpose and Need for the Resource Management Plan Revision........................................1-9

1.2.1 Purpose .................................................................................................................1-9

1.2.2 Need for Revising the Existing Plan ....................................................................1-10

1.3 Planning Process ...............................................................................................................1-12

1.3.1 Nine-Step Planning Process................................................................................1-13

1.4 Decision Framework .........................................................................................................1-15

1.4.1 Planning Issues ...................................................................................................1-16

1.4.2 Planning Criteria ................................................................................................. 1-24

1.4.3 Land Use Planning Decision Levels...................................................................1-25

1.5 Consistency with Other Programs, Plans, and Policies.....................................................1-26

1.5.1 County Plans.......................................................................................................1-27

1.5.2 State Plans...........................................................................................................1-28

1.5.3 Other Federal Agency Plans ...............................................................................1-29

1.5.4 Other Related Plans ............................................................................................1-30

1.6 Consultation and Coordination.........................................................................................1-33

1.6.1 Consultation with American Indian Tribes.........................................................1-33

1.6.2 Cooperating Agencies.........................................................................................1-34

1.6.3 Consultation with USFWS..................................................................................1-35

1.7 Policy ................................................................................................................................1-36

Chapter 2: Resource Management Alternatives

2 Description of Alternatives................................................................................................................ 2-1

2.1 Introduction......................................................................................................................... 2-1

2.2 Developing the Range of Alternatives ................................................................................ 2-2

2.2.1 Alternative Formulation........................................................................................ 2-4

2.3 Key Components of the Alternatives .................................................................................. 2-5

2.3.1 Desired Outcomes (Goals and Objectives) ........................................................... 2-5

2.3.2 Allowable Uses and Management Actions........................................................... 2-5

2.3.3 Bureau of Land Management Policy and Administrative Actions........................ 2-6

2.3.4 Summary of Changes between Draft RMP/EIS and the Proposed 

RMP/Final EIS...................................................................................................... 2-7

2.3.5 Adaptive Management........................................................................................ 2-10

2.3.6 Best Management Practices................................................................................ 2-12

2.3.7 Land Health Standards........................................................................................ 2-16

2.3.8 Activity Plans...................................................................................................... 2-16

2.3.9 Monitoring .......................................................................................................... 2-17

2.3.10 Greater Sage-Grouse Habitat Management ........................................................ 2-17

2.4 Alternatives Considered But Not Analyzed in Detail ....................................................... 2-53

2.4.1 Eliminate Livestock Grazing from BLM public lands........................................ 2-54

Table of Contents i 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement

2.4.2 OHV Rock Crawl Area Proposed in Petroglyph Canyon ................................... 2-56

2.4.3 Steamboat Butte ACEC Proposal ....................................................................... 2-57

2.4.4 Sykes Ridge ACEC Proposal.............................................................................. 2-57

2.4.5 Conservation Groups Alternative ....................................................................... 2-57

2.5 Summary of Alternatives Considered in Detail ................................................................ 2-58

2.5.1 Alternative A (No Action Alternative) ............................................................... 2-68

2.5.2 Alternative B....................................................................................................... 2-70

2.5.3 Alternative C....................................................................................................... 2-72

2.5.4 Alternative D (Proposed Alternative)................................................................. 2-74

2.6 Alternatives Considered in Detail ..................................................................................... 2-77

2.6.1 Format of the Alternatives.................................................................................. 2-78

2.6.2 Energy and Minerals........................................................................................... 2-79

2.7 Summary of Environmental Consequences by Alternative..................................2-239

Chapter 3: Affected Environment

3 Affected Environment ....................................................................................................................... 3-1 

3.1 Introduction......................................................................................................................... 3-1 

3.2 Physical, Biological, and Heritage Resources..................................................................... 3-1 

3.2.1 Air ..................................................................................................................... 3-2 

3.2.1.1 Regional Winds................................................................................. 3-2 

3.2.1.2 Criteria Air Pollutants....................................................................... 3-3 

3.2.1.3 Air Quality Monitoring ..................................................................... 3-5 

3.2.1.4 Carbon Monoxide ............................................................................. 3-6 

3.2.1.5 Lead .................................................................................................. 3-8 

3.2.1.6 Nitrogen Dioxide............................................................................... 3-8 

3.2.1.7 Ozone ................................................................................................ 3-8 

3.2.1.8 Particulate Matter.............................................................................. 3-9 

3.2.1.9 Sulfur Dioxide................................................................................... 3-9 

3.2.1.10 Air Quality Index ............................................................................ 3-10

3.2.1.11 VOCs............................................................................................... 3-11

3.2.1.12 Hazardous Air Pollutants ................................................................ 3-11

3.2.1.13 Other Pollutants............................................................................... 3-11

3.2.1.14 Criteria Pollutant Emissions............................................................ 3-11

3.2.1.15 Emission Sources............................................................................ 3-12

3.2.1.16 Air Quality Related Values............................................................. 3-13

3.2.1.17 Deposition ....................................................................................... 3-14

3.2.1.18 Visibility ......................................................................................... 3-15

3.2.1.19 Smoke Management........................................................................ 3-17

3.2.2 Climate ............................................................................................................ 3-17

3.2.2.1 Temperature .................................................................................... 3-17

3.2.2.2 Precipitation .................................................................................... 3-19

3.2.2.3 Other Climatic Features .................................................................. 3-20

3.2.2.4 Climate Change............................................................................... 3-21

3.3 Geology............................................................................................................................. 3-31

3.3.1 Geologic Setting.............................................................................................. 3-31

3.4 Soil.................................................................................................................................... 3-35

3.4.1 Geomorphic Group One: Shale and Sandstone Uplands................................. 3-36

3.4.2 Geomorphic Group Two: Floodplains, Streams, Terraces, and Fans.............. 3-36

3.4.3 Geomorphic Group Three: High Terraces and Benches ................................. 3-36

3.4.4 Geomorphic Group Four: Mountains and Foothills........................................ 3-36

3.5 Water................................................................................................................................. 3-37

3.5.1 Surface Water.................................................................................................. 3-38

3.5.2 Ground Water.................................................................................................. 3-40

3.6 Vegetation......................................................................................................................... 3-40

3.6.1 Forest and Woodlands..................................................................................... 3-41

ii Table of Contents
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

3.6.2 Rangelands and Shrublands............................................................................. 3-45

3.6.3 Riparian and Wetlands .................................................................................... 3-50

3.6.4 Urban and Agricultural Lands......................................................................... 3-55

3.6.5 Invasive Species and Noxious Weeds............................................................. 3-55

3.6.6 Special Status Plants........................................................................................ 3-61

3.7 Wildlife Habitat and Special Status Species ..................................................................... 3-63

3.7.1 Wildlife Habitat Threats.................................................................................. 3-64

3.7.2 Priority Wildlife Species................................................................................. 3-64

3.7.3 Terrestrial Wildlife.......................................................................................... 3-68

3.7.3.1 Big Game ........................................................................................ 3-68

3.7.3.2 Non-Game Animals ........................................................................ 3-72

3.7.3.3 Wildlife Special Status Species....................................................... 3-74

3.7.3.4 Special Status Wildlife in Planning Area ........................................ 3-75

3.7.3.5 Mammals......................................................................................... 3-78

3.8 Fisheries Habitat and Special Status Species .................................................................. 3-103

3.8.1 Coldwater Species......................................................................................... 3-104

3.8.2 Warmwater Species....................................................................................... 3-105

3.8.3 Fisheries Management................................................................................... 3-106

3.8.4 Non-Native Invasive (Nuisance) Aquatic Species ........................................ 3-106

3.8.5 Fisheries Special Status Species.................................................................... 3-108

3.8.5.1 Northern Redbelly X Finescale Dace (BLM Sensitive) ................ 3-109

3.8.5.2 Sauger (BLM Sensitive)................................................................ 3-109

3.8.5.3 Yellowstone Cutthroat Trout (BLM Sensitive)............................. 3-109

3.9 Wild Horses and Pryor Mountain Wild Horse Range ..................................................... 3-111

3.9.1 Population and Resource Management ......................................................... 3-112

3.10 Cultural and Heritage Resources..................................................................................... 3-113

3.10.1 Cultural History Overview ............................................................................ 3-114

3.10.2 Site Types...................................................................................................... 3-117

3.10.3 Cultural Resource Existing Conditions......................................................... 3-119

3.10.4 Native American Concerns ........................................................................... 3-121

3.10.5 Ethnographic Overview................................................................................. 3-121

3.10.6 Traditional Cultural Properties...................................................................... 3-122

3.11 Paleontological Resources............................................................................................... 3-125

3.11.1 Paleontological Overview ............................................................................. 3-126

3.11.2 The Fossil Record.......................................................................................... 3-127

3.11.2.1 Vertebrate Fossils.......................................................................... 3-127

3.11.2.2 Nonvertebrate Fossils.................................................................... 3-127

3.11.2.3 Paleontological Localities............................................................. 3-127

3.11.2.4 Potential Fossil Yield Classification ............................................. 3-128

3.11.2.5 Paleontological Resource Condition and Trend ............................ 3-131

3.11.2.6 Paleontological Resource Management on Public Lands.............. 3-132

3.12 Visual Resources............................................................................................................. 3-132

3.12.1 Visual Resources Management ..................................................................... 3-133

3.12.2 Visual Resource Management Analysis Process........................................... 3-135

3.13 Fire Ecology and Management ....................................................................................... 3-137

3.13.1 Wildfire Occurrence ...................................................................................... 3-137

3.13.2 Fuels Treatments........................................................................................... 3-139

3.13.3 Fire Regimes and Condition Causes.............................................................. 3-139

3.13.4 Frequency Fire Intensity Estimated............................................................... 3-140

3.13.5 Condition....................................................................................................... 3-140

3.14 Wilderness Characteristics.............................................................................................. 3-140

3.14.1 Pryor Mountain Unit ..................................................................................... 3-142

3.14.2 Burnt Timber Canyon Unit............................................................................ 3-144

3.14.3 Meeteetse Unit............................................................................................... 3-145

3.14.4 Bad Canyon Unit........................................................................................... 3-146

3.14.5 Weatherman Draw Unit................................................................................. 3-147

Table of Contents iii
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement

3.14.6 Yellowstone River Islands Unit .................................................................... 3-148

3.14.7 Clark’s Fork of the Yellowstone River Islands Unit ..................................... 3-151

3.14.8 Bear Creek Unit............................................................................................. 3-153

3.15 Cave and Karsts Resources............................................................................................. 3-154

3.16 Resource Uses................................................................................................................. 3-156

3.17 Energy and Mineral Resources ....................................................................................... 3-157

3.17.1 Solid Leasable Minerals................................................................................ 3-157

3.17.1.1 Coal............................................................................................... 3-157

3.17.2 Fluid Minerals............................................................................................... 3-177

3.17.2.1 Geothermal Energy ....................................................................... 3-177

3.17.2.2 Oil and Gas ................................................................................... 3-178

3.17.3 United States Geological Survey Oil and Gas Assessments ......................... 3-183

3.17.3.1 1995 USGS Assessment................................................................ 3-183

3.17.3.2 Subsequent USGS Assessments.................................................... 3-184

3.17.4 Federal Drilling Activity ............................................................................... 3-185

3.17.4.1 Existing Federal Leases................................................................. 3-186

3.17.4.2 Well Spacing................................................................................. 3-186

3.17.4.3 Unitization and Communitization ................................................. 3-186

3.17.4.4 Projected Reasonably Foreseeable Development for Oil 

and Gas.......................................................................................... 3-187

3.17.4.5 Well Completion and Stimulation................................................. 3-188

3.17.4.6 Hydraulic Fracturing ..................................................................... 3-189

3.17.4.7 Locatable Minerals........................................................................ 3-190

3.17.4.8 Mineral Materials.......................................................................... 3-191

3.18 Forestry and Woodland Products.................................................................................... 3-192

3.18.1 Forest and Woodland Communities.............................................................. 3-192

3.18.2 Wood Products.............................................................................................. 3-193

3.19 Realty, Cadastral Survey, and Lands .............................................................................. 3-194

3.19.1 Land Tenure Adjustments and Access.......................................................... 3-194

3.19.2 Disposals....................................................................................................... 3-196

3.19.3 Exchanges ..................................................................................................... 3-196

3.19.4 Acquisitions .................................................................................................. 3-196

3.19.5 Rights-of-Way, Leases, and Permits............................................................. 3-197

3.19.6 Utility Corridors............................................................................................ 3-198

3.19.7 Leases, Permits, and Easements.................................................................... 3-199

3.19.8 Communication Sites.................................................................................... 3-199

3.19.9 Airport Grants and Leases............................................................................. 3-200

3.19.10 Recreation and Public Purpose Leases and Conveyances............................. 3-200

3.19.11 Withdrawals.................................................................................................. 3-201

3.19.12 Land Classifications...................................................................................... 3-202

3.19.13 Trespass......................................................................................................... 3-203

3.20 Livestock Grazing........................................................................................................... 3-204

3.20.1 Bureau of Land Management Grazing History ............................................. 3-204

3.20.2 Grazing Permits and Leases.......................................................................... 3-209

3.20.3 Range Health Standard Assessments ............................................................ 3-210

3.20.4 Guidelines for Grazing Management ............................................................ 3-211

3.20.5 Range Improvement Projects........................................................................ 3-212

3.20.6 Prohibited Acts.............................................................................................. 3-212

3.20.7 Factors Influencing Grazing.......................................................................... 3-212

3.21 Recreation and Visitor Services...................................................................................... 3-212

3.21.1 Four Dances Natural Area ACEC and SRMA .............................................. 3-214

3.21.2 Sundance Lodge Recreation Area SRMA..................................................... 3-214

3.21.3 Other Recreation Management Areas ........................................................... 3-215

3.21.3.1 Acton Recreation Area.................................................................. 3-215

3.21.3.2 Asparagus Point Area.................................................................... 3-215

3.21.3.3 Pryor Mountains Area................................................................... 3-215

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Proposed Resource Management Plan and Final Environmental Impact Statement

3.21.3.4 Shepherd Ah-Nei Recreation Area................................................ 3-216

3.21.3.5 South Hills Area............................................................................ 3-217

3.21.3.6 17 Mile Area ................................................................................. 3-217

3.21.3.7 Horsethief Recreation Area........................................................... 3-218

3.21.3.8 Yellowstone River Corridor.......................................................... 3-218

3.21.3.9 Bundy Island ................................................................................. 3-218

3.21.3.10 Bundy Island/Mill Creek............................................................... 3-219

3.21.3.11 Elk Basin ....................................................................................... 3-219

3.21.4 Special Recreation Permits............................................................................ 3-219

3.22 Trails and Travel Management ....................................................................................... 3-220

3.23 Renewable Energy .......................................................................................................... 3-224

3.23.1 Wind.............................................................................................................. 3-225

3.23.2 Solar Resources............................................................................................. 3-227

3.23.3 Biomass Energy and Resources..................................................................... 3-227

3.23.4 Geothermal.................................................................................................... 3-228

3.23.5 Hydroelectric................................................................................................. 3-228

3.24 Transportation and Facilities........................................................................................... 3-229

3.24.1 Federal Roads, Airports, and Railways......................................................... 3-229

3.24.2 State and County Roads ................................................................................ 3-230

3.24.3 BLM Roads................................................................................................... 3-230

3.24.4 Road System Maintenance ............................................................................ 3-232

3.24.5 Facilities........................................................................................................ 3-233

3.25 Special Designations....................................................................................................... 3-234

3.26 Pompeys Pillar ................................................................................................................ 3-234

3.26.1 General Overview ......................................................................................... 3-235

3.26.2 National Monument....................................................................................... 3-235

3.26.3 National Historic Landmark.......................................................................... 3-236

3.26.4 Area of Critical Environmental Concern....................................................... 3-236

3.26.4.1 Historic Zone................................................................................. 3-237

3.26.4.2 Historic Zone - Developed ............................................................ 3-237

3.26.4.3 General Management Zone ........................................................... 3-237

3.26.5 Current Land Usage at Pompeys Pillar National Historic Landmark 

and National Monument................................................................................ 3-238

3.27 Areas of Critical Environmental Concern ....................................................................... 3-238

3.27.1 National Natural Landmark........................................................................... 3-238

3.27.2 Laws, Regulations and Policies..................................................................... 3-239

3.27.3 Existing ACECs ............................................................................................ 3-239

3.27.3.1 Bridger Fossil Area ACEC............................................................ 3-240

3.27.3.2 Castle Butte ACEC ....................................................................... 3-240

3.27.3.3 East Pryor Mountain ACEC.......................................................... 3-241

3.27.3.4 Four Dances Natural Area ACEC ................................................. 3-243

3.27.3.5 Meeteetse Spires ACEC................................................................ 3-244

3.27.3.6 Petroglyph Canyon ACEC ............................................................ 3-245

3.27.3.7 Pompeys Pillar ACEC................................................................... 3-246

3.27.3.8 Stark Site ACEC ........................................................................... 3-246

3.27.3.9 Weatherman Draw ACEC............................................................. 3-247

3.28 Wilderness Study Areas.................................................................................................. 3-250

3.28.1 WSAs in the Planning Area........................................................................... 3-251

3.28.1.1 Big Horn Tack-On WSA............................................................... 3-251

3.28.1.2 Burnt Timber Canyon WSA.......................................................... 3-252

3.28.1.3 Pryor Mountain WSA.................................................................... 3-252

3.28.1.4 Twin Coulee WSA ........................................................................ 3-252

3.29 Wild and Scenic Rivers................................................................................................... 3-252

3.29.1 Eligibility Phase ............................................................................................ 3-253

3.29.2 Suitability Phase............................................................................................ 3-254

3.30 Pryor Mountain Wild Horse Range (PMWHR).............................................................. 3-254

Table of Contents v 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement

3.31 National Historic Trails................................................................................................... 3-254

3.32 Social and Economic Conditions.................................................................................... 3-257

3.32.1 Social Conditions.......................................................................................... 3-257

3.32.1.1 Attitudes and Social Trends.......................................................... 3-257

3.32.2 Economic Conditions.................................................................................... 3-273

3.32.2.1 Demographic and Economic Characteristics and Trends.............. 3-274

3.32.2.2 BLM Land and Mineral Uses that Affect the Local 

Economy ....................................................................................... 3-277

3.32.2.3 Economic Contributions................................................................ 3-280

3.32.2.4 Recreation Use .............................................................................. 3-281

3.32.2.5 Timber Harvest ............................................................................. 3-282

3.32.2.6 Realty, Cadastral Survey, and Lands Actions............................... 3-282

3.32.2.7 Direct BLM Contributions to Area Economic Activity ................ 3-283

3.32.2.8 Ecosystem Restoration.................................................................. 3-283

3.32.2.9 Payments to Counties.................................................................... 3-284

3.32.2.10 Employment and Income .............................................................. 3-285

Appendices A-B are located in Volume 3 

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

vi Table of Contents
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

List of Tables – Volume 1

Table 1-1 Land Ownership – Billings Planning Area..................................................................................1-3 

Table 2.1 Identified Threats to Greater Sage-Grouse and Their Habitat and Applicable BLM 

Proposed Plan Resource Program Areas Addressing These Threats.........................................2-19

Table 2.2 Comparative Summary of Allocation Decisions of the Draft Alternatives and 

Proposed Plan (Proposed Alternative) for Greater Sage-Grouse Management 

(Acres).......................................................................................................................................2-22

Table 2.3 Billings Field Office Greater Sage-Grouse Habitat Objectives................................................2-28

Table 2.4 Specific Management Responses..............................................................................................2-49

Table 2.5 Comparative Summary of Proposed Land Use Decisions for Physical, Biological, 

and Cultural/Heritage Resources and Resource Uses by Alternative........................................2-59

Table 2.6 Comparative Summary of Proposed Special Designations by Alternative ...............................2-66

Table 2.7 Organization of Comprehensive Alternatives Table .................................................................2-78 

Table 2.8 Acres of Federal Mineral Estate Available or Not for Oil and Gas Leasing .............................2-81

Table 2.9 Lease Terms and Stipulations by Alternative............................................................................2-84

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage 

Resources..................................................................................................................................2-99

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support.................................................. 2-154

Table 2.12 Detailed Table of Alternatives: Special Designations............................................................. 2-200

Table 2.13 Detailed Table of Alternatives: Social and Economic Conditions......................................... 2-238

Table 2.14 Summary of Environmental Consequences by Alternative..................................................... 2-240

Table 2.15 Summary Comparison of Impacts........................................................................................... 2-258

Table 3-1 Prevailing Wind Directions and Average Speeds (mph) for Billings.................................. 3-2 

Table 3-2 Federal and State Ambient Air Quality Standards.............................................................. 3-4 

Table 3-3 Air Quality Monitoring Stations in the BiFO or Vicinity ................................................... 3-5 

Table 3-4 Air Quality Index Report................................................................................................... 3-10

Table 3-5 BiFO Criteria Pollutant Emissions by County .................................................................. 3-11

Table 3-6 Largest 2008 Emission Sources by Pollutant .................................................................... 3-12

Table 3-7 Class I and Sensitive Class II Areas in or near the BiFO .................................................. 3-14

Table 3-8 Monthly Climate Summary for Billings, Montana............................................................ 3-17

Table 3-9 Estimated Annual GHG Emissions................................................................................... 3-22

Table 3-10 Oil and Gas Greenhouse Gas Emission Sources Within the Big Horn Basin ................... 3-29

Table 3-11 Annual Stream Flow Data ................................................................................................. 3-38

Table 3-12 Impaired Water Bodies ..................................................................................................... 3-39

Table 3-13 Percent of Vegetation Cover Types in the Decision Area................................................. 3-41

Table 3-14 Forest/Woodland Vegetation Cover Types....................................................................... 3-42

Table 3-15 Rangeland Cover Types.................................................................................................... 3-45

Table 3-16 Shrubland Cover Types..................................................................................................... 3-47

Table 3-17 Rangeland Conditions....................................................................................................... 3-50

Table 3-18 2010 Functional Condition of Lotic Systems by County (miles)...................................... 3-53

Table 3-19 Functional Condition of Lentic Systems by County............................................................... 3-53

Table 3-20 DEQ Impaired Waters List in the Planning Area ................................................................... 3-54

Table 3-21 Noxious and Invasive Weed Species by County .................................................................... 3-59

Table 3-22 Special Status Plant Species................................................................................................... 3-61

Table 3-23 Habitat for Priority Wildlife Species in the Planning Area .................................................... 3-66

Table 3-24 Big Game Habitat and Distribution by Land Ownership in the Planning Area...................... 3-68

Table 3-25 Upland Game Bird Habitat and Distribution by Ownership in the Planning Area ................. 3-71

Table 3-26 Waterfowl Species Known to Occur in the Planning Area..................................................... 3-72

Table 3-27 Special Status Wildlife Species in the Planning Area ............................................................ 3-75

Table 3-28 Black-tailed Prairie Dog Acreage in the Planning Area ......................................................... 3-79

Table 3-29 White-tailed Prairie Dog Acreage in the Planning Area......................................................... 3-79

Table of Contents vii
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement

Table 3-30 Greater Sage Grouse Habitat and Lek Sites in the Planning Area.......................................... 3-84

Table 3-31 Sage-Grouse Vital Rates in Montana ..................................................................................... 3-98

Table 3-32 Native and Non-Native Fish Species Occurring in the Planning Area ................................. 3-104

Table 3-33 Fish Bearing Streams in the Decision area........................................................................... 3-105

Table 3-34 Aquatic Nuisance Species in the Planning Area................................................................... 3-107

Table 3-35 Prehistoric Site Types........................................................................................................... 3-117

Table 3-36 Historic Site Types............................................................................................................... 3-119

Table 3-37 Potential Fossil Yield Classification .................................................................................... 3-129

Table 3-38 Potential Fossil Yield Classification Acres.......................................................................... 3-129

Table 3-39 Geologic Formations Present in the Planning Area.............................................................. 3-130

Table 3-40 VRM Classes and Acreage................................................................................................... 3-134 

Table 3-41 Fires by Class Size ............................................................................................................... 3-138

Table 3-42 Fires by Cause ...................................................................................................................... 3-138

Table 3-43 Fire Activity in the Planning Area Since 2000..................................................................... 3-138

Table 3-44 Fuels Treatments from 2003-2010 ....................................................................................... 3-139

Table 3-45 Fire Regime Classifications and BiFO Estimated Acreage .................................................. 3-140

Table 3-46 Fire Regime Condition Class Description and BiFO Estimated Acreage ............................ 3-140

Table 3-47 Surface Minable Mammoth Coal Resource Estimate........................................................... 3-168

Table 3-48 Underground Minable Mammoth Coal Resource Estimate.................................................. 3-171

Table 3-49 Mammoth Coal Resource Estimate ...................................................................................... 3-171

Table 3-50 Active Oil and Gas Fields in the Planning Area................................................................... 3-180

Table 3-51 Federal Wells in the BiFO Planning Area ............................................................................ 3-181

Table 3-52 Federal Oil and Gas Production in the BiFO Planning Area................................................ 3-182

Table 3-53 Summary of Federal Wells Drilled in the Last 18 Years...................................................... 3-185

Table 3-54 All Well Types, All Ownerships in the Planning Area......................................................... 3-186

Table 3-55 Claims and Saleable Mineral Permits in the Planning Area................................................. 3-192

Table 3-56 Wood Products Harvested and Sold in the Planning Area (1994-2008) .............................. 3-193

Table 3-57 Land Status by County ......................................................................................................... 3-194

Table 3-58 Land Tenure Category Acreage............................................................................................ 3-195

Table 3-59 Land Exchanges, Acres Disposed/Acquired......................................................................... 3-195

Table 3-60 Land Acquisitions/Donations............................................................................................... 3-197

Table 3-61 Existing ROWs in the Decision Area ................................................................................... 3-197

Table 3-62 Recreation and Public Purpose Leases in the Planning Area ............................................... 3-201

Table 3-63 Areas Currently Withdrawn from Mineral Entry ................................................................. 3-202

Table 3-64 Summary AUMs by County and Preference Code in the Planning Area (Calendar Year 

2008) .................................................................................................................................... 3-209

Table 3-65 Planning Area Visits and Visitor Use Days by Primary Recreation Activities.................... 3-213

Table 3-66 Estimated Number of Vehicles Used Off-Highway in Montana (1990-1998)..................... 3-221

Table 3-67 Wind Potential in the Billings Field Office in Comparison to All Ownership ..................... 3-226

Table 3-68 State Highway Conditions in the Planning Area .................................................................. 3-230

Table 3-69 Roads in the Decision Area .................................................................................................. 3-231

Table 3-70 Pompeys Pillar Designations and Rationales ....................................................................... 3-237

Table 3-71 ACECs in the Planning Area................................................................................................ 3-239

Table 3-72 WSAs in the Planning Area.................................................................................................. 3-250

Table 3-73 Wild and Scenic Rivers and River Segments Eligibility ...................................................... 3-254

Table 3-74 Demographic and Social Information for the Montana and Wyoming Planning Area 

Counties................................................................................................................................ 3-261

Table 3-75 Environmental Justice Information for the Planning Area by County, 2013........................ 3-272

Table 3-76 BLM Surface and Mineral Estate and Major BLM Land/Mineral Uses within the 

Billings RMP Planning Area (in acres)................................................................................ 3-275

Table 3-77 Selected Economic Statistics, 2012...................................................................................... 3-276

Table 3-78 Average Annual Authorized Livestock Grazing Use (AUMs), Billing Years 1999-2009 ... 3-277

Table 3-79 Forest Products Harvested and Sold in the Billings Field Office (1994-2008) .................... 3-282

Table 3-80 Federal Rights-of-Way Revenues by Type........................................................................... 3-283

Table 3-81 Fuels Treatments (2003-2008) ............................................................................................. 3-284

Table 3-82 Annual Payments to Counties from BLM-Related Land/Mineral Uses............................... 3-285

viii Table of Contents
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Table 3-83 Billings BLM Related Employment, and Income by Major BLM Program Area................ 3-285

Table 3-84 Current Role of BLM-Related Contributions to the Area Economy ...........................3-285

Table of Contents ix
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement

List of Figures – Volume 1

Figure 1-1: Billings Field Office Planning Area Map ....................................................................................1-4

Figure 1-2: Public Lands within the Billings Field Office Planning Area......................................................1-6

Figure 1-3: BLM Federal Minerals within the Billings Field Office Planning Area ......................................1-7

Figure 1-4: BLM Surface, BLM Federal Minerals and GRSG Priority and General Habitat within the Billings 

Field Office Planning Area ........................................................................................................1-8

Figure 1-5 Nine Step Planning Process...............................................................................1-15

Figure 2-1 Reasonable Range of Alternatives for the Billings and Pompeys Pillar National 

Monument RMP/EIS................................................................................................................ 2-4 

Figure 2-2 Adaptive Management Strategy Phases ..............................................................2-11

Figure 3-1 Wind Rose for Pryor Mountain, Montana (data from 2006-2010)........................................... 3-3

Figure 3-2: Ambient Air Quality Concentrations in the BiFO Planning Area (2010-2012) ....................... 3-7

Figure 3-3 Visibility Trends on the Best and Worst Visibility Days (2005-2009) .................................. 3-16

Figure 3-4 Visibility Trends on the Best and Worst Visibility Days (2005-2009) .................................. 3-16

Figure-3-5 Montana Average Daily Maximum Temperature................................................................... 3-19

Figure 3-6 Montana Average Annual Precipitation ................................................................................. 3-20

Figure 3-7 Long-Term Historical Temperature and Precipitation Trends ............................................... 3-24

Figure 3-8 Near-Term Predicted Temperature Increases......................................................................... 3-25

Figure 3-9 Examples of Resource Impacts Due to Climate Change ........................................................ 3-26

Figure 3-10 Stratigraphic Column ............................................................................................................. 3-33

Figure 3-11 Sage-Grouse Management Zones in the Western U.S. and Canada ....................................... 3-89

Figure 3-12 Agricultural Lands within the Sage-Grouse Conservation Area ............................................ 3-90

Figure 3-13 Linear Density of Fences on Public Lands in the Sage-Grouse Conservation Area............. 3-91

Figure 3-14 Water Developments on Lands Managed by the US Bureau of Land Management .............. 3-92

Figure 3-15 Locations of Producing Oil and Gas Wells within Sage-Grouse Management Zones I 

and II................................................................................................................................. 3-93

Figure 3-16 Contoured Secondary Roads in the Sage-Grouse Conservation Area..................................... 3-94

Figure 3-17 Spatial extent of Three Human-footprint-intensity Classes for the Conterminous US 

within the Current Range of Sage-Grouse and Sage-Grouse Management Zones............ 3-95

Figure 3-18 Location of the Bridger and Joliet-Fromberg Coal Fields................................................... 3-159

Figure 3-19 Location of the Stillwater and Silvertip Coal Fields ............................................................ 3-161

Figure 3-20 Generalized stratigraphic column showing Fort Union Formation coal beds in the Red 

Lodge-Bearcreek coalfield. Stratigraphy adapted from Woodruff 1909, Rawlins 

1986, and Roberts and Rossi 1999.................................................................................. 3-163

Figure 3-21 Location of the Red Lodge-Bearcreek Coal Field................................................................. 3-164

Figure 3-22 Location of the Bull Mountain Basin, south-central Montana. Basin extent is drawn at 

the Lance-Fort Union Formation boundary. “K” denotes Cretaceous rocks and “T” 

denotes Tertiary rocks (from Stricker, 1999).................................................................. 3-166

Figure 3-23 Generalized coal stratigraphy showing the principal coal beds in the Bull Mountain 

Basin. Stratigraphy modified from Woolsey and others 1917, Connor 1989; and 

Stricker 1999................................................................................................................... 3-167

Figure 3-24 Outcrop of the Mammoth coal bed in the Bull Mountain Coal Field..................................... 3-169

Figure 3-25 Mammoth coal bed – Approximate surface mining area ˂ 10:1 strip ratio............................ 3-170

Figure 3-26 Location of Federal Coal Tracts Conveyed to Great Northern Properties Limited................ 3-174

Figure 3-27 McCleary Coal Bed Outcrop in the South Divide Resource Area, Bull Mountain Coal 

Field ................................................................................................................................ 3-175

Figure 3-28 Grazing Land Classification.................................................................................................. 3-208

x Table of Contents
ERRATA SHEET

Corrections to the Billings and Pompeys Pillar National Monument Draft Resource 

Management Plan and Environmental Impact Statement

After printing of the Billings and Pompeys Pillar National Monument Draft Resource 

Management Plan and Environmental Impact Statement, but prior to public release, the BLM 

identified the following corrections to the Draft. These corrections have not been made to the 

electronic PDF files on the website or the print version of the document:

 Figure 2-3: BLM Managed Surface, Federal Mineral Estate, and Sage-Grouse Habitat 

Management Areas within the Billings Field Office Planning Area is included in the 

document, but not listed in the List of Figures. It should have been included to the List of 

Figures, Volume I, page x.

 The map reference numbers located in the bottom right of Figures 1-1: Billings Field 

Office Planning Area Map, 1-2: Public Lands within the Billings Field Office Planning 

Area, and 1-3: BLM Federal Minerals within the Billings Field Office Planning Area are 

referencing the same maps located in the Maps Section of Volume 5 of the RMP/EIS.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

List of Acronyms 1A 

List of Acronyms

Acronym or 

Abbreviation Full Phrase

ACEC area of critical environmental 

concern

ACHP Advisory Council on Historic 

Preservation

ADA American with Disabilities Act 

AFMSS Automated Fluid Mineral 

Support System

AFY acre – feet per year

AML1 appropriate management level

AML2 abandoned mine lands

AMP allotment management plan

AMR appropriate management 

response

AMS analysis of the management 

situation

amsl above mean sea level

ANS aquatic nuisance species

AO authorized officer

APLIC Avian Protection Plan 

guidelines

APD application for permit to drill

APE area of potential effect

APHIS Animal and Plant Health 

Inspection Service

APHIS-WS Animal and Plant Health 

Inspection Service – Wildlife 

Services

AQ air quality

AQI air quality index

AQRV air quality related values

AQTW Air Quality Technical 

Workgroup

ARMP Air Resource Management 

Plan

ARTSD Air Resource Technical 

Support Document

ATV all-terrain vehicle

AU assessment units

Acronym or 

Abbreviation Full Phrase

AUM animal unit month

BA biological assessment

BACT Best Available Control 

Technology

BBM benefits based management

BCNRA Bighorn Canyon National 

Recreation Area

BEA Bureau of Economic Analysis

BIA US Dept of the Interior –

Bureau of Indian Affairs

BiFO Billings Field Office

BLM US Dept of the Interior –

Bureau of Land Management

BMPs best management practices

BO biological opinion

BOR US Dept of the Interior –

Bureau of Reclamation 

BPS budget planning system

C & MU Classification and Multiple 

Use Act

CAA Clean Air Act 

CAPS crucial area planning system 

used by MT FWP

CBNG coalbed natural gas

CEQ Council on Environmental 

Quality

CFR Code of Federal Regulations

CO carbon monoxide

CO2 carbon dioxide

COA conditions of approval

COT Conservation Objectives Team 

(GRSG)

CSP Concentrating Solar Power

CSU controlled surface use

CWA Clean Water Act

CWPP Community Wildfire 

Protection Plan
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2A List of Acronyms

Acronym or 

Abbreviation Full Phrase

CWMA Cooperative Weed 

Management Area

DEQ Department of Environmental 

Quality (Montana)

DFC Desired Future Condition

DNA Documentation of Land Use 

Plan Conformance and 

National NEPA Adequacy

DNRC Department of Natural 

Resources and Conservation

DOI Department of the Interior

DR decision record

EA environmental assessment

EIS environmental impact 

statement

EO Executive Order

EPA US Environmental Protection 

Agency

EPCA Energy Policy and 

Conservation Act Amendments 

of 2000

ERMA extensive recreation 

management area

ES executive summary

ESA Endangered Species Act of 

1973

ESR emergency stabilization and 

rehabilitation

EVT existing vegetation type

° F degrees Fahrenheit

FAR functioning at risk

FAR-D functioning at risk downward 

trend

FAR-NA functioning at risk not apparent 

trend

FAR-NF functioning at risk not 

functioning

FAR-U functioning at risk upward 

trend

FERC Federal Energy Regulatory 

Commission

Acronym or 

Abbreviation Full Phrase

FEIS Final Environmental Impact 

Statement

FLPMA Federal Land Policy and 

Management Act

FLTFA Federal Land Transaction 

Facilitation Act

FMP fire management plan

FMU fire management unit

FMUD final multiple use decision

FO field office

FOFEM first order fire effects model

FOIA Freedom of Information Act

FPA Federal Power Act

FPA fire program analysis

FPPA Farmland Policy Protection 

Act

FR Federal Register

FRCC fire regime condition class

FWFMP Federal Wildland Fire 

Management Policy

FWP Montana Fish, Wildlife, and 

Parks

FY fiscal year

GAO Government Accountability 

Office

GAWS general aquatic wildlife survey

GHMA general habitat management 

area (GRSG)

GHG greenhouse gas

GIS geographical information 

system

GPS

GRSG

global positioning system

Greater Sage-Grouse

HA herd area

HAP hazardous air pollution

HCP habitat conservation plan

HFA Healthy Forest Initiative

HFRA Healthy Forest Restoration Act

HMA herd management area

HMAP herd management area plan
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

List of Acronyms 3A 

Acronym or 

Abbreviation Full Phrase

HMP habitat management plan

HUA herd use area

HVH high value habitat

I - Interstate

IB information bulletin

IBA important bird area

IBLA Interior Board of Land Appeals

IDT interdisciplinary team

IM instruction memorandum

IMP interim management policy

IPCC Intergovernmental Panel on 

Climate Change

IPM Integrated Pest Management

IR Indian Reservation

ISA instant study area

ITA Indian Trust Assets

ITRR Institute for Tourism and 

Recreation Research, 

University of Montana

IWM integrated weed management

LAC limits of acceptable change

LANDFIRE Landscape Fire and Resource 

Management Planning Tools

Project

LBA lease by application

LCNHT / 

L&CNHT

Lewis and Clark National 

Historic Trail

LHA land health assessment

LN lease notice

LS lease stipulation

LTA land tenure adjustment

LUP land use plan

LWC Lands with Wilderness 

Characteristics

MAAQS Montana Ambient Air Quality 

Standards

MACT maximum available control 

technology

Acronym or 

Abbreviation Full Phrase

mbf thousand board feet

mcf thousand cubic feet

MBTA Migratory Bird Treaty Act

MDEQ Montana Department of

Environmental Quality

MEI maximally exposed individual

MFISH Montana Fish Information 

System

MIST minimum impact suppression 

tactics

MLE most likely exposure

MLP Master Leasing Plan

MLRA Major Land Resource Area 

mmbf million board feet

mmcf million cubic feet

MOA memorandum of agreement

MOU memorandum of understanding

MNHP Montana Natural Heritage 

Program

MSIP Montana State Implementation 

Plan

MT Montana

MTFWP Montana Fish, Wildlife, and 

Parks

mtpy metric tons per year

NAAQS National Ambient Air Quality 

Standards

NAICS North American Industry 

Classification System

NCDC National Climatic Data Center

NDVI Normalized Difference 

Vegetation Index

NEI National Emission Inventory

NEPA National Environmental Policy 

Act of 1969

NESHAPS National Emission Standards 

for Hazardous Air Pollutants

NF non functional

NFP National Fire Plan of 2000
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

4A List of Acronyms

Acronym or 

Abbreviation Full Phrase

NGO non-government organization

NHL National Historic Landmark

NHPA National Historic Preservation 

Act

NHT National Historic Trail

NISMS National Invasive Species 

Information Management 

System

NLCS National Landscape 

Conservation System

NM National Monument

NMFS National Marine Fisheries 

Service

NNL National Natural Landmark

NOA Notice of Availability

NO2 nitrogen dioxide

NOAA National Oceanic and 

Atmospheric Administration

NOI Notice of Intent

NOx mono-nitrogen oxides NO and 

NO2

NPNHT Nez Perce National Historic 

Trail

NPS National Park Service

nps nonpoint source

NRCS U.S. Dept. of Agriculture, 

Natural Resources 

Conservation Service

NREL U.S. DOE National Renewable 

Energy Laboratory

NRHP National Register of Historic 

Places

NRS natural resource specialist

NSR new source review

NSPS new source performance 

standards

NSO no surface occupancy

NWR National Wildlife Refuge

NWReGAP Northwest Regional Gap 

Analysis Project

NWSRS National Wild and Scenic 

River System

Acronym or 

Abbreviation Full Phrase

O3 ozone

O&G oil and gas

OHV off-highway vehicle

OHV EIS Off-Highway Vehicle 

Environmental Impact 

Statement

ORP Outdoor Recreation Planner

ORV outstanding remarkable value

OSV over snow vehicle

PAC priority areas for conservation

Pb lead

PDM Pre-Disaster Mitigation Plan

PE chemical and biological control

PEIS preliminary environmental 

impact statement

PFC proper functioning condition

PFYC potential fossil yield 

classification

PHMA Priority habitat management 

area (GRSG)

PGM photochemical grid modeling

PILT payment in lieu of taxes

PL public law

PLO public land office

PM particulate matter

PM2.5 particulate matter smaller than 

2.5 microns in diameter

PM10 particulate matter smaller than 

10 microns in diameter

PMU population management unit

PMWHR Pryor Mountain Wild Horse 

Range

ppm part per million

PPMN Pompeys Pillar National 

Monument

PRPA Paleontological Resources 

Protection Act

PS public health and safety
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

List of Acronyms 5A 

Acronym or 

Abbreviation Full Phrase

PSD prevention of significant 

deterioration

PSQ probable sale quantity

PV photovoltaics

R & PP Recreation and Public 

Purposes Act

R & VS Recreation and Visitor 

Services

RAC Resource Advisory Council

RAMS risk assessment and mitigation 

strategy

REIS Regional Economic 

Information System

RELs Reference Exposure Levels

RfCs Reference Concentrations

RFD reasonably foreseeable 

development

RFDS reasonably foreseeable 

development scenario

RIP range improvement project

RMIS recreation management 

information system

RMP Resource Management Plan

RMS rangeland management 

specialist

RMZ recreation management zone

RNA research natural area

ROD record of decision

ROI region of influence

ROS recreation opportunity 

spectrum

ROW right-of-way

RA restoration area (GRSG)

RPS Rangeland Program Summary 

Record of Decision (ROD)

SASEM Simple Approach Smoke 

Estimation Model

SHPO State Historic Preservation 

Office

S & G Standards and Guides

SIP State Implementation Plan

Acronym or 

Abbreviation Full Phrase

SLT standard lease term

SO2 sulphur dioxide

SOC species of concern

SOP standard operating procedure

SMZ stream management zone

SPE Signal Peak Energy

SRMA Special recreation management 

area

SRP special recreation permit

SSP special status plants

SSS special status species

T & E threatened and endangered

TC tribal consultation

TCP traditional cultural property

TDS total dissolved solids

TL timing limitation

TM transportation and travel 

management

TMA travel management area

TMDL total maximum daily load

TNEB thriving natural ecological 

balance

TNR temporary nonrenewable

TPS Total Petroleum Systems

tpy short tons per year

TSP total suspended particles

TSS total suspended solids

UFAS Uniform Federal Accessibility 

Standards

URF Unit Risk Factors

US United States

USACE United States Army Corps of 

Engineers

USC United States Code

USDI United States Department of 

the Interior
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

6A List of Acronyms

Acronym or 

Abbreviation Full Phrase

USEPA United States Environmental 

Protection Agency

USFS US Dept of Agriculture, Forest 

Service

USFWS US Dept of the Interior, Fish 

and Wildlife Service

USGS US Dept of the Interior, 

Geological Service

VF vegetation forest and woodland 

products

VOCs volatile organic compounds

VRI visual resource inventory

VRM visual resource management

WA wilderness area

WAAQS Wyoming Ambient Air Quality 

Standards

WAFWA Western Association of Fish 

and Wildlife Agencies

WDEQ Wyoming Department of 

Environmental Quality

WDM wildlife damage assessment

WEG Wind Erodibility Group

WFDSS Wildland Fire Decision 

Support System

WFIP wildland fire implementation 

plan

WFM wildland fire ecology 

management

Acronym or 

Abbreviation Full Phrase

WFSA wildland fire situation analysis

WHB wild horses and burros

WMA wildlife management area

WMPP Wildlife Monitoring and 

Protection Plan

WSA wilderness study area

WSR wild and scenic river

WUI wildland urban interface

WWCC Western Wyoming Community 

College

YCT Yellowstone cutthroat trout
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Executive Summary ES-1 

EXECUTIVE SUMMARY

ES.1 INTRODUCTION 

The Federal Land Policy and Management Act of 1976 (FLPMA) directs the United States 

(US) Department of the Interior (DOI), Bureau of Land Management (BLM) to develop and

periodically revise or amend its resource management plans (RMP), which guide management 

of BLM-administered lands. This RMP and Environmental Impact Statement (EIS) describes 

and analyzes alternatives for the future management of public lands and resources the BLM

administers in the Billings Field Office (BiFO) in south-central Montana. 

The BLM Billings and Pompeys Pillar National Monument Proposed Plan provides a layered 

management approach that offers the highest level of protection for Greater Sage-Grouse 

(GRSG) in the most valuable habitat. Land use allocations in the Proposed Plan would limit

or eliminate new surface disturbance in Priority Habitat Management Areas (PHMA), while 

minimizing disturbance in General Habitat Management Areas (GHMA). In addition to

establishing protective land use allocations, the Proposed Plan would implement a suite of 

management tools, such as disturbance limits, GRSG habitat objectives and monitoring, 

mitigation approaches, adaptive management triggers and responses, and other protective 

measures throughout the range. These overlapping and reinforcing conservation measures 

will work in concert to improve and restore GRSG habitat condition and provide consistency 

in how the BLM will manage activities in GRSG habitat in the planning area. 

ES.1.1 Rationale and Relationship to the Greater Sage-Grouse Planning Strategy 

The Billings and Pompeys Pillar National Monument RMP addresses the March 2010 US Fish 

and Wildlife Service (USFWS) 12-Month Finding for Petitions to List the Greater SageGrouse (Centrocercus urophasianus) as Threatened or Endangered (75 Federal Register

13910, March 23, 2010). In that finding, the USFWS concluded that GRSG was “warranted,

but precluded” for listing as a threatened or endangered species. A “warranted, but precluded”

determination is one of three results that may occur after a petition is filed by the public to list a 

species under the Endangered Species Act (ESA). This finding indicates that immediate 

publication of a proposed rule to list the species is precluded by higher-priority listing 

proposals; that is, a species should be listed based on the available science, but listing other 

species takes priority because they are more in need of protection. 

The USFWS reviewed the status of and threats to the GRSG in relation to the five listing 

factors provided in Section 4(a)(1) of the ESA. Of the five listing factors reviewed, the 

USFWS determined that Factor A, “the present or threatened destruction, modification, or 

curtailment of the habitat or range of the GRSG,” and Factor D, “the inadequacy of existing 

regulatory mechanisms,” posed “a significant threat to the GRSG now and in the foreseeable 

future” (75 Federal Register 13910, March 23, 2010). The USFWS identified the principal

regulatory mechanisms for the BLM as conservation measures in Land Use Plans (LUPs).
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

ES- 2 Executive Summary

The Billings and Pompeys Pillar National Monument RMP is one of the 15 RMP revisions and

amendments and environmental impact statements being prepared by the BLM as part of the 

National Greater Sage-Grouse Planning Strategy.1 These documents provide a set of

management alternatives focused on specific conservation measures across the range of the 

GRSG (see Figure ES-1 Greater Sage-Grouse Planning Strategy Boundaries).

Science-based decision making and collaboration with state and local partners are fundamental 

to the National Greater Sage-Grouse Planning Strategy. The 15 GRSG LUP/EISs address

threats to GRSG identified by state fish and wildlife agencies, the BLM National Technical 

Team, and the USFWS in the context of its listing decision and the Conservation Objectives 

Team (COT) report. The COT report was prepared by wildlife biologists from state and federal 

agencies and provides a blueprint for the overall conservation approach set forth in the BLM 

GRSG LUP/EISs.2 Where consistent with conservation objectives, the GRSG LUP/EISs 

adopt unique state- and stakeholder-developed approaches and priorities. Additional sciencebased reviews by the US Geological Survey and related scientific literature provided further 

guidance on specific issues that arose in developing the final BLM and Forest Service GRSG 

LUP/EISs. 

Figure ES-1 Greater Sage-Grouse Planning Strategy Boundaries 

1 BLM (US Department of the Interior, Bureau of Land Management). 2011. Instruction Memorandum 2012-

044, BLM National. Greater Sage-Grouse Land Use Planning Strategy. Washington, DC. December 27, 2011.

2 USFWS (US Department of the Interior, Fish and Wildlife Service). 2013. Greater Sage-grouse (Centrocercus

urophasianus) Conservation Objectives: Final Report. USFWS, Denver, CO. February 2013.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Executive Summary ES-3 

In addition, regular meetings with the Western Governors Association Sage- Grouse Task 

Force provided additional opportunities for coordination with member states.3

ES.1.2 Description of the Planning Area and Habitat Management Areas 

The planning area is the geographic area within which the BLM will make decisions 

during this planning effort. The planning area boundary includes all lands regardless of 

jurisdiction. The Billings and Pompeys Pillar National Monument RMP planning area covers

approximately 10.8 million acres of federal, state, and private lands in Big Horn, Carbon, 

Golden Valley, Musselshell, Stillwater, Sweet Grass, Wheatland, and Yellowstone counties in

Montana. The BiFO also administers 4,300 acres of public land in Big Horn County, Wyoming.

Of the total area, 434,200 acres are BLM-administered surface lands and 889,500 acres are 

BLM federal mineral estate. 

While the planning area consists of all lands regardless of ownership, decisions resulting from 

the Billings and Pompeys Pillar National Monument RMP/EIS would apply only to BLMadministered lands, including surface and split-estate lands with BLM-administered subsurface 

mineral rights. Chapter 3, Affected Environment, describes the current resource and resource 

use conditions in the planning area.

As part of the National Greater Sage-Grouse Planning Strategy, GRSG habitat on BLMadministered lands in the decision area consists of lands allocated as PHMA and GHMA 

(Table ES-1 Habitat Management Areas in the Billings Planning Area, Figure ES-2 Greater 

Sage-Grouse Habitat Management Areas – Billings and Pompeys Pillar National Monument 

RMP/EIS). PHMA and GHMA are defined as follows: 

 PHMA (158,900 acres): BLM-administered lands identified as having the highest value 

to maintaining sustainable sage-grouse populations. The boundaries and management 

strategies for PHMA are derived from and generally follow the Preliminary Priority

Habitat (PPH) boundaries (see Chapter 3, Affected Environment) identified in the 

Billings and Pompeys Pillar National Monument RMP/EIS, but may be modified 

based on the objectives of each alternative. Areas of PHMA largely coincide with areas 

identified as Priority Areas for Conservation in the COT report. 

 GHMA (113,800 acres): BLM-administered lands that require some special management

to sustain sage-grouse populations, but that are not as important as PHMA. The 

boundaries and management strategies for GHMA are derived from and generally 

follow the Preliminary General Habitat (PGH) boundaries (see Chapter 3, Affected

Environment) identified in the Billings and Pompeys Pillar National Monument 

RMP/EIS, but may be modified based on the objectives of each alternative. 

3 The Western Governors Association Sage-Grouse Task Force works to identify and implement high 

priority conservation actions and integrate ongoing actions necessary to preclude the need for the 

GRSG to be listed under the ESA. The Task Force includes designees from the 11 western states where 

GRSG is found as well as representatives from USFWS, BLM, Natural Resources Conservation Service, 

Forest Service, United States Geological Survey, and Department of the Interior. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

ES- 4 Executive Summary

The planning area includes other BLM-administered lands that are not allocated as habitat 

management areas for GRSG. These lands would be managed as described in Chapter 2 of 

the Billings and Pompeys Pillar National Monument RMP/EIS. 

Table ES-1 Habitat Management Areas in the Billings Planning Area 

Habitat Management Areas in the Billings Planning Area

Habitat Management

Area

Acres of BLMAdministered LandsPercent of BLM-Administered

Lands in Planning Area

PHMA 158,900 37

GHMA 113,800 26

Other BLM-administered

lands

161,400 37

ES.2 PURPOSE AND NEED 

The purpose of this RMP revision project is to ensure that public lands are managed 

according to the principles of multiple use identified in FLPMA while maintaining valid 

existing rights and other obligations already established. The new RMPs will address

changing needs of the Planning Area and create a management strategy that best achieves a 

combination of the following planning issues within the framework of the planning. 

 Employing a community-based planning approach to seek broadly supported solutions to

issues, and collaborate with federal, state, and local cooperating agencies. 

 Establishing goals and objectives for managing resources and resource uses in the 

434,200 surface acres and 889,500 acres of federal mineral estate in the Planning Area 

administered by the BLM BiFO in accordance with the principles of multiple use and

sustained yield. 

 Identifying land use plan decisions to guide future land management actions and subsequent 

site-specific implementation decisions. 

 Identifying management actions and allowable uses anticipated to achieve the established 

goals and objectives and reach desired outcomes. 

 Providing comprehensive management direction by making land use decisions for all 

appropriate resources and resource uses the BLM administers in the Planning Area. 

 Providing for compliance with applicable tribal, federal, and state laws, standards, and

implementation plans, and BLM policies and regulations. 

 Recognizing the Nation’s need for domestic sources of minerals, food, timber, and fiber 

 Retaining flexibility to adapt to new and emerging issues and opportunities and to provide 

for adjustments to decisions over time based on new information and monitoring. 

 Striving to be compatible with the plans and policies of adjacent local, state, tribal, and

federal agencies and consistent with federal laws, regulations, and BLM policies; and be 

flexible enough to adapt to future BLM policy and guidance updates. 

 Identify and incorporate appropriate conservation measures to conserve, enhance, and 

restore GRSG habitat by reducing, minimizing, or eliminating threats to that habitat 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Executive Summary ES-5 

Figure ES-2 Greater Sage-Grouse Habitat Management Areas – Billings and Pompeys Pillar National Monument RMP/EIS 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

ES- 6 Executive Summary

The BLM currently administers public lands in the Planning Area according to the 1984

Billings Resource Area RMP. Although this existing plan has been amended 12 times

since 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. 

This RMP is needed to respond to the USFWS’s March 2010 “warranted, but precluded” ESA

listing petition decision (75 Federal Register 13910, March 23, 2010). The USFWS identified

inadequacy of regulatory mechanisms as a significant factor in its finding on the petition to

list the GRSG. In its listing decision, the USFWS noted that changes in management of 

GRSG habitats are necessary to avoid the continued decline of GRSG populations. Changes in

land allocations and conservation measures in BLM RMPs provide a means to implement 

regulatory mechanisms to address the inadequacy identified by USFWS. 

ES.3 PROPOSED ACTION 

The proposed federal action is the Proposed Plan, which identifies resource management 

actions in accordance with the multiple-use and sustained-yield mandates of FLPMA. The 

proposed action is also intended to provide a consistent framework for managing GRSG and its

habitat on BLM-administered lands. The alternatives, including the Proposed Plan, comprise 

desired future outcomes and a range of management actions, allowable uses, and land use

allocations that guide management on BLM-administered lands. The Proposed Plan (see ES.6 

Greater Sage-Grouse Habitat Management Proposed Plan and Environmental Effects),

represents the agency’s approach for addressing the purpose and need. 

ES.4 DEVELOPMENT OF THE RMP/EIS 

ES.4.1 Scoping 

A Notice of Intent (NOI) published in the Federal Register on May 15, 2008, formally 

announced the BLM’s intent to revise the existing plan and prepare the associated EIS. 

Publication of the NOI initiated the scoping process and invited affected and interested 

agencies, organizations, and the general public to participate in determining the scope and

issues to be addressed by alternatives and analyses in the EIS. The BLM held seven public 

scoping meetings in Pompeys Pillar National Monument, Billings, Bridger, Red Lodge, Big 

Timber, and Roundup, Montana, and Lovell, Wyoming in August 2008. The seven scoping

meetings provided the public with an opportunity to learn and ask questions about the 

project and the planning process and to submit their issues and concerns to the BLM. In

addition to members of the BLM Interdisciplinary Team, about 90 people attended the 

scoping meetings. The BLM collected comments from the public during the scoping 

meetings and throughout the scoping period. The final Scoping Summary Report, available 

online at http://www.blm.gov/wo/st/en/prog/more/sagegrouse.html, prepared in conjunction

with all the GRSG LUPAs, summarizes the scoping and issue-identification process and

describes 13 broad issue categories identified during the scoping process. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Executive Summary ES-7 

ES.4.2 Cooperating Agency Collaboration 

The BLM invited 43 local, state, federal, and tribal representatives to participate as cooperating 

agencies on the Billings and Pompeys Pillar National Monument RMP/EIS. The BLM invited 

these entities to participate because they have jurisdiction by law or because they could offer 

special expertise. 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) are the fifteen agencies that 

agreed to participate as cooperating agencies in the RMP revision. The BLM and cooperating 

agencies participated in workshops in 2008 and 2009 to formulate alternatives and to keep 

cooperating agencies informed and to solicit their input. Development of this Proposed RMP 

and Final EIS considered comments from cooperating agencies on the Draft RMP and Draft

EIS and previous administrative drafts.

The BLM invited 17 Native American tribes to be cooperating agencies as part of the RMP 

revision and conducted ongoing coordination, including letters and face-to-face meetings. The 

Northern Cheyenne Tribe requested to serve as a formal cooperating agency. 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 17 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 17 tribes requesting their review/comments.

ES.4.3 Development of the Draft RMP/EIS

Development of Management Alternatives

In accordance with NEPA and the Council on Environmental Quality (CEQ) implementing 

regulations (40 Code of Federal Regulations 1500), the planning team considered public input 

and developed a reasonable range of alternatives for the Draft RMP/EIS. 

The planning team developed four unique alternatives, including one No Action Alternative and

three action alternatives, which were subsequently analyzed in the Draft RMP/EIS. Each of the 

preliminary action alternatives was designed to: 

 Address the 13 range-wide GRSG planning issues 

 Fulfill the purpose and need for the RMP 

 Meet the multiple-use and sustained-yield mandate of FLPMA 

 Respond to USFWS-identified issues and threats to GRSG and its habitat, including 

specific threats identified in the COT report 

Collectively, the three action alternatives (Alternatives B, C, and D) analyzed in the Draft 

RMP/EIS offered a range of possible management approaches for responding to the purpose 

and need as well as the planning issues and concerns identified through public scoping. While 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

ES- 8 Executive Summary

the overarching goal of the long-term conservation of GRSG and its habitat is the same

across alternatives, each alternative contains a discrete set of objectives and management 

actions, which if selected as the final plan, would constitute a unique RMP. 

Publication of Draft RMP/EIS

Public Comment Period

The Notice of Availability (NOA) for the Billings Draft RMP/EIS was published in the Federal 

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

period ended on June 29, 2013. The BLM held six public meetings in Billings, Bridger, Big 

Timber, Red Lodge, and Roundup, Montana; and Lovell, Wyoming. A total of 190 people 

attended these meetings. Written public comments were reviewed and considered by the BLM. 

Comment Analysis

During the public comment periods, the BLM received thousands of written comments by 

mail, email, and submissions at the public meetings. Comments covered a wide spectrum of 

thoughts, opinions, ideas, and concerns. Upon receipt, the BLM reviewed the comments, 

grouped similar substantive comments under an appropriate topic heading, and evaluated and

wrote summary responses addressing the comment topics. The response indicated whether or 

not the commenters’ points would result in new information or changes being included in

the Final RMP/EIS. In many circumstances, public comments prompted such changes to the 

Draft RMP/EIS. Chapter 5, Consultation and Coordination, provides a detailed description of 

the comment analysis methodology and an overview of the public comments received. 

ES.5 RMP/EIS ALTERNATIVES AND ENVIRONMENTAL EFFECTS 

ES.5.1 Alternative A 

Alternative A represents the continuation of current management under the existing land use 

plan (1984), as amended. Direction contained in existing laws, regulation, and policy would

also continue to be implemented. This alternative provides the baseline against which to

compare the other alternatives. Under Alternative A, resources, resource uses, and sensitive 

habitats would receive management emphasis (methods and mix of multiple-use management

of public land) at present levels. In general, most activities would be analyzed on a case- bycase basis, and few uses would be limited or excluded as long as land health standards would be 

met.

Impacts on GRSG and associated habitat could include short-term and long- term adverse 

habitat loss and fragmentation, species displacement due to disturbance, and degradation of

habitat quality. For GRSG, recent research findings have provided updated and more 

accurate seasonal timing restrictions and expanded protection distances than those in 

Alternative A.

ES.5.2 Alternative B 

Alternative B is based on the conservation measures developed by the BLM National 

Technical Team (NTT) planning effort described in Instruction Memorandum (IM) No. WO2012-044. As directed in the IM, the conservation measures developed by the NTT must be 

considered and analyzed, as appropriate, through the land use planning and NEPA processes by
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Executive Summary ES-9 

all BLM state and field offices that contain occupied GRSG habitat. Alternative B would

emphasize the conservation of physical, biological, and/or cultural resources over 

commodity production, mineral extraction, and motorized recreation. Relative to all 

alternatives, Alternative B conserves the most land area for physical, biological, and

cultural resources, closes the most miles of roads in travel management areas, and is the 

most restrictive to coal and fluid mineral leasing and the most restrictive to renewable energy 

development. Management actions would focus on maintaining those ecological systems that are 

functioning and healthy and restoring ecological systems that have been degraded or altered. 

Production of food, fiber, minerals and services would be more constrained than under the 

other alternatives, and in some cases and in some areas, uses would be excluded to protect 

sensitive or fragile resources. 

Alternative B would establish PHMA, GHMA, and GRSG Restoration Areas. Under this 

alternative only, PHMA (BLM-administered surface; 154,500 acres) would be administered as

an Area of Critical Environmental Concern (ACEC).

ES.5.3 Alternative C 

Alternative C would emphasize commodity production (e.g., forage and minerals), motorized 

recreational access, and services. Among the three action alternatives (Alternatives B, C, and

D), Alternative C closes the least miles of roads in travel management areas and is the least 

restrictive to coal and fluid mineral leasing. Under this alternative, constraints on commodity 

production for the protection of sensitive resources would be the least restrictive possible

within the limits defined by law, regulation, and BLM policy, including the ESA, cultural 

resource protection laws, and wetland preservation. In this alternative, constraints to protect 

sensitive resources would tend to be implemented in specified geographic areas rather than 

across the entire planning area. 

The acreages for PHMA, GHMA, and Restoration Areas are the same as under Alternatives B 

and D.

Generally, the impacts on GRSG would be greater than those described under Alternatives B 

and D, with less protection to wildlife resources due to smaller buffers and fewer avoidance

areas for ROWs and other potential development. There would be less impact on wildlife than 

Alternative A, with greater restrictions and areas closed to travel and other development. 

ES.5.4 Alternative D (Proposed RMP) 

Alternative D addresses the key planning issues identified in Chapter 1 by incorporating 

elements from each of the other alternatives to strike a balance between long-term 

conservation of public land and resources within the planning area with commodity 

production, recreational access, and services. Regarding the conservation of physical, 

biological, and cultural resources and restrictions on mineral leasing, Alternative D is generally 

between Alternatives B and C. Alternative D represents an approach to land management that

address the issues, management concerns, and purpose and need while balancing resources and

resource uses. 

The acreages for PHMA, GHMA, and Restoration Areas are the same as under Alternatives B 

and C. Within PHMA, impacts from oil and gas leasing, development, and geophysical 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

ES- 10 Executive Summary

activities, as well as surface disturbance and disruptive activities, would be similar to

Alternative B. However, Alternative B is closed to oil and gas leasing and Alternative D is an

NSO. Grazing allotments would be designated management Category I allotments. 

ES.6 GREATER SAGE-GROUSE HABITAT MANAGEMENT PROPOSED PLAN AND 

ENVIRONMENTAL EFFECTS 

In consideration of public comments, best science, cooperating agency coordination, and 

internal review of the Draft RMP/EIS, the BLM developed this Proposed Plan for Greater SageGrouse Habitat Management (Proposed Plan). The Proposed Plan represents the BLM’s

proposed approach for meeting the purpose and need consistent with the agency’s legal and 

policy mandates. 

The BLM Proposed Plan addresses threats to GRSG and its habitat identified by the USFWS in

the March 2010 listing decision that apply to the Billings planning area as well as threats 

described in the COT report. The Proposed Plan seeks to provide greater regulatory certainty 

for management actions intended to conserve the GRSG (see Figure ES-2, Key Components 

of the Billings Proposed Plan Addressing COT Report Threats). In making its determination of

whether the GRSG is warranted to be listed as threatened or endangered under the ESA, the 

USFWS will evaluate the degree to which land use planning decisions proposed in this 

RMP/EIS address threats to GRSG and its habitat.

The Proposed Plan would maintain and enhance GRSG populations and habitat. Consistent with 

the Governor of Montana’s Sage Grouse Habitat Conservation Program, the Proposed Plan 

focuses on conserving GRSG in PHMA. The Proposed Plan benefits GRSG populations by

eliminating disturbance near leks and other key areas. 

The Proposed Plan establishes conditions, subject to valid existing rights, for new 

anthropogenic activities to ensure a net conservation gain to GRSG in PHMA and GHMA.

The Proposed Plan would reduce habitat disturbance and fragmentation through limitations on

surface-disturbing activities, while addressing changes in resource condition and use through 

monitoring and adaptive management. The Proposed Plan provides a framework for prioritizing

areas in PHMA for wildfire, invasive annual grass, and conifer treatments, which will maintain

and enhance GRSG habitat. 

The Proposed Plan complements the Governor of Montana’s Sage Grouse Habitat 

Conservation Program and the Governor’s Executive Order (EO 10- 2014) by establishing 

similar conservation measures and focusing restoration efforts in the same key areas most

valuable to the GRSG. 

If the BLM finds that the State of Montana is implementing a GRSG Habitat Conservation 

Program that is effectively conserving the GRSG, the BLM will review the management 

goals and objectives to determine if they are being met and whether amendment of the BLM 

Proposed Plan is appropriate to achieve consistent and effective conservation and GRSG

management across all lands regardless of ownership. 

For a full description of the Proposed Plan, see Section 2.3.4.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Executive Summary ES-11

Table ES- 2 Key Components of the Billings Proposed Plan Addressing COT Report 

Threats 

Key Components of the Billings Proposed Plan Addressing COT Report Threats

Threats to GRSG

and its Habitat (from

COT Report)

Key Component of the Proposed Plan

All Threats

 Implement the Adaptive Management Plan, which allows for more

restrictive land use allocations and management actions to be

implemented if habitat or population hard triggers are met.

 Require and ensure mitigation that provides a net conservation gain to

GRSG.

 Monitor implementation and effectiveness of conservation measures in

GRSG habitats according to the Habitat Assessment Framework.

 Apply buffers necessary based on project type and location to address

impacts on leks when authorizing actions in GRSG habitat.

 Apply Required Design Features (RDF) when authorizing actions in

GRSG habitat.

 Prioritize the leasing and development of fluid mineral resources

outside of GRSG habitat.

All development threats,

including mining,

infrastructure, and

energy development

 PHMA: Implement an anthropogenic disturbance cap of 3% at the

Biologically Significant Unit (BSU) and project area scale.

 PHMA: Implement a density cap of an average of 1 energy and mining

facility per 640 acres.

Energy Development—

Fluid Minerals

 PHMA: Open to fluid mineral leasing subject to No Surface Occupancy

(NSO) stipulation without waiver or modification, and with limited

exception.

 GHMA: Open to fluid mineral leasing subject to NSO within 0.6 miles

of an occupied lek and Timing Limitation (TL) stipulation from March 1

to June 15 within 3 miles of a lek.

Energy Development—

Wind Energy

 PHMA: Exclusion area (not available for wind energy development

under any conditions)

 GHMA: Avoidance Area (may be available for wind energy

development with special stipulations)

Energy Development—

Solar Energy

 PHMA: Exclusion area (not available for solar energy development

under any conditions)

 GHMA: Avoidance Area (may be available for solar energy

development with special stipulations)

Infrastructure – major

Rights-of-Way (ROW)

 PHMA: Avoidance area (may be available for major ROWs with special

stipulations)

 GHMA: Avoidance area (may be available for major ROWs with

special stipulations)

Infrastructure – minor

ROWs

 PHMA: Avoidance area (may be available for minor ROWs with

special stipulations)
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

ES- 12 Executive Summary

Key Components of the Billings Proposed Plan Addressing COT Report Threats

Threats to GRSG

and its Habitat (from

COT Report)

Key Component of the Proposed Plan

Mining—locatable

minerals

 Apply RDFs to locatable minerals consistent with applicable law.

Mining—non-energy

leasable minerals

 PHMA: Closed area (not available for non-energy leasable minerals)

Mining—saleable

minerals

 PHMA: Closed area (not available for saleable minerals) with a limited

exception (may remain open to free use permits and expansion of

existing active pits if criteria are met)

Mining—coal

 PHMA is essential habitat for GRSG for purposes of the suitability

criteria set forth at 43 CFR 3461.5(o)(1).

Livestock Grazing

 Prioritize the review and processing of grazing permits/leases in

PHMA.

 The NEPA analysis for renewals and modifications of grazing

permits/leases will include specific management thresholds, based on

the GRSG Habitat Objectives Table, Land Health Standards and

ecological site potential, to allow adjustments to grazing that have

already been subjected to NEPA analysis.

 Prioritize field checks in PHMA to ensure compliance with the terms

and conditions of grazing permits.

Free-Roaming Equid

Management

 Not applicable. Not present in GRSG habitat in the planning area.

Range Management

Structures

 Allow range improvements which do not impact GRSG, or which

provide a conservation benefit to GRSG such as fences for protecting

important seasonal habitats.

Recreation  PHMA: Do not construct new recreation facilities.

Fire

 PHMA: Only treatments that conserve, enhance, or restore Greater

Sage-Grouse habitat would be allowed.

Nonnative, Invasive

Plants Species

 Noxious and invasive weed control would not occur within 0.5 mile of

nesting and brood rearing areas for special status species during the

nesting and brood rearing season.

 Use Integrated Pest Management to make progress towards a healthy

plant community.

Sagebrush Removal

 PHMA: Maintain a minimum of 70 percent of lands capable of

producing sagebrush with 10 to 30 percent sagebrush canopy cover.

 All BLM use authorizations will contain terms and conditions regarding

the actions needed to meet or progress toward meeting the habitat

objectives for GRSG.

Pinyon and/or Juniper

Expansion

 Remove conifers encroaching into sagebrush habitats, prioritizing

occupied GRSG habitat.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Executive Summary ES-13

Key Components of the Billings Proposed Plan Addressing COT Report Threats

Threats to GRSG

and its Habitat (from

COT Report)

Key Component of the Proposed Plan

Agricultural Conversion

and Ex-Urban

Development

 GRSG habitat will be retained in federal management.

ES.7 SUMMARY 

Since the release of the Draft Billings and Pompeys Pillar National Monument RMP/EIS, the 

BLM has continued to work closely with a broad range of governmental partners, including the 

United States Department of Agriculture Natural Resources Conservation Service, the USFWS 

and US Geological Survey in DOI, Indian tribes, governors, state agencies, and county 

commissioners. Through this cooperation, the BLM has developed the Proposed Plan that, in 

accordance with applicable law, achieves the long-term conservation of GRSG and its habitat. 

Conservation of the GRSG is a large-scale challenge that requires a landscape- scale solution that 

spans 11 western states. The Billings and Pompeys Pillar National Monument RMP/EIS achieves 

the consistent, range-wide conservation objectives as outlined below. Additionally, the Billings 

and Pompeys Pillar National Monument RMP/EIS aligns with the State of Montana priorities and

land management approaches consistent with conservation of GRSG. 

Minimize additional surface disturbance. The most effective way to conserve GRSG is to

protect existing, intact habitat. The BLM aims to reduce habitat fragmentation and protect key 

habitat areas. The Billings and Pompeys Pillar National Monument RMP/EIS minimizes 

surface disturbance on 434,200 acres of BLM-administered lands by allocating lands as

PHMA and GHMA with decisions that aim to conserve GRSG habitat. 

The most important aspects from the Proposed Plan that minimize surface disturbance 

include the 3 percent cap on anthropogenic surface disturbances in PHMA, the NSO stipulation 

that prohibits surface occupancy and use in PHMA, managing PHMA as ROW exclusion for 

renewable and solar energy exploration and facility development, and managing PHMA as ROW 

avoidance for major and minor ROWs. 

Improve habitat condition. While restoring lost sagebrush habitat can be very difficult in

the short term, particularly in the most arid areas, it is often possible to enhance habitat 

quality through purposeful management. The Billings and Pompeys Pillar National Monument 

RMP/EIS commits to management actions necessary to achieve science-based vegetation and

GRSG habitat management objectives established in the Proposed Plan. 

Vegetation treatments would be used to improve GRSG habitat. For example, treatment 

methods, including prescribed burning and mechanical treatments would be used to eliminate

conifer encroachment and stimulate vegetative re- growth in grassland/shrub land habitats,
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

ES- 14 Executive Summary

reduce fuels, thin under-stories, recycle nutrients, and create small openings in forested 

vegetation types. Prescribed fire could also be used to meet specific fuels objectives that would

protect GRSG habitat in PHMA (e.g., used as a component with other treatment methods to

combat annual grasses and restore native plant communities). 

Reduce threat of rangeland fire to sage-grouse and sagebrush habitat. Rangeland fire can 

destroy sagebrush habitat and lead to the conversion of previously healthy habitat into 

landscapes dominated by invasive species. The Billings and Pompeys Pillar National 

Monument RMP/EIS incorporates Secretarial Order 3336 and sets forth protocols to improve the 

BLM’s ability to protect GRSG habitat from damaging wildfire.

Within PHMA, only treatments that conserve, enhance, or restore GRSG habitat would be 

allowed. Prescribed fire could be used to meet specific fuels objectives that would protect 

GSRG habitat in PHMA (e.g., creation of fuel breaks that would disrupt the fuel continuity 

across the landscape in stands where annual invasive grasses are a minor component in the 

understory). 

A fire risk assessment would be completed for implementation of prescribed fire in relation to

GRSG goals and objectives. When prescribed fire is used for vegetation treatments, the burn 

plan would clearly indicate how COT objectives would be addressed and met by use of 

prescribed fire and why alternative techniques for vegetation treatment were not selected.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Reader’s Guide to This Document

Volume 1

• Chapter 1: Purpose and Need for Action. This chapter introduces the Proposed 

Resource Management Plan and Final Environmental Impact Statement (PRMP/FEIS), 

describes the purpose and need to which BLM is responding, provides an overview of 

the BLM planning process, identifies planning issues and criteria, summarizes 

consultation and coordination, and identified topics not addressed by this RMP revision. 

• Chapter 2: Resource Management Alternatives. Chapter 2 describes how the four 

alternatives (A through D) were developed, the components and content of each 

alternative, and discusses the alternatives considered but eliminated from further 

consideration. It also presents a comparative summary of impacts of each alternative. 

Resource discussions in Chapters 2, 3, and 4 are organized according to the following 

topics: 

► Physical, Biological, and Cultural/Heritage Resources – Air, Climate Change, 

Geology, Soil, Water, Vegetation (Forests and Woodlands, Rangelands, 

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 and Burros, Cultural Resources, 

Paleontological Resources, Visual Resources, Wildland Fire Ecology and 

Management, Wilderness Characteristics, Cave and Karst Resources

► Resource Uses and Support – Energy and Mineral Resources (Coal, Fluid 

Minerals, Locatable Minerals, Mineral Materials), Forestry and Woodland 

Products, Realty, Cadastral Survey, and Realty (Land Tenure Adjustment and 

Access; Rights-of-Way, Leases and Permits; and Withdrawals), Livestock 

Grazing, Recreation and Visitor Services, Trails and Travel Management, 

Renewable Energy, Transportation and Facilities

► Special Designations – Pompeys Pillar National Monument and ACEC, Areas 

of Critical Environmental Concern, Wilderness Study Areas, Wild and Scenic 

Rivers, Pryor Mountain Wild Horse Range, and National Historic Trails 

► Socioeconomic Resources – Social and Economic Conditions, Environmental 

Justice, and Tribal Treaty Rights

• Chapter 3: Affected Environment. This chapter describes the Decision Area and the 

existing environmental conditions that could be impacted by the alternatives. Chapter 3 

also serves as the baseline for analysis of impacts in Chapter 4. 

Volume 2

• Chapter 4: Environmental Consequences. Chapter 4 forms the scientific and analytic 

basis for comparing environmental impacts of each alternative, including the No Action 

Alternative. Impacts generally are described in terms of direct or indirect and short-term 

or long-term, when applicable. Potential cumulative and unavoidable impacts and 

irreversible and irretrievable commitments are also discussed in this chapter. 

Reader’s Guide RG-1 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Volume 3

• Chapter 5: Consultation and Coordination. This chapter describes the public 

participation opportunities and the consultation and collaborative efforts made as part of 

the RMP/EIS revision process. It includes a summary of the issues brought forward 

during the public comment period, list of the commenters, and the comments with 

responses. This chapter also includes the names and qualifications of the people 

responsible for preparing this Proposed RMP and Final EIS. 

• Chapter 6: References. This chapter provides full citation information for all 

references cited within the document.

• Glossary: The glossary defines select terms used throughout this document. 

• Appendices A-B: The appendices include documents that support existing resource 

conditions or situations, substantiate analyses, provide resource management guidance, 

explain processes, or provide information directly relevant or supporting conclusions in 

the Proposed RMP and Final EIS. There are twenty-nine numbered appendices, two of 

which are included in this volume. 

Volume 4 

• Appendices C through O: The appendices include documents that support existing 

resource conditions or situations, substantiate analyses, provide resource management 

guidance, explain processes, or provide information directly relevant or supporting 

conclusions in the Proposed RMP and Final EIS. There are twenty-nine numbered 

appendices, thirteen of which are included in this volume 

Volume 5

• Appendices P through Z, AA, AB, and AC: The appendices include documents that 

support existing resource conditions or situations, substantiate analyses, provide 

resource management guidance, explain processes, or provide information directly 

relevant or supporting conclusions in the Proposed RMP and Final EIS. There are 

twenty-nine numbered appendices, fourteen of which are included in this volume. 

• Maps: Maps depict the affected environment or the alternatives by resource. For hard 

copy versions of the document, all maps except the oversize Travel Management Area

(TMA) maps are printed and found after Appendix AC. All maps, including the Travel 

Management Area (TMA) maps, can be found, along with an electronic version of the 

document on a DVD at the back of Volume 2. For DVD versions of the document, 

maps are provided in a separate file on the DVD. Electronic copies of the maps are also 

available on the project website: http://on.doi.gov/1EJBdaE

Reader’s Guide RG-2 
CHAPTER 1:

PURPOSE AND NEED 

FOR ACTION

CHAPTER 1:

PURPOSE AND NEED 

FOR ACTION

Greater Sage-Grouse
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Proposed Resource Management Plan and Final Environmental Impact Statement

1 Purpose and Need

1.1 Introduction and Background

Chapter 1 contains background information on the planning process and sets the stage for the 

information that is presented in the rest of the document. There are seven main sections in 

Chapter 1. They are:

• 1.1 Introduction and Background 

► Historical Overview

► Land Ownership

► Description of the Billings Field Office Planning Area

• 1.2 Purpose and Need for the Resource Management Plan Revision 

► Purpose 

► Need for Revising the Existing Plan

• 1.3 Planning Process 

► Nine Step Planning Process 

• 1.4 Decision Framework

► Planning Issues

► Planning Criteria

► Land Use Planning Decision Levels

• 1.5 Consistency with Other Programs, Plans, and Policies 

• 1.6 Consultation and Coordination 

• 1.7 Policy

In accordance with the Federal Land Policy and Management Act of 1976 (FLPMA), the 

Bureau of Land Management (BLM) is responsible for management of public lands and its 

resources based on the principles of multiple use and sustained yield. Management direction is 

provided by land use plans, which determine appropriate multiple uses, allocate resources, 

develop strategies to manage and protect resources, and establish systems to monitor and 

evaluate the status of resources and effectiveness of management. Land use plans are intended 

to guide management, allowing continuing uses of public land over extended time periods. 

This Proposed Resource Management Plan (RMP) and Final Environmental Impact Statement 

(EIS) will provide direction for the future management of public lands and resources 

administered by the Bureau of Land Management (BLM), Billings Field Office and Pompeys 

Pillar National Monument. The planning area is located in south central Montana and includes 

434,154 surface acres of public land and 889,479 acres of federal mineral estate in Big Horn, 

Carbon, Golden Valley, Musselshell, Stillwater, Sweet Grass, Wheatland, and Yellowstone 

counties in Montana. The Billings Field Office also administers 4,298 acres of public land in 

Big Horn County, Wyoming (see Table 1-1) as part of the Pryor Mountain Wild Horse Range. 

The RMP/EIS will also address management for the 51 acres of public land designated as 

Pompeys Pillar National Monument (PPNM). Collectively, the lands that BLM administers 

(surface and mineral estate) are considered the “decision area.” 

Chapter 1: Purpose and Need for Action 1-1 
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1.1.1 Historical Overview

In 1946, the U.S. Grazing Service merged with the General Land Office to form the BLM. The 

foundation for the BLM dates back to the Land Ordinance of 1785, which established the 

public domain and led to the creation of the General Land Office. The Northwest Ordinance of 

1787 instituted the survey and settlement of lands ceded from the 13 colonies to the federal 

government and lands later acquired by the government from other countries. While the 

Nation’s westward expansion progressed and the land base expanded, the settlement of western 

lands was encouraged through the enactment of a variety of laws, including the Homestead acts 

and the Mining Law of 1872. Over time, the luring of pioneers to settle the west became less 

necessary and the commercial value of these lands increased. A variety of statutes established

to manage mineral, timber, or livestock foraging activities on public lands followed. For 

example, the Mineral Leasing Act of 1920 allowed leasing, exploration, and production of 

selected commodities, such as coal, oil, gas, and sodium, on public lands. Another example is 

the Taylor Grazing Act of 1934, which provided for management of the public rangelands. 

After passage of the Federal Land Policy and Management Act of 1976 (FLPMA), BLMadministered lands were managed according to the principles of multiple use and sustained 

yield. Since 1976, the BLM has managed for multiple use and to balance increasing and 

competing demands for resources on public lands.

1.1.2 Land Ownership within the Billings Field Office Planning Area 

As defined by Section 103(e) of FLPMA, “...public lands mean 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...” The U.S. Department of the Interior (USDOI) BLM Billings 

Field Office is responsible for managing the public lands in Big Horn, Carbon, Golden Valley, 

Musselshell, Stillwater, Sweet Grass, Wheatland, and Yellowstone counties, Montana as well 

as 4,298 acres of public land in Big Horn County, Wyoming. County governments have land 

use planning responsibility for the private lands located within their jurisdictions. 

Except for Carbon County, most of the public land in the planning area is in scattered tracts 

intermingled with state and private lands. Throughout the planning area, there are also 

intermingled mineral ownerships, as well as federal minerals under privately owned surface, 

usually referred to as split-estate land. The scattered surface land pattern and varied mineral 

ownerships, along with split-estate lands, strongly impact management options. Appendix G 

provides details regarding split estate lands and the BLM’s administrative responsibilities for 

managing the federal minerals. 

The Billings Field Office is located in the south central portion of Montana and covers a total 

of approximately 10.8 million surface acres of federal, state, tribal, and private lands in eight 

counties (Figure 1-1). Of the total area, the Billings Field Office has surface management

responsibility for approximately 434,154 acres (about four percent of the planning area) of 

BLM administered public land (herein referred to as public land) (Figure 1-2). The Billings 

Field Office also has administrative responsibility for approximately 889,479 acres of federal 

mineral estate (Figure 1-3). The Billings and Pompeys Pillar National Monument RMP 

decision area also includes administration of approximately 4,298 acres of public land of the 

Pryor Mountain Wild Horse Range (PMWHR) in Big Horn County, Wyoming (BLM MOUMT931-6901) (Appendix Q) and Pompeys Pillar National Monument (51 acres). 

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In this document, the term “planning area” applies to all lands within the nine-county area, 

regardless of surface ownership (Figure 1-1). Table 1-1 summarizes the surface land ownership 

and federal mineral estate within the planning area. Collectively, the lands that BLM 

administers (surface and mineral estate) are considered the “decision area.” RMP decisions 

apply only to BLM-administered public lands and resources, with the exception being Bureau 

of Reclamation lands where the oil and gas is under federal jurisdiction then the oil and gas 

decisions made in this RMP/EIS do apply. It is important to note that the BLM may only make 

decisions that affect public lands and resources, but it is responsible for collaborative planning 

with the public and adjacent jurisdictions so as to consider the impacts of its actions on all 

resources in the region. 

Table 1-1 Land Ownership – Billings Planning Area

County Ownership

(In Acres)

BLM Public Lands (in Planning Area)

BLM Federal 

Mineral Estate (in Planning Area)

Other Surface Owners

(Private, State, Other Federal)

Big Horn, MT 7 1.015 2,572,759

Big Horn, WYa 4,298 4,298 0

Carbon 220,556 341,380 1,319,729

Golden Valley 7,943 44,360 755,843

Musselshell 101,247 226,885 1,197,198

Stillwater 5,504 58,359 1,154,905

Sweet Grass 15,893 75,229 1,191,450

Wheatland 1,333 21,433 913,802

Yellowstone 77,540 116,517 1,695,307

TOTAL 434,321 889,479 10,803,310

Note: a Billings Field Office has administrative authority for 4,298 acres of public land located in Wyoming as part of the Pryor Mountain 

Wild Horse Range. 

1.1.3 Description of the Billings Field Office Planning Area 

The planning area is bisected by several major rivers: the Bighorn, Yellowstone, Musselshell, 

Clark’s Fork of the Yellowstone, Stillwater, and Boulder, and includes portions of several 

mountain ranges: Little Snowy, Snowy, Belt, Crazy, Absaroka, Beartooth, Bull, and Pryor 

mountains. Except for several contiguous blocks of land in Carbon and Musselshell counties, 

most of the BLM public lands in the planning area are scattered tracts intermingled with private 

and state lands. Lands managed by the Billings Field Office include public domain (lands 

which have never left federal ownership), acquired lands and/or mineral interests (lands which 

left federal ownership and were later purchased under the Bankhead-Jones Act, exchanged for, 

donated, or purchased) and federal mineral estate (subsurface) lands beneath private or state

lands or lands administered by other federal agencies (Figure 1-2 and Figure 1-3). The RMP 

will not make decisions for the surface or mineral estates of private or state-owned lands and 

minerals. The RMP, however, will provide stipulations for split estate situations involving 

federal oil and gas (O&G) overlain by private or state-owned surface.

Chapter 1: Purpose and Need for Action 1-3 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Figure 1-1: Billings Field Office Planning Area Map 

1-4 Chapter 1: Purpose and Need for Action
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Proposed Resource Management Plan and Final Environmental Impact Statement

Figure 1-2: Public Lands within the Billings Field Office Planning Area

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Proposed Resource Management Plan and Final Environmental Impact Statement

Figure 1-3: BLM Federal Minerals within the Billings Field Office Planning Area

Chapter 1: Purpose and Need for Action 1-7 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Figure 1-4: BLM Surface, BLM Federal Minerals and GRSG Priority and General Habitat within the Billings Field Office Planning Area

BLM Managed Surface, Federal 

Minerals, and Sage-Grouse 

Priority and General Habitat 

within the Billings Field Office 

Planning Area 

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Proposed Resource Management Plan and Final Environmental Impact Statement

1.2 Purpose and Need for the Resource Management Plan 

Revision

Council on Environmental Quality (CEQ) regulations (40 Code of Federal Regulations [CFR] 

1502.13) require the purpose and need of an environmental impact statement (EIS) to “briefly 

specify the underlying purpose and need to which the agency is responding in proposing the 

alternatives.” The purpose and need section of this RMP/EIS provides a context and framework 

for establishing and evaluating the reasonable range of alternatives described in Chapter 2.

1.2.1 Purpose 

Section 102 of FLPMA sets forth the policy for periodically projecting the present and future 

use of public lands and their resources using the land use planning process. Sections 201 and 

202 of FLPMA establish the BLM’s land use planning requirements. BLM Handbook 

H-1601-1, Land Use Planning Handbook, provides guidance for implementing the BLM land 

use planning requirements established by Sections 201 and 202 of FLPMA and the regulations 

in 43 CFR 1600. 

The purpose, or goal, of the land use plan is to provide a comprehensive framework for the 

BLM’s management of the public lands within the planning area, and to ensure these public 

lands are managed in accordance with FLPMA and the principles of multiple use and sustained 

yield. The purpose of this plan revision is to consolidate the existing land use plans and their 

amendments, and to reevaluate, with public involvement, existing conditions, resources, and 

uses and reconsider the mix of resource allocations and management decisions that are 

designed to balance uses with the protection of resources pursuant to FLPMA and other 

applicable law. This resource management plan (RMP) revision will address the growing needs 

of the planning area and result in selection of a management strategy that best achieves a 

combination of the following: 

• Employ a community-based planning approach to collaborate with federal, state, 

and local cooperating agencies.

• Resolve multiple use conflicts or issues between resource values and resource 

uses. The resulting RMP will establish consolidated guidance and updated goals, 

objectives, and management actions for the public lands in the Billings Field 

Office. The RMP will be comprehensive in nature and will address issues that 

have been identified through agency, interagency, and public scoping efforts. 

• Establish goals and objectives (desired outcomes) for management of resources 

and resource uses within the approximately 434,321 surface/mineral estate acres 

and an additional 889,479 acres of federal mineral estate (underlying private or 

state surface) administered by the BLM Billings Field Office in accordance with 

the principles of multiple use and sustained yield. 

• Identify land use plan decisions to guide future land management actions and 

subsequent site-specific implementation decisions. 

Chapter 1: Purpose and Need for Action 1-9 
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Proposed Resource Management Plan and Final Environmental Impact Statement

• Identify management actions and allowable uses anticipated to achieve the 

established goals and objectives and reach desired outcomes.

• Provide comprehensive management direction by making land use decisions for 

all appropriate resources and resource uses administered by the Billings Field 

Office. 

• Provide for compliance with applicable tribal, federal, and state laws, standards, 

implementation plans, and BLM policies and regulations. 

• Recognize the nation’s needs for domestic sources of minerals, food, timber, and 

fiber, and incorporate requirements of the Energy Policy and Conservation Act 

(EPCA) Reauthorization of 2000. 

• Retain flexibility to adapt to new and emerging issues and opportunities and to 

provide for adjustments to decisions over time based on new information and 

monitoring. 

• Strive to be compatible with existing plans and policies of adjacent local, state, 

tribal, and federal agencies and be consistent with federal law, regulations, and 

BLM policy. 

• Incorporate appropriate management actions and practices to conserve Greater 

Sage-grouse and its habitats on BLM managed land. 

1.2.2 Need for Revising the Existing Plan 

Currently, lands within the Billings Field Office decision area, including Pompeys Pillar 

National Monument, are managed according to the 1984 Billings Resource Area RMP, as 

amended.

The BLM identified the need to revise this land use plan through a formal plan evaluation 

completed in 2009. Since completion of the 1984 RMP, considerable changes have occurred 

within the decision area. Heightened public awareness, increased public demand for use of the 

lands, and increases in conflict between competing resource values and land uses continue to 

challenge the BLM’s management goals and objectives. The Billings Field Office is facing a 

wide variety of issues affecting local communities, regional, and state interests, and the health 

of the public lands. This, along with emerging issues and changing circumstances, resulted in 

the need to revise the existing plans. Given the nature of the issues that face the Billings Field 

Office and their overlap among federal, tribal, state, and local jurisdictions, the Billings Field 

Office will revise the existing land use plan, as amended, into one planning document – the 

Billings and Pompeys Pillar National Monument RMP/EIS. This plan revision is a combined 

effort that addresses both the Billings Field Office and the Pompeys Pillar National monument 

in a consolidated RMP and associated EIS. This document refers to the combined Billings and 

PPNM planning areas as the Planning Area and is referenced throughout the document as the 

Billings and Pompeys Pillar National Monument DRMP/EIS.

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Proposed Resource Management Plan and Final Environmental Impact Statement

There are a number of new issues (such as new Endangered Species Act listings), higher levels 

of controversy around existing issues, and new (unforeseen) public land uses and concerns that 

have arisen over the years which the BLM intends to address through this revision. These and 

other select examples of new data, new and revised policies, and emerging issues and changing 

circumstances demonstrate the need to revise the existing plans. 

The March 4, 2010 decision by the U.S. Fish and Wildlife Service that the greater sage-grouse 

warranted listing but was precluded [Endangered and Threatened Wildlife and Plants; 12-

Month Findings for Petitions to list the Greater Sage-Grouse (Centrocercus urophasianus) as 

Threatened or Endangered] set in motion the most comprehensive land-use planning initiative 

in the BLM’s history. 

In 2011, the BLM began updating land-use plans across the West so as to ensure not only the 

long-term viability of the greater sage-grouse on public lands and the continued economic 

vitality of the West. This has been a complex and demanding process involving collaboration 

with an unprecedented number of stakeholders, including Governors, State Fish and Game 

agencies, the U.S. Fish and Wildlife Service and many others. The BLM’s mandate of multiple 

use and sustained yield has required us to balance the full range of resource uses on public 

lands, including the conservation of crucial wildlife habitat. As we have worked through this 

process, public land managers throughout the BLM have made difficult resource management 

decisions. 

These documents provide key guidance that will enable the BLM to finalize land use plans that 

will contribute to the conservation of the Greater Sage-Grouse and other sagebrush associated 

species across the West. The guidance outlines a suite of tools, such as disturbance limits in 

key habitats, net conservation gain, and mitigation approaches, which will help us to reach this 

goal. These mechanisms will work in concert to conserve sage-grouse habitat so that we can 

achieve our twin goals of thriving Greater Sage-Grouse populations and robust Western 

economies.

Greater Sage-grouse Conservation Objectives: Priority Areas for Conservation (PAC) and 

how they correlate with Priority and General Habitat Management Areas 

In 2012, the Director of the U.S. Fish and Wildlife Service (USFWS) asked the Conservation 

Objectives Team (COT), consisting of state and USFWS representatives, to produce 

recommendations regarding the degree to which the threats need to be reduced or ameliorated 

to conserve greater sage-grouse (GRSG) so that it would no longer be in danger of extinction or 

likely to become in danger of extinction in the foreseeable future. The COT Report (USFWS 

2013a) provides objectives based upon the best scientific and commercial data available at the 

time of its release. The BLM/FS planning decisions analyzed in the LUP/EISs are intended to 

ameliorate threats identified in the COT report and to reverse the trends in habitat condition. 

The COT Report can be viewed online at the following address: 

http://www.fws.gov/mountain-prairie/species/birds/sagegrouse/COT/COT-Report-with-DearInterested-Reader-Letter.pdf 

Chapter 1: Purpose and Need for Action 1-11
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The highest level objective in the COT Report is identified as meeting the objectives of 

Western Association of Fish and Wildlife Agencies’ (WAFWA) 2006 GRSG Comprehensive 

Strategy of “reversing negative population trends and achieving a neutral or positive population 

trend.” 

The COT Report provides a WAFWA Management Zone and Population Risk Assessment. 

The report identifies localized threats from sagebrush elimination, fire, conifer encroachment, 

weed and annual grass invasion, mining, free-roaming wild horses and burros, urbanization, 

and widespread threats from energy development, infrastructure, grazing, and recreation 

(USFWS 2013a, p. 18). 

Key areas across the landscape that are considered “necessary to maintain redundant, 

representative, and resilient populations” are identified within the COT Report. The USFWS in 

concert with the respective state wildlife management agencies identified these key areas as 

Priority Areas for Conservation (PACs). 

Within the Billings Field Office Planning Area boundaries, the PACs consist of a total 

4,050,227 acres, regardless of land ownership. Under the Proposed Plan, the PACs are 

comprised of 158,926 surface acres of PHMA managed by the BLM, 113,816 surface acres of 

GHMA managed by the BLM, and 78,927 surface acres of Restoration habitat managed by the 

BLM (Figure 1-4). 

Conservation Buffer Distance Estimates for Greater Sage-Grouse – A Review: 

On November 21, 2014 the USGS published “Conservation Buffer Distance Estimates for 

Greater Sage-Grouse—A Review” (USGS 2014). The USGS review provided a compilation 

and summary of published scientific studies that evaluate the influence of anthropogenic 

activities and infrastructure on GRSG populations. The BLM has reviewed this information and 

examined how lek buffer-distances were addressed through land use allocations and other 

management actions in the Draft Billings and Pompeys Pillar National Monument RMP/EIS. 

Based on this review, in undertaking BLM management actions, and consistent with valid and 

existing rights and applicable law in authorizing third party actions, the BLM will apply the lek 

buffer-distances in the USGS Report “Conservation Buffer Distance Estimates for Greater Sage 

Grouse-A Review (Open File Report 2014-1239)” in both GHMA and PHMA as detailed in 

Appendix AA (section G). 

This RMP revision incorporates specific management actions and conservation measures to 

conserve Greater sage-grouse and its habitats on BLM land. 

1.3 Planning Process

The process for the development, approval, maintenance, and amendment or revision of RMPs 

was initiated under the authority of Section 202(f) of FLPMA and Section 202(c) of the 

National Environmental Policy Act (NEPA). The process is guided by BLM planning 

regulations in 43 CFR 1600 and CEQ regulations in 40 CFR 1500. 

The hierarchy of documents that BLM decision-makers consider for planning and project 

implementation is: 

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• Land Use Plans. The highest level of decision-making specific to land use is the 

resource management plan (RMP). RMPs generally make land allocations and provide 

goals and objectives for managing specific areas of land. They provide the framework 

for managing all natural resources under BLM authority for the planning area. Plan 

decisions are based on a public NEPA disclosure process, usually an EIS. 

• Activity Plans. Mid-level decisions are provided in activity plans. These plans contain 

more detailed management decisions than do RMPs. Activity plans address 

management of specific programs or areas. Examples include allotment management 

plans, recreation area management plans, and habitat management plans. An activity 

plan usually selects and applies best management practices to meet land use plan 

objectives. Decisions that cover major (often geographically widespread) proposals lead 

to coordinated activity plans that cover all programs in an integrated manner. 

• Project Plans. The BLM analyzes individual projects proposed in a specific location for 

localized or site-specific effects. For example, the BLM would evaluate a range 

improvement proposal with a site-specific environmental analysis including NEPA, 

Endangered Species Act (ESA) consultation, and National Historic Preservation Act 

(NHPA) consultation. 

All management direction or actions developed as part of the BLM planning process are subject 

to valid rights and must meet the objectives of the BLM’s multiple use management mandate 

and responsibilities (FLPMA Section 202[c] and [e]). Valid rights include all valid leases, 

permits, patents, rights-of-way (ROW), or other land use rights or authorizations existing on the 

date of the approval of FLPMA. 

The FLPMA requires the BLM to use land use plans as tools by which “present and future use 

is projected” (43 U.S.C. 1701 (a)(2)). The act’s implementing regulations for planning, 43 CFR 

Part 1600, state that land use plans are a preliminary step in the overall process of managing 

public lands, “designed to guide and control future management actions and the development of 

subsequent, more detailed and limited scope plans for resources and uses” (43 CFR Part 

1601.0-2). Public participation and input are important components of land use planning. 

Revision of existing land use plans is a major federal action for the BLM. The National 

Environmental Policy Act (NEPA) of 1969, as amended, requires federal agencies to prepare 

an EIS for major federal actions (USDI Departmental Manual Part 516 Chapter 11.4A(1)); 

thus, this EIS accompanies the revision of the existing plans. This RMP/EIS analyzes the 

impacts of four alternative scenarios for management of the public lands and resources within 

the planning area, including the No Action Alternative. The No Action Alternative reflects 

current management. The NEPA requires analysis of a No Action Alternative.

1.3.1 Nine-Step Planning Process

The BLM uses a nine-step planning process (see Figure 1-5) when developing and revising 

RMPs, as required by 43 CFR 1600 and planning program guidance in the BLM Land Use 

Planning Handbook H-1601-1. The planning process is designed to help the BLM identify the 

uses of BLM-administered lands desired by the public and to consider these uses to the extent 

Chapter 1: Purpose and Need for Action 1-13
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Proposed Resource Management Plan and Final Environmental Impact Statement

they are consistent with the laws established by Congress and the policies of the executive 

branch of the federal government.

The planning process is issue-driven (Step 1). The plan revision process is undertaken to 

resolve management issues and problems as well as to take advantage of management 

opportunities. The BLM utilized the public scoping process to identify planning issues to direct 

(drive) the revision of the existing plans. The scoping process was also used to introduce the 

public to preliminary planning criteria, which set limits to the scope of the RMP revision 

(Step 2).

As appropriate, the BLM used existing data from a variety of sources and collected new data as 

necessary to address planning issues and to fill data gaps identified during public scoping (Step 

3). Using these data, the planning issues, and the planning criteria, the BLM conducted an 

Analysis of the Management Situation (AMS) (Step 4) to describe current management and 

identify management opportunities for addressing the planning issues. Current management 

reflects management under the existing plans and management that would continue through 

selection of the No Action Alternative. The existing affected environment is summarized from 

the AMS into Chapter 3 of the RMP/EIS. The AMS is included as part of the Administrative 

Record for this plan and is available in the Billings Field Office and on the Billings Field 

Office’s planning website (http://on.doi.gov/1EJBdaE).

Results of the first four steps of the planning process clarified the purpose and need and 

identified key planning issues that need to be addressed in the RMP. Key planning issues 

reflect the focus of the RMP revision and are described in more detail in the Planning Issues 

section of this RMP/EIS. 

Alternatives constitute a range of management actions which are anticipated to achieve 

identified goals or objectives. During alternative formulation (Step 5), the BLM Billings Field 

Office collaborated with cooperating agencies to identify goals and objectives (desired 

outcomes) for resources and resource uses in the planning area. 

These desired outcomes addressed the key planning issues, were constrained by the planning 

criteria, and incorporated the management opportunities identified by the BLM. Details of the 

alternatives were developed through the identification of management actions and allowable 

uses anticipated to achieve the goals and objectives. The alternatives represent a reasonable 

range for managing resources and resource uses within the planning area under the multiple use 

and sustained yield mandate of FLPMA. Chapter 2 of this document describes and summarizes 

the alternatives. 

This RMP/EIS also includes an analysis of the impacts of each alternative in Chapter 4 

(Step 6). With input from cooperating agencies and BLM specialists, and in consideration of 

planning issues, planning criteria, and the impacts of the alternatives, the BLM has identified a 

Proposed Alternative (Alternative D) from among the four alternatives (Step 7). This is 

documented in the RMP/EIS, which will be distributed to the public for review and comment 

(also Step 7). 

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Step 8 of the land use planning process will occur following receipt and consideration of public 

comments on the RMP/EIS. In preparing the Proposed RMP/Final EIS, the BLM has

considered all comments received during the public comment period. In developing the 

Proposed RMP/Final EIS, the Montana BLM State Director, who is the decision maker for this 

plan revision, has the authority and discretion to select an alternative in its entirety or to 

combine components of the various alternatives presented to prioritize differing resources 

and/or uses consistent with the multiple use and sustained yield mandate. Because these are 

combined planning efforts, upon issuance of the Billings and PPNM Proposed RMP and Final 

EIS, and subsequent reviews and resolution of protests, if any, two separate Records of 

Decision (RODs) will be issued. The regulations at 43 CFR Part 1610 provide, prior to the 

approval of the proposed RMP, a 60-day period for the governor of Montana for “consistency 

review” and a 30-day period to protest the Proposed RMP to the BLM Director for “any person 

who participated in the planning process and has an interest which is or may be adversely 

affected by the approval” of the Proposed RMP/Final EIS. Step 9, Monitoring and Evaluation, 

occurs after a Record of Decision (ROD) is issued and the Approved RMP is being 

implemented.

Figure 1-5: Nine Step Planning Process

Source: 43 CFR 1610.4

Note: * Public participation is invited throughout the planning process, but is formally requested at these steps.

** The RMP will be revised as necessary based on monitoring and evaluation findings, new data, new or revised 

policy, and changes in circumstances consistent with applicable laws and regulations.

1.4 Decision Framework

As stated in the previous section, identifying the planning issues and developing planning 

criteria are the first steps in defining the scope of the RMP revision. The planning issues and 

criteria provide the framework in which planning decisions are made. Planning decisions refer 

to what is established or determined by the approved RMP. The RMP provides guidance for 

planning decisions according to the following categories: 

Step 1 • Scoping and Identification of Issues *

Step 2 • Development of Planning Criteria *

Step 3 • Inventory Data and Information Collection

Step 4 • Analysis of the Management Situation

Step 5 • Formulation of Alternatives

Step 6 • Estimation of Effects Alternatives

Step 7 • Selection of Preferred Alternative. 

Step 8 • Selection of the RMP *

Step 9 • Monitoring and Evaluation ** 

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Proposed Resource Management Plan and Final Environmental Impact Statement

• Physical, Biological, and Cultural/Heritage Resources

• Resource Uses and Support 

• Special Designations 

In the context of these categories, management strategies were developed to provide viable 

options for addressing planning issues. The management strategies provide the building blocks 

from which general management scenarios and the more detailed resource management 

alternatives were developed. The resource management alternatives reflect a reasonable range 

of management options that fall within limits set by the planning criteria. The planning issues 

and planning criteria used to revise the existing plans are described in the following sections. 

1.4.1 Planning Issues

The BLM conducted an early and open scoping process to determine the scope, or range, of 

issues to be addressed in this RMP/EIS. Scoping identifies the affected public and agency 

concerns, defines the relevant issues and alternatives that will be examined in detail in the 

RMP/EIS, and eliminates those issues that are not significant. The BLM’s Handbook H-1601-1 

Land Use Planning Handbook defines planning issues as “disputes or controversies about 

existing and potential land and resource allocations, levels of resource use, production, and 

related management practices.” 

Public scoping was designed to meet the public involvement requirements of FLPMA and 

NEPA. This cooperative process included soliciting input from interested state and local 

governments, tribal governments, other federal agencies and organizations, and individuals, to 

identify the scope of issues to be addressed in the plan and to assist in the formulation of 

reasonable alternatives. The scoping process was an excellent method for opening dialogue 

between the BLM and the general public about management of the public lands and for 

identifying the concerns of those who have an interest in the area. 

As part of the scoping process, the BLM also requested that the public submit nominations for 

potential areas of critical environmental concern (ACECs) and nominations of rivers for 

potential inclusion in the National Wild and Scenic Rivers System (NWSRS).

The scoping period for the Billings and Pompeys Pillar National Monument RMP began on 

May 15, 2008 with publication of the Notice of Intent (NOI) in the Federal Register, and ended 

on August 22, 2008. Scoping also included open-house meetings in seven communities 

(Pompeys Pillar National Monument, Billings, Bridger, Red Lodge, Big Timber, and Roundup, 

Montana, and Lovell, Wyoming). In addition, the BLM issued news releases to notify the 

public regarding the scoping period and the planning process and to invite the public to provide 

written comments. The Billings Field Office received written comments via email, fax, and 

regular mail. Comments obtained from the public during the scoping period were used to define 

the relevant issues that would be addressed by a reasonable range of alternatives.

For the Billings and Pompeys Pillar National Monument RMP/EIS planning process, scoping 

comments received were placed in one of three categories:

• Issues to be resolved in the RMP/EIS 

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• Issues addressed through other policy or administrative action (and therefore not 

addressed in the RMP/EIS)

• Issues eliminated from detailed analysis because they are beyond the scope of 

the RMP/EIS

Some important issues to be addressed in the RMP were identified by the public and other 

agencies during the scoping process. The Billings and Pompeys Pillar National Monument 

RMP/EIS Scoping Report (available for review on the RMP planning web page at 

http://on.doi.gov/1EJBdaE) summarizes the scoping process.

The issues identified in the Scoping Report fall into one of 10 broad categories. Other resource 

and use issues are identified in the BLM Planning Handbook (H-1601-1). All of these issues 

were considered in developing the alternatives brought forward in this RMP/EIS. 

1.4.1.1 Travel Management Planning 

Travel management and access is addressed at two levels in this document. Proposed travel 

management is described both at the land-use planning level (allocating open, closed, and 

limited area designations) as well as at the Field Office level (specific route designations) as 

part of the RMP decision to be made. In addition, there are eleven Travel Management Areas

(TMA) for which site-specific management by individual travel routes is proposed by 

alternative. Site-specific travel plan decisions for each of these eleven areas will be made 

separately from the RMP level decisions as implementation level decisions. 

Four public meetings were held over a one-week period in June 2009. These public meetings 

were held in the population centers nearest the eleven travel management areas: Lovell, 

Wyoming: Cottonwood and Pryor Mountain TMAs; Bridger, Montana: Cottonwood, Grove 

Creek, Warren, and Pryor Mountain TMAs; Roundup, Montana: Horsethief and Gage 

Dome/Colony Road TMAs; and Billings, Montana: Acton, Cottonwood, Grove Creek, Mill 

Creek/Bundy, Pryor Mountain, Shepherd Ah-Nei, South Hills, and Tin Can Hill TMAs. To 

advertise the meetings, BLM sent a newsletter to all people on its mailing list and advertised 

the meetings on its public website. In addition, BLM sent a press release to the appropriate 

newspapers, radio stations, and television stations announcing the meetings. 

The participants at the public meetings were asked to provide written comments on the 

proposals for consideration in the travel management process. Meeting participants reviewed 

maps and information related to the proposed eleven TMAs. (See Appendix O for Travel 

Management Route Designation Process and Implementation-Level Plans)

1.4.1.2 Issues to be Addressed in the Billings and Pompeys Pillar National 

Monument RMP/EIS 

Those planning issues determined to be within the scope of the EIS are used to develop one or 

more of the alternatives or are addressed in other parts of the EIS. For example, as planning 

issues were refined, the BLM collaborated with cooperating agencies to develop a reasonable 

range of alternatives designed to address and (or) resolve key planning issues, such as what 

areas, if any, contain unique or sensitive resources requiring special management. A reasonable 

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range of alternatives provides various scenarios for how the BLM and cooperating agencies can 

address this and other key planning issues, including the management of resources and resource 

uses in the decision area. In other words, key planning issues serve as the rationale for

alternative development. The key planning issues identified for developing alternatives in this 

EIS are listed below:

Issue 1: How can the public lands be managed to provide desired plant 

communities?

A healthy cover of perennial vegetation stabilizes the soil, increases infiltration of precipitation, 

reduces runoff, provides clean water to adjacent streams, and minimizes noxious weed 

invasion. Some resource uses (e.g., grazing, mineral development, OHV use, and recreation) 

can affect the natural function and condition of plant communities. Plant communities can also 

be altered and affected by fire, invasive species, and natural disasters (e.g., floods and drought). 

All factors mentioned that may affect rangeland, forest, and riparian vegetation will be 

addressed in the RMP. 

Issue 2: How can public lands be managed to maintain or improve wildlife and 

fisheries habitats and control invasive species?

Where public land ownership patterns are highly fragmented protection and/or improvement of 

fish and wildlife habitats is more challenging. The key to maintaining fish and wildlife habitats 

is diverse, healthy vegetation and plant communities and good water quality, stream channel, 

and riparian conditions. The RMP will identify the range (current and potential) of wildlife 

habitat as well as habitat conditions in the decision area. 

Issue 3: How can public lands be managed to conserve and recover threatened, 

endangered, proposed, and sensitive species, including Greater Sage-grouse? 

The majority of the animal species considered sensitive by Montana/Dakotas BLM are found in 

habitats within the planning area. Many of these species are associated with grassland and 

sagebrush habitats, and the decision area contains a portion of their global breeding range.

The RMP will identify reasonable strategies to conserve and recover special status species in 

the decision area in consultation with the U.S. Fish and Wildlife Service as required under the 

Endangered Species Act and Bureau Special Status Species policy. Special status species 

include species listed, proposed for listing, or candidate species under the Endangered Species 

Act and sensitive species identified by the BLM (Appendix H). 

In March 2010, the U.S. Fish and Wildlife Service (USFWS) determined that the greater sagegrouse warranted protection under the Endangered Species (ESA), but that listing the species 

was precluded by the need to address other, higher-priority species first (75 FR 13910, March 

23, 2010). One reason for the USFWS decision was an identified need for “improved 

regulatory mechanisms” to ensure species conservation. The principal regulatory mechanisms 

for BLM are Resource Management Plans (RMPs), therefore, the BLM is using this 

opportunity to develop long-term and effective management for the species on the BLM lands 

(WO IM 2012-044). 

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Issue 4: What public lands will be available for commercial activities and how will 

those activities be managed while protecting the integrity of other resources. 

A wide variety of commercial activities are conducted on BLM-managed lands in the planning 

area. Some of the primary uses are: oil and gas development, coal mining, livestock grazing, 

rights-of-way and land use authorizations, commercial recreation permits, locatable/saleable 

minerals, and forest product removal, and community wildfire protection plans. The potential 

for wind power development is also present. The RMP will identify areas available for 

commercial activities and how those activities will be managed to protect resource values. 

Issue 5: How should recreation activities be managed in response to public demand 

while protecting natural and cultural resource values and provide for visitor safety?

Recreation use in the decision area continues to increase. With this popularity has come a 

demand for a greater variety and availability of recreation opportunities such as motorized and 

non-motorized trails (including equestrian trails), climbing, mountain biking, hiking, and 

camping. With the number of visitors growing, resource and user conflicts are becoming more 

common. Recreational use needs to be managed, including identifying special recreation 

management areas (SRMAs) where management attention is needed to highlight important 

recreational opportunities or deal with problems such as conflicts between users or impacts on 

other resources. The RMP should assist the BLM in providing access to the public lands and to 

ensure quality environmentally responsible outdoor recreational opportunities, experiences, and 

benefits for the growing number of public land users. 

Issue 6: How will conflicts between motorized and non-motorized uses be resolved 

and how will effects to resources from motorized use be addressed? 

Use of the public lands in south central Montana (for recreation, commercial uses, and general 

enjoyment) has grown in popularity in recent years. With this popularity has come a demand 

for greater variety and availability of access opportunities, including off-highway vehicle 

(OHV) use. With the number of visitors growing, resource and user conflicts are becoming 

more common. Motorized use needs to be managed, including identifying areas to be restricted 

or closed for the protection of other resource values. 

Major considerations in alternative development and estimation of the effects for travel and 

access management in the RMP will include: public and administrative access needs, road 

densities, recreational activities, and resource values. 

Issue 7: What areas should be designated for special management (e.g., ACECs and 

Wild and Scenic Rivers) and how should these areas be managed?

FLPMA and BLM policy require the BLM to give priority to designation and protection of 

ACECs during the land use planning process. The Wild and Scenic River (WSR) Act directs 

federal agencies to consider the potential for including watercourses into the National Wild and 

Scenic Rivers System during the land use planning process. The alternatives analyzed in this 

RMP/EIS include a range of management prescriptions for managing the existing and potential 

ACECs, as well as for managing the eligible rivers as suitable WSRs. 

As part of the Billings and Pompeys Pillar National Monument RMP/EIS development, 

evaluations were conducted to address whether certain places in the decision area

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Proposed Resource Management Plan and Final Environmental Impact Statement

qualified/remained qualified for special designation to protect unique or significant values. 

Subject to valid existing rights, the RMP will avoid approval of proposed actions that could 

degrade the values of potential special designations. 

Issue 8: How will local social and economic conditions be addressed? 

Through this RMP/EIS, the BLM will identify how management of various resources and BLM 

authorized activities in the decision area will affect economic and social conditions. 

Issue 9: How will the cultural and historic values at Pompeys Pillar National 

Monument be protected? 

The cultural and historic values and associated viewshed at Pompeys Pillar NM (if it is within 

the decision area) will be preserved through management actions developed in this RMP for 

Pompeys Pillar National Monument. Pompeys Pillar National Monument (51 acres) was 

designated a national monument for the purpose of protecting ethnographic, historic, and 

archaeological values associated with Pompeys Pillar.

Issue 10: How will recreation and visitor services at Pompeys Pillar National 

Monument be managed? 

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. 

1.4.1.3 Issues Considered But Not Further Analyzed 

1.4.1.3.1 Master Leasing Plans 

During the preparation of the Billings and Pompeys Pillar National Monument RMP revision, 

the BLM issued Washington Office Instruction Memorandum (IM) 2010-117 which introduced 

the Master Leasing Plan (MLP) concept as part of the BLM Oil and Leasing Reform. The MLP 

process entails analyzing likely development scenarios and varying levels of protective design 

features and/or mitigation measures in a defined area with greater detail (i.e., at a finer scale) 

than a traditional RMP allocation analysis, but at a less site-specific level than a development 

plan that has been fully defined by an operator. While preparation of some MLPs may result in 

land use plan-level decisions, some may result in implementation-level decisions. 

No externally generated MLP proposals were received for the Billings Field Office. After an 

internal review by BLM staff, the need to address or consider an MLP within the Billings Field 

Office was determined not to meet the criteria. The following provides a brief overview of the 

findings of the review criteria. For a more detailed review of the MLP criteria and 

considerations, a full report can be reviewed at: 

http://www.blm.gov/style/medialib/blm/mt/blm_programs/energy/oil_and_gas/leasing/leasing_

reform.Par.58748.File.dat/MLPAssessments.pdf 

There is not a majority of federal mineral estate within the planning area (only 4% percent of 

the area is BLM federal mineral estate). In addition, there is not a substantial portion of the 

federal mineral estate that is currently leased (57 percent). The Billings Field Office is 

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considered to have mostly moderate to low occurrence potential based on the updated 

Reasonably Foreseeable Development (RFD) scenario prepared for the Proposed Billings and 

Pompeys Pillar National Monument RMP/EIS. There is scattered oil production throughout the 

southern portion of the area, as well as some production in the northeast corner of the area. This 

production is in older fields with all of the wells being drilled prior to 2000. Since the area only 

contains 4 percent federal mineral estate, and since there is no new discovery, an MLP analysis 

is not warranted at this time. 

Based on the reasons described above and the range of alternatives considered to address the 

planning issues and resource values identified, in relationship to oil and gas leasing and 

development, an MLP proposal is not analyzed further in this RMP. 

1.4.1.3.2 Non-Energy Leasable Minerals 

Non-energy leasable minerals, such as phosphate, sodium, potassium , sulphur, trona, or 

gilsonite are not present in the decision area. As non-energy leasables are not present, no 

allocations are made by alternative nor are they discussed or analyzed further in this document. 

1.4.1.4 Issues Addressed Through Policy or Administrative Action 

Policy or administrative actions include those actions that are implemented by the BLM 

because they are standard operating procedure, because federal law requires them, or because 

they are BLM policy. Administrative actions do not require a planning decision to implement. 

They are, therefore, issues that are eliminated from detailed analysis in this planning effort. The 

following issues can be addressed by policy or administrative actions:

• Compliance with existing laws and policies (e.g., FLPMA, NEPA, Endangered 

Species Act, American Antiquities Act, Clean Air Act, Clean Water Act, 

National Historic Preservation Act [NHPA], etc.).

• The allocation of forage between livestock and wildlife, and the application of 

specific management practices on allotments within the Billings Field Office is 

provided for through the application of Montana’s Standards for Rangeland 

Health, Guidelines for Livestock Grazing Management, and supporting 

monitoring data. When monitoring and inventory data indicate a need, changes 

to the allocation of forage for livestock and wildlife are made after coordination 

with permittees, the Montana Fish, Wildlife, and Parks, and other affected 

interests in order to assure that resource objectives are met. Livestock grazing 

management practices may also be adjusted to assure that grazing practices are 

compatible with other uses of the public lands. These allocation and 

management adjustments are implementation decisions according to the BLM’s 

Land Use Planning Handbook (H-1601-1), and are done on an allotment or other 

site-specific basis.

• Education, enforcement/prosecution, vandalism, and volunteer coordination. 

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Proposed Resource Management Plan and Final Environmental Impact Statement

• Assist in resolving, to the extent possible, inconsistencies between federal and 

non-federal agency plans, and to be consistent with state and local plans to the 

maximum extent, consistent with federal law and the purposes of FLPMA. 

• Management of cultural resources, which includes up-to-date inventories, nondisclosure of sensitive sites, proposal of cultural sites for the National Register 

of Historic Places (NRHP), and Native American consultation.

• Management of the Billings Field Office’s four existing WSAs (approximately

28,631 acres) follows BLM Manual 6330 – Management of BLM Wilderness 

Study Areas until such time as Congress acts upon the recommendations. The 

BLM is statutorily required under 43 U.S.C. 1782(c) to manage these areas to 

protect their suitability for Congressional designation into the National 

Wilderness Preservation System unless and until Congress either designates an 

area as wilderness or releases it from further consideration. The BLM’s 

discretion to make planning decisions on management of WSAs is limited to 

designating WSAs as visual resource management (VRM) Class I and 

determining if the WSAs will be limited or closed to OHV use.

• Completion of inventory of riparian and wetland areas and the use of monitoring 

and mitigation to help protect these resources. 

• Recreation management improvements, including a comprehensive sign system 

and maps. 

• Administration of existing mineral leases, permits, and other authorized uses.

• Administration of valid existing rights.

• Monitoring wildlife and biodiversity. 

• Monitoring air quality. 

• Mitigation measures for site-specific projects.

• Noxious weed control. 

• Eligibility standards for specially designated areas.

• Protection of threatened, endangered, or sensitive species. 

• Coordination with local, state, and federal agencies.

• Cooperation with user groups. 

1.4.1.5 Issues beyond the Scope of the RMP 

Issues beyond the scope of the RMP process include all issues not related to decisions that 

would occur as a result of the planning process. They include decisions that are not under the 

jurisdiction of the Billings Field Office or are beyond the capability of the BLM to resolve as 

part of the planning process. Issues identified in this category include: 

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• Settlement of RS 2477 claims. The State of Montana and the Counties of Big 

Horn, Carbon, Golden Valley, Musselshell, Stillwater, Sweet Grass, Wheatland, 

and Yellowstone and the State of Wyoming and Big Horn County may hold 

valid existing highway rights-of-way across public lands in the planning area 

pursuant to Revised Statute (RS) 2477, Act of July 26, 1866, chapter 262, § 8, 

14 Stat. 251, 253, codified at 43 USC § 932. This RMP does not adjudicate, 

analyze, or otherwise determine the validity of claimed RS 2477 rights-of-way. 

Nothing in this RMP extinguishes any valid right-of-way, or alters in any way 

the legal rights the State of Montana and the Counties of Big Horn, Carbon, 

Golden Valley, Musselshell, Stillwater, Sweet Grass, Wheatland, and 

Yellowstone and the State of Wyoming and Big Horn County have to assert and 

protect RS 2477 rights, and to challenge in federal court or other appropriate 

venue any use restrictions imposed by the RMP that they believe are 

inconsistent with their rights. If a claimed right-of-way is recognized by the 

BLM through an administrative determination, or a right-of-way is determined 

to be valid by a court of law, any use restriction imposed by this RMP shall no 

longer apply to it. 

• New proposals for WSAs or wilderness. Any individual, organization, or agency 

can submit potential wilderness designation lands to Congress for designation. 

Only Congress can designate WSAs, established under Section 603 of FLPMA, 

as wilderness or release WSAs for other uses. 

• Expansion of the Pryor Mountain Wild Horse Range beyond the Herd Area. 

Wild horses can only be managed on areas of public lands where they were 

known to exist in 1971, at the time of the passage of the Wild Free-Roaming 

Horses and Burros Act (herd areas and territories). Under section 1339 

“Limitation of Authority” the Wild Free-Roaming Horses and Burros Act of 

1971 states “Nothing in this Act shall be construed to authorize the Secretary to 

relocate wild free-roaming horses or burros to areas of the public lands where 

they do not presently exist”. Until a change in the law allows for expansion of 

the Pryor Mountain Wild Horse Range onto additional Forest Service and BLM 

lands that are outside of the Herd Area and Territory, the agencies have a legal 

obligation to follow the law to the greatest extent possible. Horses were in the 

Pryor Mountains historically, but by 1968 they were largely limited to the 1968 

designated range due to the Forest Service/BLM boundary fence. Though there 

is much supposition as to the extent of wild horses in 1971, comprehensive 

agency inventories, assessments, and public involvement (Hall, 1972 and 

BLM/USFS, 1974) provided the basis for Herd Area and Territory boundaries 

per the 1971 Act. Subsequent land use planning efforts in 1984 (BLM) and 1987 

(USFS) validated the same areas as being wild horse herd management area and 

territory, respectively. 

• Activities and uses beyond the jurisdiction of the BLM. 

• Changing existing laws, policies, and regulations. 

• Availability of funding and personnel for managing programs. 

Chapter 1: Purpose and Need for Action 1-23
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Proposed Resource Management Plan and Final Environmental Impact Statement

1.4.2 Planning Criteria

BLM planning regulations (43 CFR 1610) require the preparation of planning criteria as 

preliminary to the development of all RMPs. Planning criteria are the standards, rules, and 

guidelines that help to guide the planning process. These criteria influence all aspects of the 

planning process, including inventory and data collection, developing issues to address, 

formulating alternatives, estimating impacts, and selecting the Preferred Alternative. In 

conjunction with the planning issues, planning criteria ensure that the planning process is 

focused and incorporates appropriate analyses. Planning criteria are developed from 

appropriate laws, regulations, and policies as well as from public participation and coordination 

with cooperating agencies, other federal agencies, state and local governments, and American 

Indian tribes. 

Planning criteria used in the development of this RMP are: 

• The RMP will recognize the existence of valid existing rights

• The RMP will comply with applicable laws, regulations, executive orders, and 

BLM supplemental program guidance 

• Planning decisions will cover BLM-administered public lands, including splitestate lands where the federal government has retained the sub-surface mineral 

estate

• Planning decisions will use and observe the principles of multiple use and 

sustained yield set forth in FLPMA and other applicable law (43 United States 

Code [USC] 1701 (c)(1)) 

• The BLM will use a systematic interdisciplinary approach to achieve integrated 

consideration of physical, biological, economic, and other sciences (43 USC 

1701 (c)(2))

• Areas potentially suitable for ACEC or other special designations will be 

identified and, where appropriate, brought forward for analysis in the EIS (43 

USC 1701 (c)(3)) 

• The BLM will rely, to the extent it is available, on the inventory of public lands, 

their resources, and other values (43 USC 1701 (c)(4)) 

• The BLM will consider present and potential uses of the public lands (43 USC 

1701 (c)(5))

• The BLM will consider the relative scarcity of the values involved and the 

availability of alternative means (including recycling) and sites for the 

realization of those values (43 USC 1701 (c)(6))

• The BLM will consider the relationship between short-term uses of the human

environment and the maintenance and enhancement of long-term productivity

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• Decisions in the RMP will comply with applicable pollution control laws, 

including state and Federal air, water, noise, or other pollution standards or 

implementation plans (43 USC 1701 (c) (8))

• To the extent consistent with the laws governing the administration of the public 

lands (FLPMA 202 b(9)), BLM will be consistent with existing officially 

approved or adopted resource plans, policies, or programs of other federal 

agencies, state agencies, American Indian tribes, and local governments that 

may be affected (43 CFR 1610.3-1 (c) (9))

• The National Greater Sage-Grouse Habitat Conservation Strategy (BLM 2004a) 

requires that impacts to sagebrush habitat and sagebrush-dependent wildlife 

species (including greater sage-grouse) be analyzed and considered in BLM land 

use planning efforts for the public lands with sage-grouse/sagebrush habitats. 

• The BLM will utilize the Western Association of Fish and Wildlife Agencies 

(WAFWA) Conservation Assessment of Greater Sage-Grouse and Sagebrush 

Habitats (Connelly, et al. 2004), and any other appropriate resources, to identify 

greater sage-grouse habitat requirements and best management practices.

1.4.3 Land Use Planning Decision Levels 

The BLM planning process has been organized into different decision levels that progress from 

the very general to the very specific. Such organization is called a step-down process, which is 

presented below. Decisions at each step build on the previous steps so that in the end, specific 

management actions are consistent with the overall BLM mission. Not all steps are the subject 

of the Billings and Pompeys Pillar National Monument RMP/EIS. The higher-level steps for 

national, state, and Field Office –wide decisions previously have been established. Annotations 

in the following outline identify where in the document each step in the outline is presented. 

• Planning Criteria – Section 1.4.2 

• Scoping Issues – Section 1.4.1.2 

• Goals and Objectives for each Resource Program – Section 2.6 

• Management Actions for each Resource Program – Section 2.6 

1.4.3.1 Types of Decisions 

The BLM administers programs to manage public resources at the national, state, and local 

levels. BLM management of public lands is based on a network of decisions made at each of 

the administration levels. There are two general types of decisions contained in the RMP/EIS; 

land use plan and implementation. Both are subject to the requirements of NEPA. 

Land use plan decisions provide general guidance for future site-specific management activities 

within a defined framework. 

Implementation decisions are characterized by having project or activity level detail, a narrow 

focus, and actions specific to a unique location during a specified time period. 

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1.4.3.1.1 Land Use Plan Decisions

This RMP provides general management guidance for management actions. These actions 

conform to national laws, agency policies, and BLM-wide or statewide plans that are currently 

approved. 

Travel management and access is addressed at two levels in this document: (1) RMP level 

decisions, such as identification of Travel Management Areas (TMA) and the designation of 

areas as ‘open,’ ‘closed,’ or ‘limited’ to motorized vehicle use; and (2) site-specific motorized 

travel route designations within TMAs which are implementation-level decisions. 

The Billings and Pompeys Pillar National Monument RMP addresses a range of alternatives for 

establishing Travel Management Areas. Specific management objectives were defined for each 

TMA, consistent with the overall desired outcomes for travel management. Within these 

TMAs, a range of alternatives to address route-specific designations were proposed by 

alternative, and addressed in this document. However these route-specific designations would 

be implementation-level decisions. Upon finalization of the RMP, the decision for each of the 

TMAs will be considered to be separate decisions. Travel management outside of the 11 TMAs 

would continue to be limited to existing roads and trails and in accordance with the RMP 

Record of Decision (ROD). 

1.4.3.1.2 Implementation Level Decisions

Actions that need a level of analysis beyond that contained in the RMP/EIS would undergo 

their own NEPA review before they could be implemented. These actions would be in 

conformance with the Approved RMP and would be tiered to the NEPA analysis contained in 

the Proposed RMP/Final EIS. As per BLM Handbook H-8342-1 and Travel and Transportation 

Manual 1626 Section 1626, site specific analyses would be conducted for each of the eleven 

Travel Management Plans. 

1.5 Consistency with Other Programs, Plans, and Policies

According to one of the regulations implementing FLPMA (43 CFR 1610), BLM RMPs and 

amendments must be consistent, to the extent practical, with officially approved or adopted 

resource-related plans of other federal, state, local and tribal governments so long as the 

guidance and RMPs are also consistent. The BLM RMPs must also be consistent with the 

purposes, policies, and programs of FLPMA and other federal laws and regulations related to 

public lands, including federal and state pollution control laws (see 43 CFR 1610.3-2 [a]). If 

these other entities do not have officially approved or adopted resource-related plans, then the 

BLM RMPs must, to the extent practical, be consistent with those entities’ officially approved 

and adopted resource-related policies and programs. This consistency will be accomplished 

through incorporating the policies, programs, and provisions of public land laws and 

regulations and federal and state pollution control laws (see 43 CFR 1610.3-2 [b]).

Before the BLM state director approves RMP decisions, the Montana governor has 60 days to 

identify inconsistencies between the proposed plan and state plans and programs and to provide 

written comments to the BLM state director. The BLM and the state may mutually agree on a 

shorter review period. If the governor does not respond within this period, it is assumed that the 

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Proposed Resource Management Plan and Final Environmental Impact Statement

proposed RMP decisions are consistent. If the governor recommends changes in the proposed 

plan or amendment that were not raised during the public participation process, the state 

director shall provide the public with an opportunity to comment on the recommendations (see 

43 CFR 1610.3-2 [e]). This public comment opportunity will be offered for 30 days and may 

coincide with the 30-day comment period for the notice of significant change. If the state 

director does not accept the governor’s recommendations, the governor has 30 days to appeal in 

writing to the BLM director (see 43 CFR 1610.3-2[e]).

Plans formulated by federal, state, local, and tribal governments that relate to management of 

lands and resources have been reviewed for consistency as the Billings and Pompeys Pillar

National Monument RMP/EIS has been developed. 

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 officially-approved 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 officially-approved state and local plans or policies and programs conflict with the 

purposes, policies, and programs of federal law applicable to public lands, there will be an 

inconsistency that cannot be resolved. With respect to officially-approved state and local 

policies and programs (as opposed to plans), this consistency provision only applies to the 

maximum extent practical. 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 state or county plans, planning processes, policies, or planning 

stipulations.

1.5.1 County Plans 

The planning area encompasses approximately 434,154 BLM-administered surface acres 

located in portions of Big Horn, County, Montana, and all of Carbon, Golden, Musselshell, 

Stillwater, Sweet Grass, Wheatland and Yellowstone counties. Additionally, there are about 

4,298 acres administered by the Billings Field Office in Big Horn County, Wyoming. There are 

also approximately 889,497 subsurface acres of mineral estate administered by the Billings 

Field Office in the planning area.

The BLM completed a consistency review of existing county Land Use Plans (LUP). The 

following county plans or growth plans/policies that were reviewed in either draft or final form 

at the time this report was being prepared include: 

• Carbon County Montana Growth Policy (2003) 

• Red Lodge Growth Policy (2008)

• Park County (1998) 

• Cody Comprehensive Plan (1997) 

• Stillwater County Growth Policy (2007) 

• Columbus Area Growth Policy (2005) 

Chapter 1: Purpose and Need for Action 1-27
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Proposed Resource Management Plan and Final Environmental Impact Statement

• Sweet Grass County Growth Policy (2008) 

• Big Timber Growth Policy (2008) 

• Big Horn County, Wyoming, Community Assessment 

• Yellowstone County Growth Policy – combined with Billings (Draft 2008) 

• Laurel Growth Management Plan (2004) 

Other community assessments and plans were reviewed to capture local/regional concerns and 

for consistency purposes, including the Yellowstone Business Partnership Seasonality Project 

(Billings-Cody subregion). County wildfire protection plans that address hazardous fuels and 

fire suppression were also reviewed and are consistent with the BLM local and national fire 

plans. 

1.5.2 State Plans 

A number of planning documents, strategies, or policies that guide management activities affect 

public lands. Many of the plans directly impact or otherwise affect BLM-administered public 

lands, agreements, or other partnership involvement opportunities. In addition to BLM’s 

cooperating agency relationship with several state agencies (see Cooperating Agencies section 

below), ongoing coordination and communication will take place to ensure consistency, as 

appropriate. A list of state plans most pertinent to the decision area is below. BLM resource 

specialists reviewed many of these plans and determined that to the extent possible, they are 

consistent with current management of BLM public lands. 

• Air Pollution State Implementation Plan (MT Department of Environmental 

Quality [MTDEQ]) 

• Montana’s Comprehensive Fish and Wildlife Conservation Strategy Statewide 

Habitat Plan (MT Fish, Wildlife, and Parks [MTFWP], 1994) 

• Management plan and conservation strategies for greater sage-grouse in 

Montana (MT Greater Sage-Grouse Working Group, 2004) 

• Montana Statewide Elk Management Plan (2004) 

• Conservation Plan for Black-tailed and White-tailed Prairie Dogs in Montana 

(MT Prairie Dog Working Group, 2002) 

• Montana Bald Eagle Management Plan. 2nd ed. (MT Bald Eagle Working 

Group, 1994) 

• Montana Gray Wolf Conservation and Management Plan (MTFWP, 2003) 

• Conservation Plan for Grizzly Bear in Montana (MTFWP, 2001) 

• Montana Fish, Wildlife & Parks Endangered Wildlife Program 

• Memorandum of Understanding and Conservation Agreement for West slope 

Cutthroat Trout and Yellowstone Cutthroat Trout in Montana (MTFWP, 2007) 

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Proposed Resource Management Plan and Final Environmental Impact Statement

• Management of Mountain Lions in Montana (MTFWP, 1996) 

• Montana Nonpoint Source Management Plan (MTDEQ 2007) 

• Montana Tourism and Recreation Strategic Plan (2008) 

• The Montana Weed Management Plan (Montana Noxious Weed Summit 

Advisory Council Weed Management Task Force, May 2008) 

• The Montana Weed Management Plan (Duncan 2005) 

• Boulder River Watershed Total Maximum Daily Loads (MDEQ 2009) 

• Salinity TMDL for Sage Creek, Montana (MDEQ 2002) 

• Lower Musselshell TMDL Planning Area Decision Document (MDEQ 2001) 

• The Governor of the State of Montana issued Executive Order 10-2014 which 

created the Montana Sage Grouse Oversight Team (MSGOT) and the Montana 

Sage Grouse Habitat Conservation Program. The executive order outlines a 

number of conservation strategies for state agencies to follow for land uses and 

activities in sage-grouse habitat in addition to establishing the MSGOT and 

habitat conservation program. The State conservation efforts are complimentary 

to the conservation measures proposed in the BLM land use plans and when 

combined will provide conservation efforts across land ownership boundaries. 

1.5.3 Other Federal Agency Plans 

• Custer National Forest Land and Resource Management Plan (Forest Plan), 

Final Environmental Impact Statement (FEIS), and Record of Decision (ROD) 

(1987), as amended 

• Gallatin National Forest Land and Resource Management Plan (Forest Plan), 

Final Environmental Impact Statement (FEIS), and Record of Decision (ROD) 

(1987), as amended

• U.S. Army Corps of Engineers – Yellowstone River Corridor Comprehensive 

Study http://nris.mt.gov/yellowstone 

• Crow Indian Reservation Natural, Socio-Economic and Cultural Resources 

Assessment and Conditions Report (2002) 

http://www.deq.mt.gov/CoalBedMethane/FinalEIS/CrowNarrative.pdf 

• Northern Cheyenne Tribe and Its Reservation (2002) 

• U.S. Department of Interior National Park Service, Lewis and Clark National 

Historic Trail Comprehensive Plan for Management and Use (1982) 

http://www.nps.gov/lecl/parkmgmt/index.htm 

Chapter 1: Purpose and Need for Action 1-29
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

• U.S. Department of Agriculture Forest Service, Nez Perce National Historic 

Trail Comprehensive Management Plan (1990) 

http://www.fs.usda.gov/main/npnht/landmanagement 

1.5.4 Other Related Plans 

FLPMA requires that the BLM, when developing or revising land use plans, shall— 

...to the extent consistent with the laws governing the administration of the 

public lands, coordinate the land use inventory, planning, and management of 

activities of or for such lands with the land use planning and management 

programs of other Federal departments and agencies and of the States and local 

governments within which the lands are located...and assure that consideration 

is given to those State, local and tribal land use plans for public lands [and] 

assist in resolving, to the extent practical, inconsistencies between Federal and 

non-Federal Government plans...(43 U.S.C. S 1712 (c) (9))

The BLM must keep apprised of the many ongoing programs, plans, and policies that are being 

implemented in the planning area by other federal, state, local, and tribal governments. The 

BLM will seek to be consistent with or complementary to other management actions whenever 

possible. 

A number of plans have been developed by the BLM that relate to or otherwise govern 

management in the decision area. Some of these plans amended the Billings RMP while others, 

though they have not been formally adopted through the land use planning process, are 

considered by BLM when implementation level planning is conducted or other specific actions 

are analyzed. These major plans and other major management guidance are listed below and 

provide a perspective of the many management considerations pertinent to the Decision Area. 

1.5.4.1 Land Use Plans and Amendments 

• Billings Resource Management Plan (1984) 

• Wilderness EIS for the Billings Resource Area (1988) 

• Pryor Mountain Herd Management Area Plan (activity plan and amendment) 

(1992) 

• Miles City District Oil and Gas RMP Amendment/EIS (1994) 

• Pompeys Pillar Environmental Assessment/Amendment (1996) 

• Standards for Rangeland Health and Guidelines for Livestock Grazing for 

Montana, North Dakota, and South Dakota Record of Decision (USDI-BLM 

1997) 

• Areas of Critical Environmental Concern Environmental Assessment and 

Amendment of the Billings, Powder River, and South Dakota RMPs (1999) 

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Proposed Resource Management Plan and Final Environmental Impact Statement

• Pompeys Pillar Interpretative Center Environmental Assessment and 

Amendment (2002) 

• Sundance Lodge and Four Dances Environmental Assessment/Amendment 

(2002) 

• Off-Highway Vehicle Record of Decision and Plan Amendment for Montana, 

North Dakota, and Portions of South Dakota (USDI-BLM 2003) 

• Fire/Fuels Management Plan Environmental Assessment/Plan Amendment for 

Montana and the Dakotas (USDI-BLM 2003) 

• Montana Final Statewide Oil and Gas EIS and Amendment for Powder River 

and Billings RMPs (2003) 

• Supplement to the Montana Statewide Oil and Gas EIS and Amendment of the 

Powder River and Billings RMPs (2008) 

1.5.4.2 Other National, Statewide, and Field Office Plans 

• Vegetation Treatment on BLM Lands in Thirteen Western States (USDI-BLM 

1991) 

• Amendment for Wind Energy Development for BLM Lands in the Western 

United States (2005) 

• Climate Change Supplementary Information Report: Montana, North Dakota, 

and South Dakota Bureau of Land Management (2010) 

• Vegetation Treatments Using Herbicides on BLM Lands in Seventeen Western 

States (USDI-BLM 2007) 

• Geothermal Leasing in the Western United States Final EIS (2008)

• Montana Statewide Wilderness Study Report (USDI-BLM 1991) 

• National Fire Plan and 2001 Federal Fire Policy 

• Draft National BLM Sage Grouse Habitat Conservation Strategy (USDI-BLM 

2003) 

• Interim Bull Trout Habitat Conservation Strategy and Implementation (USDIBLM 1996) 

• BLM Butte Resource Management Plan and Environmental Impact Statement 

and Record of Decision (2009) 

http://www.blm.gov/mt/st/en/fo/butte_field_office/rmp/rod.html 

• BLM Miles City RMP/EIS revision (2015) 

http://www.blm.gov/mt/st/en/fo/miles_city_field_office/rmp.html 

Chapter 1: Purpose and Need for Action 1-31
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Proposed Resource Management Plan and Final Environmental Impact Statement

• BLM HiLine RMP/EIS revision (2015) 

http://www.blm.gov/mt/st/en/fo/malta_field_office/rmp.html 

• BLM Lewistown RMP/EIS amendment (2015) 

https://www.blm.gov/epl-frontoffice/eplanning/planAndProjectSite.do?methodName=renderDefaultPlanOrProjectSite

&projectId=36877&dctmId=0b0003e8805c9d29 

• BLM South Dakota RMP/EIS revision (2015) 

http://www.blm.gov/mt/st/en/fo/south_dakota_field/rmp.html 

• BLM North Dakota RMP amendment (2015) 

https://www.blm.gov/epl-frontoffice/eplanning/planAndProjectSite.do?methodName=renderDefaultPlanOrProjectSite

&projectId=36811&dctmId=0b0003e8805be23a 

• BLM Bighorn Basin RMP/EIS revision (2015) 

http://www.blm.gov/wy/st/en/programs/Planning/rmps/bighorn/docs.html 

1.5.4.3 Related Plans and Policies 

• Canada Lynx Conservation Assessment and Strategy (Ruediger et al. 2000) 

• Montana Bald Eagle Management Plan (USBOR 1994) 

• Pacific Bald Eagle Recovery Plan (USFWS 1986)

• National Sage-Grouse Habitat Conservation Strategy (BLM 2004a) 

• Management Plan and Conservation Strategies for Sage-Grouse in Montana – 

Final. The Management Plan and Conservation Strategies for Sage-Grouse in 

Montana (MSGWG 2005) is designed to provide biological information, 

identify information gaps, and facilitate data collection required for future 

resource management decisions. It establishes a process to achieve sage-grouse 

management objectives and provides a framework to guide local management 

efforts. Regional or local groups will adapt the statewide plan to develop and 

implement strategies in respective geographic areas that will improve or 

maintain the sagebrush steppe and reduce or mitigate factors that may further 

reduce habitats or populations. 

• While energy development has been identified as the primary threat to the 

greater sage-grouse within its eastern range, this area is not immune to the threat 

of wildfire. Within the Rocky Mountain Region wildfire was identified by the 

Conservation Objectives Team Final Report (2013) as a present and widespread 

threat in seven of thirteen priority areas of conservation (PACs) and as a present 

but localized threat in the remaining PACs. While fire is a naturally occurring 

disturbance in the sagebrush steppe, the incursion of non-native annual grasses 

is facilitating an increase in mean fire frequency which can preclude the 

opportunity for sagebrush to become re-established. As such the RMP includes 

requirements (referred to as Greater Sage-grouse Wildfire and Invasive Species 

Habitat Assessment in appendices in Draft documents) that landscape scale Fire 

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Proposed Resource Management Plan and Final Environmental Impact Statement

and Invasives Assessments be completed and updated regularly to more 

accurately define specific areas to be treated to address threats to sagebrush 

steppe habitat. Within the Rocky Mountain region, assessments have not yet 

been completed but will be scheduled based on the need to identify and address 

potential threats. Additionally, the Secretary of Interior issued Secretarial Order 

3336 on January 5, 2015 which establishes the protection, conservation and 

restoration of “the health of the sagebrush-steppe ecosystem and, in particular, 

greater sage-grouse habitat, while maintaining safe and efficient operations as a 

critical fire management priority for the Department”. The Secretarial Order 

will result in a final report of activities to be implemented prior to the 2016 

Western fire season. This will include prioritization and allocation of fire 

resources and the integration of emerging science, enhancing existing tools to 

implement the Resource Management Plan and improve our ability to protect 

sagebrush-steppe from damaging wildfires.

• Memorandum of Understanding Among the US Department of Agriculture, US 

Department of the Interior, and US Environmental Protection Agency, 

Regarding Air Quality Analyses and Mitigation for Federal Oil and Gas 

Decisions through the National Environmental Policy Act Process (2011). 

1.6 Consultation and Coordination

This section describes specific actions taken by the BLM to consult and coordinate with 

American Indian tribes, government agencies, and interest groups, and to involve the interested 

public during preparation of the RMP/EIS. 

A Notice of Intent (NOI) published in the Federal Register (FR) on May 15, 2008 formally 

announced the intent of the BLM to revise the existing plans and prepare the associated EIS.

Publication of the NOI initiated the scoping process and invited participation of affected and 

interested agencies, organizations, and the general public in determining the scope and issues to 

be addressed by alternatives and analyzed in the EIS. Additional detail regarding actions taken 

by the BLM to involve the public and consult and coordinate with American Indian tribes, 

government agencies, and interest groups is provided in Chapter 5. 

1.6.1 Consultation with American Indian Tribes 

Consultation with American Indian tribes is part of the NEPA scoping process and a 

requirement of FLPMA. RMPs must address consistency with tribal plans and protection of 

treaty rights and must observe specific planning coordination authorities, including complying 

with relevant portions of the National Historic Preservation Act, American Indian Religious 

Freedom Act, Executive Order 13007 (Indian Sacred Sites), and Executive Order 12898 

(Environmental Justice). In developing the Billings and Pompeys Pillar National Monument 

RMP/EIS, BLM representatives offered to meet with representatives of sixteen American 

Indian tribes to inform them of the planning process and solicit information on potential issues 

and concerns. None of the tribes responded to the offers. These same tribes were also invited to 

become cooperating agencies on the Billings and Pompeys Pillar National Monument

Chapter 1: Purpose and Need for Action 1-33
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Proposed Resource Management Plan and Final Environmental Impact Statement

RMP/EIS. The Northern Cheyenne tribe became a cooperating agency. Tribal consultation is 

still ongoing. American Indian tribes and organizations invited to become cooperating agencies

to date include: 

• Arapahoe

• Assiniboine and Gros Ventre (Ft. Belknap)

• Assiniboine and Sioux (Ft. Peck) 

• Blackfeet

• Chippewa Cree (Rocky Boy)

• Crow

• Lower Brule

• Northern Cheyenne 

• Oglala Sioux 

• Rosebud Sioux 

• Standing Rock Sioux 

• Three Affiliated Tribes (Mandan, Hidatsa, and Arikara Nations) 

• Turtle Mountain Band of Chippewa 

A more detailed discussion of consultation with American Indian tribes can be found in 

Chapter 5 of this RMP/EIS.

1.6.2 Cooperating Agencies 

CEQ requirements contained in 40 CFR 1501.6 and 1508.5 implement the NEPA mandate that 

federal agencies responsible for preparing NEPA analysis and documentation do so “in 

cooperation with state and local governments” and other agencies with jurisdiction by law or 

special expertise (42 USC 4331(a), 4332(2)). In support of this mandate, the BLM invited local, 

county, state, and tribal agencies to participate as cooperating agencies in the development of 

the Billings and Pompeys Pillar National Monument RMP/EIS. Cooperating agency status 

offers the opportunity for interested agencies to assume additional roles and responsibilities 

beyond the collaborative planning processes of attending public meetings and reviewing and 

commenting on plan documents. Fifteen agencies accepted the invitations to become formal 

cooperating agencies in developing the RMP and signed cooperating agency agreements: 

• Big Horn County, Wyoming 

• Bureau of Indian Affairs 

• Bureau of Reclamation

• Carbon County, Montana 

• Department of Natural Resources and Conservation Northeastern Land Office 

• Department of Natural Resources and Conservation Southern Land Office 

• Golden Valley County, Montana 

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Proposed Resource Management Plan and Final Environmental Impact Statement

• Montana Association of Conservation Districts 

• Montana Fish, Wildlife, and Parks 

• Montana State Historic Preservation Office 

• Musselshell County, Montana 

• Musselshell Planning Project 

• Northern Cheyenne Tribe 

• Wheatland County, Montana 

• Yellowstone County, Montana 

Other state and federal agencies, participated as part of the review process, but were not formal 

cooperating agencies: Wyoming Fish and Game Department, Wyoming State Historic 

Preservation Office, NPS Bighorn Canyon NRA, USFS Custer National Forest, and U.S. Fish 

and Wildlife Service (USFWS). 

1.6.3 Consultation with USFWS 

The Endangered Species Act (ESA) directs all Federal agencies to work to conserve 

endangered and threatened species and to use their authorities to further the purposes of the 

Act. Section 7 of the Act, called “Interagency Cooperation,” is the mechanism by which 

Federal agencies ensure the actions they take, including those they fund or authorize, do not 

jeopardize the existence of any listed species.

In 2008, the BLM and USFWS signed and implemented a Consultation Agreement for the 

RMP revision for the Billings Field Office (BLM and USFWS 2008). That document defined 

the respective roles and responsibilities of the two agencies and addressed the Section 7 

consultation process to be followed for listed, proposed, or candidate species and their habitat 

located within the respective planning areas. As part of the implementation of this agreement, 

the Billings Field Office has consulted with USFWS throughout development of the RMP/EIS. 

The Billings Field Office will continue consultation with the USFWS through completion of 

the final biological assessment (BA) and Proposed RMP/Final EIS. 

The BLM sent a letter to the USFWS concerning Section 7 consultation, presenting the 

approach for consultation, including the process of Programmatic Species-Specific Section 7 

consultations on Montana BLM RMPs. The USFWS provided a species list to the Billings 

Field Office for evaluating BLM Section 7 responsibilities. A draft biological assessment 

analyzing potential impacts to these species has been prepared and informally submitted to the 

USFWS for comment. The BLM has incorporated into the RMP/EIS a list of species-specific 

conservation measures common to all alternatives that will serve to provide management 

direction for habitat of listed species (Appendix H). These measures were developed as a result 

of a statewide programmatic Section 7 consultation effort on existing land use plans. 

Section 7 consultation has previously occurred for the oil and gas lease sale program within the 

Billings Field Office. A set of lease notices, developed as part of that consultation, have been 

incorporated into this RMP/EIS, as standard requirements common to all alternatives (see 

Appendix B).

Chapter 1: Purpose and Need for Action 1-35
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Proposed Resource Management Plan and Final Environmental Impact Statement

Formal Section 7 consultation will proceed with the BLM’s submission of a final biological 

assessment prepared for the Proposed RMP/Final EIS. The USFWS will respond with a 

biological opinion that will be included in the administrative record. The BLM will consider 

application of all measures suggested by the USFWS.

1.7 Policy

No proclamations or legislative designations that would influence decisions or constrain the 

alternatives have been issued within the decision area. 

Implementing the RMP begins when the Montana BLM State Director signs the ROD for the 

RMP. Implementation of the decisions in the RMP would be tied to the BLM budgeting 

process. An implementation schedule would be developed, providing for the systematic 

accomplishment of decisions in the approved RMP. 

1-36 Chapter 1: Purpose and Need for Action
CHAPTER 2:

RESOURCE 

MANAGEMENT 

ALTERNATIVES

CHAPTER 2:

RESOURCE 

MANAGEMENT 

ALTERNATIVES

Pompeys Pillar 

National 

Monument
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-1 

2 Description of Alternatives

2.1 Introduction 

Chapter 2 begins with material describing the development of alternatives and then moves to 

the presentation of the management actions for resources, resource uses, and resource 

management programs. Information is presented in the same sequence in Chapters 3 and 4 for 

each of the topic areas. Several of the categories contain subsections that focus on particular 

aspects of a resource program. 

This chapter contains alternatives that describe different approaches to the management of 

public lands and resources in the planning area. Each alternative represents a complete and 

reasonable set of goals and management actions to guide future management of BLMadministered public lands and resources in the planning area. 

This chapter describes and compares four alternatives for managing BLM-administered lands 

and their resources within the Billings Field Office (BiFO) and Pompeys Pillar National 

Monument (PPNM). These alternatives are identified as Alternative A, Alternative B, 

Alternative C, and Alternative D (Proposed). The No Action Alternative (Alternative A) 

represents the continuation of current management direction and proposes no new plan or 

management actions. This alternative is required by Council on Environmental Quality 

regulations and provides a baseline for comparison of the other alternatives (Council on 

Environmental Quality 1981). The BLM Billings Field Office developed the action alternatives 

(B, C, and D) by considering issues and concerns raised during the public scoping period and 

through planning criteria and guidance applicable to management of resources and resource 

uses. The three action alternatives (B, C, and D) describe proposed changes to current 

management as well as the existing management that would be carried forward into future 

management. The alternatives constitute a range of management actions that set forth different 

priorities and measures to emphasize certain uses or resource values under the multiple use 

sustained yield mandate to achieve the identified desired outcomes (goals and objectives) for 

each resource. These alternatives provide a range of choices for resolving the planning issues 

identified in Chapter 1.0. 

Evaluation of a reasonable range of alternatives is required by the National Environmental 

Policy Act (NEPA) and the Council on Environmental Quality (CEQ) regulations (40 Code of 

Federal Regulations (CFR) Part 1502.14), as well as by BLM planning regulations. As required 

in the CEQ regulations, the reasonable range must include a “no action” alternative (CEQ 1981, 

Question 3.A) which is the continuation of current management under the Billings Resource 

Area Resource Management Plan (RMP) and Record of Decision (ROD) (1984), as amended. 

The BLM Billings Field Office recognizes that social, economic, and environmental issues 

cross land ownership jurisdictions and that extensive cooperation is needed to actively address 

issues of mutual concern. To the extent possible, these alternatives were developed utilizing 

input from public scoping comments, cooperating agencies, and the Eastern Montana Resource 

Advisory Council (RAC). 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-2 Chapter 2: Resource Management Alternatives

This chapter is organized into the following sections: 

 2.2 Developing the Range of Alternatives – describes the process and key 

concepts used to develop the range of alternatives considered in detail 

 2.3 Key Components of the Alternatives – briefly describes each of the key 

components of the alternatives, including a description of desired outcomes, 

management actions, adaptive management, mitigation guidelines and land 

health standards 

 2.4 Alternatives Considered but Not Analyzed in Detail – describes 

alternatives that were considered, but dismissed from detailed analysis 

 2.5 Summary of the Alternatives – a brief summary of each alternative is 

presented in this section (Table 2.5 and Table 2.6 ) 

 2.6 Alternatives Considered in Detail – includes an overview of each 

alternative considered in detail by program, as well as a comprehensive 

discussion of the various management actions and allocations for each 

alternative considered in detail in a tabular format (Table 2.10, Table 2.11, Table 

2.12, and Table 2.13) 

 2.7 Summary of Environmental Consequences by Alternative – describes the 

impacts of the alternatives and includes tabular comparison of impacts for the 

alternatives considered in detail (Table 2.14 and Table 2.15) 

2.2 Developing the Range of Alternatives 

The alternatives described in this chapter represent varying approaches to addressing and 

resolving key planning issues (see Chapter 1) and to managing resources and resource uses in 

the planning area. Each alternative comprises two categories of land use planning decisions: (1) 

desired outcomes (goals and objectives) and (2) allowable uses and management actions that 

are anticipated to achieve desired outcomes. These two categories are discussed below. 

The BLM complied with the National Environmental Policy Act of 1969 (NEPA) and the 

Council on Environmental Quality (CEQ) implementing regulations at 40 Code of Federal 

Regulations (CFR) 1500 in the development of alternatives for this RMP/EIS, including 

seeking public input and analyzing reasonable alternatives. Where necessary to meet the 

planning criteria, to address issues and comments from cooperating agencies and the public, or 

to provide a reasonable range of alternatives, the alternatives include management options for 

the planning area that would modify or amend decisions made in the 1984 Billings RMP and 

ROD, as amended. Some decisions from the 1984 Billings RMP and ROD are acceptable and 

reasonable; in these instances, there is limited need to develop alternative management 

prescriptions. In some cases, management prescriptions are the same across all alternatives or 

may reflect only a decision to implement or not implement an action. All alternatives would 

comply with state and federal laws, regulations, and policies, and standards, and implement 

actions originating from laws, regulations, and policies. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-3 

Public input received during the scoping process was considered to ensure that all issues and 

concerns would be addressed, as appropriate, in developing the alternatives. Comments 

received during and after the formal scoping period cover a wide range of issues. The scoping 

process and its results, as well as opportunities for future public and agency involvement, are 

summarized in Chapter 5. The development of alternatives was initiated with compiling and 

analyzing Alternative A (No Action). Alternatives B, C, and D (Proposed) were then developed 

and analyzed. 

Many of the decisions from the existing Billings RMP have been implemented. In some cases, 

implementation of these decisions established valid existing rights or other obligations that are 

important considerations in preparing the revised Billings and Pompeys Pillar National 

Monument RMP/EIS. For example, some oil and gas resources in the planning area are leased 

and some rights-of-way have been approved. The presence of these valid existing rights 

influences, and sometimes limits management choices. Specific to the oil and gas program, the 

alternatives in this RMP/EIS address the availability and allocation of lands for future oil and 

gas leasing, potential lease stipulations and additional mitigation to be considered and applied 

during the Application for Permit to Drill (APD) process. Mitigation measures and BMPs 

identified in this RMP/EIS would be applied to the APDs for new leases and could be applied 

to APDs from existing leases through subsequent implementation-level planning processes. 

The BLM manages public lands and resource values in accordance with the principles of 

multiple use and sustained yield. Given these principles and the inherent conflicting nature of 

resource conservation and resource development, alternative formulation occurs within the 

limits of planning criteria that address the needs of present and future generations, while 

remaining flexible for periodic adjustments. This approach resulted in a reasonable range of 

alternatives that vary by their emphasis on allowable uses and management actions that affect 

conservation and development. For example, restrictions on oil and gas development in and 

around occupied Greater Sage-Grouse leks may exclude or constrain one land use (i.e. oil and 

gas development) to protect another (i.e. special status species – wildlife). Of course, not all 

resources or resource uses are mutually exclusive, but rarely do actions beneficial to one 

resource benefit all of the other resources and resource uses that the BLM must manage. The 

multitude of resources within the planning area coupled with the requirement to manage for 

multiple use and sustained yield requires developing alternatives across a continuous spectrum 

from resource conservation to resource development. For example, Alternative B places more 

emphasis on resource conservation, whereas Alternative C places more emphasis on resource 

development. The remaining alternatives (A and D) fall in between B and C on the continuous 

spectrum, as shown in Figure 2-1. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-4 Chapter 2: Resource Management Alternatives

Figure 2-1 Reasonable Range of Alternatives for the Billings and Pompeys Pillar National 

Monument RMP/EIS 

2.2.1 Alternative Formulation

Once developed, the BLM analyzed the alternatives to determine their impacts on the 

environment and the degree to which each alternative met the desired outcomes (goals and 

objectives) identified for that resource or resource use. Based on the impacts analysis of these 

alternatives, along with knowledge of specific issues raised throughout the planning process, 

input from cooperating agencies and BLM resource specialists, consideration of planning 

criteria, and potential resolution of resource conflicts, the BLM has identified Alternative D as 

the Proposed Alternative. 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 groups during the scoping process; and (3) addresses potential 

environmental issues identified during review of the proposed management actions 

The BLM selected the Proposed Alternative based on the following selection criteria: 

1) Satisfy statutory requirements 

2) Reflect the best combination of decisions to achieve the BLM goals and policies 

3) Represent the best solution to the purpose and need 

4) Provide the best approach to addressing key planning issues 

5) Consider cooperating agencies and BLM specialists’ recommendations

Resource Development

Conservation Emphasis

Limits of

Planning Criteria

Reasonable Range

of Alternatives
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-5 

All of the alternatives presented in this document have been analyzed by a BLM 

interdisciplinary team. Alternative D was identified in the Draft RMP and Environmental 

Impact Statement (EIS) as the Preferred Alternative. Based on comments received during the 

public comment period on the Draft RMP/EIS and additional internal review, the BLM revised 

the Preferred Alternative. As modified, Alternative D is presented as the Proposed Alternative 

and Proposed RMP in the Final EIS. 

Upon completion of this process, the Decisions Comment to All Alternatives combined with 

the Proposed Alternative selected by the State Director (either Alternative D or any of the other 

alternatives, or a combination thereof) will form the management plan for the Billings Field 

Office and Pompeys Pillar National Monument. 

2.3 Key Components of the Alternatives 

Alternatives described in this chapter represent approaches to addressing key planning issues 

(see Chapter 1) and to managing resources and resource uses in the planning area. Each 

alternative comprises two categories of land use planning decisions: (1) desired outcomes 

(goals and objectives) and (2) allowable uses and management actions. 

2.3.1 Desired Outcomes (Goals and Objectives) 

Goals and objectives provide overarching direction for BLM actions in meeting the agency’s 

legal, regulatory, policy, and strategic requirements. Goals are broad statements of desired 

outcomes, but generally are not measurable. Objectives are more specific statements of a 

desired outcome that may include a measurable component. Objectives generally are 

anticipated to achieve the stated goals.

2.3.2 Allowable Uses and Management Actions

Allowable uses and management actions comprise the second category of land use planning 

decisions and are anticipated to achieve the desired outcomes (goals and objectives). 

Alternatives were refined to address planning issues, resolve resource conflicts, improve 

consistency, and ensure resource-specific decisions for the following categories in the RMP 

revision process (see Table 2.7 ): 

1) Physical, Biological and Cultural/Heritage Resources 

2) Resource Uses and Support 

3) Special Designations 

Management actions are proactive measures or limitations intended to guide BLM activities in 

the planning area. Three types of management actions are included in the alternatives. The first 

is management actions common to all alternatives, which will apply regardless of what 

alternative is selected. The second is management common to action alternatives, which will 

apply to alternatives B, C, and D regardless of which alternative is selected. The third is 

management actions by alternative, which represent the choice(s) considered across 

alternatives. 
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2-6 Chapter 2: Resource Management Alternatives

Allowable uses identify where land uses are allowed, restricted, or prohibited on all BLMadministered surface and Federal mineral estate in the planning area. Alternatives may include 

specific land use restrictions to meet goals and objectives and may exclude certain land uses to 

protect resource values. For example, alternatives considered for this RMP revision prohibit 

surface occupancy (i.e., no surface occupancy [NSO]) by oil and gas development within 

occupied Greater Sage-Grouse leks and associated buffers. Because the alternatives identify 

whether particular land uses are allowed, restricted, or prohibited, allowable uses often include 

a spatial component (e.g., map) to display the variances between alternatives. 

The third type of management action, management actions by alternative, represents the range 

of choices considered across alternative. An example of this type of management actions is to 

restore riparian habitat to address issues of water quality and/or fish and wildlife habitat. In this 

example, the acreage or mileage of riparian habitat to restore may vary by alternative, whereas 

the action (restore riparian habitat) is retained for all alternatives. 

It is important to note that the RMP is strategic in nature, and, while it provides an overarching 

vision for managing resources in the planning area, it also allows management flexibility in 

light of changing priorities, information, and circumstances. This management flexibility can 

be called adaptive management. 

2.3.3 Bureau of Land Management Policy and Administrative Actions 

The BLM has policy guidance already established under various instruction memoranda and 

information bulletins from both the Washington and Montana State Offices. Policies are 

generally issued and/or updated based on new science, research, and technology. For example, 

one policy is that “to reduce the risk of collisions, avoid the use of guy wires for turbine or 

MET tower supports. All existing guy wires should be marked with recommended bird 

deterrent devices (WO IM-2010-022).” While many of these policies are included as 

management actions where appropriate or included in supplementary information in some 

appendices, there are numerous policies that apply to the Billings Field Office and all cannot be 

described here in their entirety. For more information on BLM policies applicable to land use 

planning, refer to BLM Handbook H-1601-1, Land Use Planning Handbook (2005) and the 

information bulletins and instruction memorandums available on BLM websites for the 

Washington and Montana State Offices 

http://www.blm.gov/wo/st/en/prog/planning/planning_overview/guidance.html

Administrative actions are the day-to-day activities required to serve the public and to provide 

optimum management of the Billings Field Office’s resources. These actions are allowable by 

regulation and do not require authorization within an RMP, but may require site-specific 

analysis under NEPA. For example, in day-to-day management of the Billings Field Office, 

BLM is responsible for law enforcement activities that need not be authorized under the RMP. 

Additionally, BLM may authorize or restrict access in certain areas in emergency situations 

(with proper notification requirements) or coordinate with other agencies and organizations, 

such as Montana Fish, Wildlife, and Parks, for specific activities that may not require sitespecific NEPA documentation efforts. These or other administrative actions would be 

conducted in the BiFO, sometimes in partnership with other landowners, agencies or 

organizations. The degree to which these actions are carried out depends upon BLM policies, 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-7 

available personnel, funding levels and further environmental analysis and decisions, as 

appropriate. 

2.3.4 Summary of Changes between Draft RMP/EIS and the Proposed 

RMP/Final EIS 

The Draft RMP/EIS was published in March 2013, and the public comment period closed in 

June 2013. The BLM received 771 comment letters/emails of which 463 letters/emails 

contained substantive comments. From those letters/emails, a total of 890 individual comments 

were received which touched on a wide range of issues. While many of the comments 

supported the Proposed Alternative in the Draft RMP/EIS, commenters also identified areas 

where the document could be improved. The B&PPNM RMP interdisciplinary team carefully 

evaluated these comments (Chapter 5). The Proposed RMP/Final EIS contains a number of 

changes made in response to comments. A summary of the changes follow. The changes made 

in the Proposed RMP/Final EIS prompted by comments do not require a supplemental EIS 

because they do not include or raise any issues that were outside of the range of alternatives 

presented and analyzed in the Draft RMP/EIS. 

As a result of public comments, the best science, cooperating agency coordination, and internal 

review of the Draft RMP/EIS, the BLM has developed the Proposed RMP/Final EIS for 

managing BLM-administered public lands. The Proposed RMP/Final EIS focusses on 

addressing public comments, while continuing to meet the BLM’s legal and regulatory 

mandates. The Proposed RMP/Final EIS is a variation of the Preferred Alternative (D) and is 

within the range of alternatives analyzed in the DRMP/EIS. 

Changes made to the Proposed RMP/Final EIS from the Preferred Alternative (D) in the Draft 

RMP/EIS are the following: 

Air Resources and Climate Change: Additional background information was added to the 

Proposed RMP regarding emissions of greenhouse gases (GHG) and national actions to reduce 

GHGs. The goals were revised for air quality and air quality-related values, and objectives 

were added for reducing air pollutant and GHG emissions from BLM-authorized activities. 

Fluid Minerals: Additional background information was added to the Proposed RMP 

regarding hydraulic fracturing (fracking). New oil and gas lease stipulations were added for 

Air Quality, Sensitive Soils and Rock Outcrops, and Source Water Protection. To provide 

consistency between Montana/Dakotas BLM land use plan revisions, many of the fluid mineral 

lease stipulations for wildlife have been revised (Appendix C). 

Wilderness Characteristics: Based on citizen-submitted information an additional area (Bear 

Creek area) was evaluated for wilderness characteristics. It is proposed to be managed for its 

wilderness characteristics under Alternative B only. Also between Draft and Final, the 

inventory of the islands in the Clark’s Fork and Yellowstone Rivers was completed. The 

acreages (total acres reviewed, acres containing wilderness character, and acres with nonwilderness character) have been updated accordingly (Appendix K). 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-8 Chapter 2: Resource Management Alternatives

Trails and Travel Management: The Travel and Transportation section of the RMP and the 

Travel Management Plan (Appendix O) have been revised to bring these sections into 

compliance with recent Manual and Policy changes made since the planning effort began. A 

field office wide non-motorized travel system comprising approximately 75 miles on 52 

individual routes was developed in Chapter 2 and included in the Chapter 4 impact analysis, as 

well as in the stand-alone Travel Plan (Appendix O). 

A total of 17 individual route changes were made in the Travel Management Areas (TMAs) 

between Draft and Final. After all changes, a total of two routes with four miles were found to 

be county maintained and approximately 3.3 cumulative miles were changed from an open to 

motorized use to a limited or closed to motorized use category. 

Additional information from public comments was received on routes outside of the TMAs as 

well. These will be included in the route inventory to begin in FY 2015. 

The Chapter 2 language regarding landing airplanes and helicopters on landlocked BLM 

managed surface has been modified, but does not alter the Chapter 4 analysis. 

Chapter 2 language regarding snowmobile use has been modified but does not alter the Chapter 

4 analysis. 

The No Action Alternative (Alternative A) for the South Hills Travel Management Area has 

been selected as the Proposed Alternative. 

Wild and Scenic Rivers: The Wild and Scenic River Suitability Report has been included in 

Appendix R. 

Visual Resources: The Visual Resource Inventory has been updated and included in the 

document. Neither the Chapter 2 alternatives or Chapter 4 impact analysis have been affected 

by this update. 

Areas of Critical Environmental Concern: One new ACEC (Steamboat Butte) proposal was 

received during the public comment period. It has been evaluated and met the Relevance 

criteria, but not the Importance criteria (Appendix E). Based on the 2014 VRM inventory and 

the Alternative D ACEC management prescriptions, several ACECs VRM classes are now 

Class II. The Chapter 4 impact analysis has not been affected by this update. 

Solid Leasables – Coal: Chapter 3 has been updated with current information and maps as has 

Appendix M. 

Federal Mineral Estate: The federal mineral estate acreage identified in Chapter 1 of the Draft 

RMP/EIS identified all the federal mineral estate within the Billings Field Office boundaries 

(1,839,782 acres), USFS, USFWS, BOR and BLM. This acreage as been corrected to only the 

BLM administered federal mineral estate (889,479 acres). This acreage change has not affected 

impact analysis in any way as only the BLM administered federal mineral estate acreage was 

used during impact analysis. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-9 

Wildlife – Greater Sage-Grouse: When the Billings Field Office began the RMP revision 

process in 2008, all BLM managed surface within GRSG priority habitat and general habitat 

received a detailed and thorough review to ensure each parcel of land contained sage-grouse 

habitat. Those lands not containing habitat of any kind, although within the GRSG general 

habitat boundaries, was not identified and not analyzed as GRSG general habitat in the Draft 

RMP. However between draft and final, the Billings Field Office modified the boundaries to 

the GRSG GHMAs to match those the National Operations Center was using. The result was 

all BLM managed surface within the GRSG Priority Areas for Conservation (PAC) regardless 

of habitat condition, vegetation cover, or development has been incorporated into GRSG 

Priority Habitat Management Areas and General Habitat Management Areas. As a result, the 

GRSG GHMA in Alternative D has increased in acreage. Management actions and effected 

acreages within Fluid Minerals, Realty, Cadastral Survey, and Lands (ROWs), Renewable 

Energy have been modified as a result of the GRSG habitat management modification. 

Allocations for PHMA and GHMA – allocations in the PRMP/FEIS provide more opportunities 

for uses in GHMA, while still maintaining conservation management by establishing screening 

criteria for project/activity review in GRSG habitat. 

The USGS Buffer Study – Included in a management action to incorporate the lek bufferdistances identified in the USGS report titled Conservation Buffer Distance Estimates for 

Greater Sage-Grouse – A Review: USGS Open File Report 2014-1239 (Mainer et al. 2014) 

during the NEPA analysis at the implementation stage. Although the buffer report was not 

available at the time of the DEIS release, applying these buffers was addressed in the DEIS and 

is qualitatively within the spectrum of alternatives analyzed. Specifically Alternative B 

identified and analyzed allocation restrictions such as closure to fluid minerals, 

recommendations for locatable mineral withdrawal, and restrictions on Renewable Energy 

development. Accordingly, the management decision to require lek buffers for development 

within certain habitat types is within the range of alternatives analyzed. 

Adaptive management – Identification of hard and soft adaptive management triggers for 

population and habitat and identified appropriate management responses. Chapter 2 of the 

DEIS identified that the BLM would further develop the adaptive management approach by 

identifying hard and soft triggers and responses. All of the adaptive management hard trigger 

responses were analyzed within the range of alternatives. For example, if a hard trigger is 

reached in GHMA, and GHMA would be managed as open to saleable minerals in the 

Proposed Plan, the response would be to manage it as closed to saleable minerals. This closure 

was analyzed under Alternative B in the Draft EIS. 

Monitoring and Disturbance – The monitoring framework was further refined in the FEIS, and 

further clarification as to how disturbance cap calculations would be measured were developed 

for the FEIS. During the public comment period, BLM received comments on how monitoring 

and disturbance cap calculations would occur at implementation. The DEIS outlined the major 

components of the monitoring strategy, as well as provided a table portraying a list of 

anthropogenic disturbances that would count against the disturbance cap. A BLM Disturbance 

and Monitoring Sub-team further enhanced the two sections of Appendix AA (Sections B and 

C) in the FEIS. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

2-10 Chapter 2: Resource Management Alternatives

Mitigation Strategy; Net Conservation Gain – The net conservation gain strategy is in response 

to the overall landscape goal which is to enhance, conserve, and restore GRSG and its habitat. 

All of the Action Alternatives provided management actions to meet the landscape-scale goal. 

The intent of the Proposed Plan is to provide a net conservation gain to the species. To do so, in 

undertaking BLM management actions, and, consistent with valid existing rights and applicable 

law, in authorizing third party actions that result in habitat loss and degradation within priority 

habitat (core population areas and core population connectivity corridors), the BLM would 

require and ensure mitigation that provides a net conservation gain to the species including 

accounting for any uncertainty associated with the effectiveness of such mitigation. This would 

be achieved by avoiding, minimizing, and compensating for impacts by applying beneficial 

mitigation actions. 

WAWFA Management Zone Cumulative Effects Analysis on GRSG – A quantitative 

cumulative effects analysis for GRSG was included in the FEIS. This analysis was completed 

to analyze the effects of management actions on GRSG at the biologically significant scale 

which was determined to be at the WAWFA Management Zone. The DEIS, in Chapter 4, 

included a qualitative analysis and identified that a quantitative analysis would be completed 

for the FEIS at the WAWFA Management Zone. 

NEPA requires agencies to prepare a supplement to the Draft EIS if 1) the agency makes 

substantial changes in the proposed action that are relevant to environmental concerns; or 2) if 

there are significant new circumstances or information relevant to environmental concerns and 

bearing on the proposed action or its impacts. A supplement is not necessary if a newly 

formulated alternative is a minor variation of one of the alternatives and is qualitatively within 

the spectrum of alternatives analyzed in the Draft EIS. 

The Proposed RMP revision includes components of the alternatives analyzed in the Draft EIS. 

Taken together, these components present a suite of management decisions that present a minor 

variation of the preferred alternative identified in the Draft RMP/EIS and are qualitatively 

within the spectrum of alternatives analyzed. 

As such, the BLM had determined that the Proposed RMP/Final EIS is a minor variation of the 

preferred alternative and that the impacts of the Proposed RMP/Final EIS would not affect the 

human environment in a substantial manner or to a significant extent not already considered in 

the EIS. The impacts disclosed in the Proposed RMP/Final EIS are similar or identical to those 

described in the Draft RMP/EIS. 

2.3.5 Adaptive Management

The Department of the Interior Office of Environmental Policy and Compliance issued ESM03 

6, which provides initial guidance to all agencies on the implementation of adaptive 

management practices for NEPA compliance. The Interior Department Manual 516 DM 4.16 

defines adaptive management as “a system of management practices based on clearly identified 

outcomes, monitoring to determine if management actions are meeting outcomes and, if not, 

facilitating management change that would best ensure that outcomes are met or re-evaluate the 

outcomes.”
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-11

This Proposed RMP/EIS recommends an adaptive management strategy. This adaptive 

management process is flexible and generally involves four phases: planning, implementation, 

monitoring, and evaluation (see Figure 2-2). 

Figure 2-2 Adaptive Management Strategy Phases 

Adaptive management is a formal, systematic, and rigorous approach to learning from the 

results of management actions, accommodating change and improving management. It involves 

synthesizing existing knowledge, exploring alternative actions, and making explicit forecasts 

about their results. Management actions and monitoring programs are carefully designed to 

generate reliable feedback and clarify the reasons underlying results. Actions and objectives are 

then adjusted based on this feedback and improved understanding to continue to try to achieve 

the desired outcomes. In addition, decisions, actions and results are carefully documented and 

communicated to others so that knowledge gained through experience is passed on rather than 

lost when individuals move or leave the organization. 

As the BLM obtains new information, it is able to evaluate monitoring data and other resource 

information to periodically refine and update desired outcomes (goals and objectives), 

management actions, and allowable uses. This allows continual refinement and improvement of 

management prescriptions and practices. 

Land use plan level decisions would not be immediately adaptable. These include goals, 

objectives, special designations, and allocations. Plan amendments would be required to change 

these decisions. Implementation or activity level decisions could be adapted as conditions are 

studied and monitored. Future activity level plans would follow NEPA procedures and involve 

the public. Some resource management plan-level decisions would not be immediately 

adaptable. 

The BLM will review monitoring results on a periodic basis, and any management objectives 

or actions that may need to be changed or adjusted will be open to public review and comment 

before decisions are made through an environmental review process. Appendix X provides 

more information on implementation and monitoring. Appendix AA (sections A and B) 

provides specific guidance for monitoring sage-grouse and sagebrush habitats, which will allow 

for adjustments to plan decisions, based on the described adaptive management approach. 

Implementation

Evaluation Monitoring

Planning
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Proposed Resource Management Plan and Final Environmental Impact Statement 

2-12 Chapter 2: Resource Management Alternatives

Through implementation an adaptive management approach may also be used for specific 

activities in the planning area, if appropriate, consistent with Secretarial Order 3270 (Adaptive 

Management). Adaptive management would require activity level planning, environmental 

review, and public involvement. 

Planning, implementing, monitoring, evaluating, and adjusting as necessary through planning, 

are the four steps of Adaptive Management. Planning involves a great amount of time and 

resources to identify issues and management opportunities to address those issues. During the 

planning process, the scope of the issue is identified and management goals, objectives and 

actions are defined to address the issues. Once the planning process is completed, decisions are 

implemented, monitored, and evaluated over a period of time to determine if goals are being 

met and if management actions are achieving the desired objective or standard. Results of 

monitoring are documented and communicated to appropriate parties, and management 

objectives and actions are modified, if necessary, based on results. 

All proposed actions in the future must conform to the Billings and Pompeys Pillar National 

Monument RMP and Record of Decision when completed (43 CFR 1601.0-5(b)). Proposed 

actions on or affecting BLM land must also be reviewed for National Environmental Policy Act 

(NEPA) compliance. Proposed actions fall into one of five categories: (1) actions that are 

exempt from NEPA; (2) actions that are categorically excluded; (3) actions that are covered by 

an existing NEPA environmental document; (4) actions that require preparation of an 

environmental assessment (EA) to determine if an environmental impact statement (EIS) is 

needed; or (5) actions that require preparation of an EIS. The NEPA procedural, 

documentation, and public involvement requirements are different for each category. However, 

all proposed actions must be in conformance with the approved resource management plan. 

For additional information, please refer to BLM Handbook H-1790-1 available at most BLM 

offices or on the BLM website at: 

http://www.blm.gov/pgdata/etc/medialib/blm/ak/aktest/planning/planning_general.Par.2116.Fil

e.dat/Handbook.NEPA.H-1790-1.2k8.01.30[1].pdf.

2.3.5.1 Adaptive Management and GRSG

If the BLM finds that the State of Montana is implementing a GRSG Habitat Conservation 

Program that is effectively conserving the GRSG, the BLM will review the management goals 

and objectives to determine if they are being met and whether amendment of the BLM plan is 

appropriate to achieve consistent and effective conservation and GRSG management across all 

lands regardless of ownership. In making amendments to this plan, the BLM will coordinate 

with the USFWS as BLM continues to meet its objective of conserving, enhancing and 

restoring GRSG habitat by reducing, minimizing or eliminating threats to that habitat. 

2.3.6 Best Management Practices 

Best management practices for all resources may be found in Appendix B and Greater SageGrouse best management practices may be found in Appendix AA (section F). Best 

management practices are management actions that have been developed by agency, industry, 

scientific, and/or working groups as methods for mitigating environmental impacts associated 

with certain kinds of activity. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-13

Best management practices would be implemented at the discretion of the Authorized Officer 

on a project specific 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 

wherever appropriate. 

Throughout the planning area, BLM-authorized activities associated with all resource and all 

resource use programs would be subject to impact mitigation/minimization guidelines and best 

management practices (BMPs) found in Appendices B and AB (note: refer to Appendix D –

Fluid Minerals for operating standards specific to oil and gas leasing and developing). 

The purpose of the BMPs is to (1) reserve for the BLM the right to modify the operations of 

surface-disturbing and/or disruptive activities as part of the statutory requirements for 

environmental protection, and (2) inform a potential lessee, permittee, or operator of the 

requirements that must be met when using BLM-administered public lands. Operating 

standards are given as acceptable methods for mitigating anticipated effects and achieving the 

desired plan outcomes but are not prescribed as the only method for achieving the outcomes. 

Mitigation of surface-disturbing or disruptive activities would be applied where needed to 

minimize impacts and could be applied consistent with the oil and gas stipulations outlined in 

the Fluid Minerals section of Chapter 2. Mitigation measures would be applied on a case-bycase basis during activity level planning if an evaluation of the project area indicates the 

presence of important wildlife species seasonal wildlife habitat or other resource concern. 

Exceptions may be granted by the authorized officer if an environmental review demonstrates 

that effects could be mitigated to an acceptable level, habitat for the species is not present in the 

area, or portions of the area can be occupied without affecting a particular species. Exceptions 

may also be granted where the short-term effects are mitigated by the long-term benefits (e.g., 

prescribed fire or forest health treatments). 

The mitigation would be requirements, procedures, management practices or design features 

that the BLM, through issuance of the record of decision would adopt as operational 

requirements. The BLM may add additional site-specific restrictions as deemed necessary by 

further environmental analysis and as developed through consultation with other federal, state, 

and local regulatory and resource agencies. 

2.3.6.1 Mitigation Measures and Conservation Actions for Surface 

Disturbing and Disruptive Activities

Mitigation measures and conservation actions are Best Management Practices (BMPs), 

operating procedures, or design features that have been developed to avoid, minimize, rectify, 

reduce, or compensate for potentially significant adverse environmental impacts associated 

with surface disturbing or disruptive activities which many impact a variety of resource values 

(including, but not limited to: soils, riparian and wetlands, cultural and paleontological 

resources, rangelands and shrublands, special status plants, wildlife habitat, fisheries habitat, 

etc.). 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

2-14 Chapter 2: Resource Management Alternatives

For the purposes of applying mitigation measures, surface disturbing and disruptive activities 

are defined as follows: 

Surface-Disturbing Activities: The physical disturbance or removal of land surface and 

vegetation. Some examples of surface-disturbing activities include, but are not limited to, 

construction of roads, well pads, pipelines, power lines, 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. 

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 term 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. 

For example, emergency activities (fire suppression, search and rescue, etc.), or rangeland 

monitoring, routine maintenance associated with an approved authorization, dispersed 

recreational activities (hunting, hiking, etc.), and livestock grazing are not considered surfacedisturbing or disruptive activities. 

Mitigation measures for all resources are included in Appendix B (Best Management Practices 

for all resources /resource uses) and Appendix AA (Section F) includes the Greater SageGrouse Mitigation Measures and Conservation Actions. The BLM may add additional 

mitigation measures as deemed necessary by further environmental analysis and as developed 

through consultation with other federal, state, and local regulatory and resource agencies. 

The BLM will apply appropriate mitigation measures and conservation actions to BLM 

authorized activities to avoid, minimize, rectify, reduce, or compensate for impacts if an 

evaluation of the project area indicates the presence of important wildlife species, seasonal 

wildlife habitat, or other resource concerns. The sequence of mitigation action will be: 

Step 1. Avoid - Adverse impacts to resources of concern are to be avoided and no 

action shall be permitted if there is a practicable alternative with less adverse 

impact. 

Step 2. Minimize - If impacts to resources of concern cannot be avoided, 

appropriate and practicable steps to minimize adverse impacts must be taken. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-15

Step 3. Compensate - Appropriate and practicable compensatory mitigation is 

required for unavoidable adverse impacts which remain. The amount and quality of 

compensatory mitigation may not substitute for avoiding and minimizing impacts. 

Even after avoiding and minimizing impacts, projects that will cause adverse impacts to 

resources typically require some type of compensatory mitigation. Compensatory mitigation 

refers to the restoration, establishment, enhancement, or in certain circumstances preservation 

of resources for the purpose of offsetting unavoidable adverse impacts. The BLM will 

determine the appropriate form and amount of compensatory mitigation required. Methods of 

compensatory mitigation include restoration, establishment, enhancement and preservation. 

 Restoration: Re-establishment or rehabilitation of a resource with the goal of returning 

natural or historic functions and characteristics to a currently degraded area. Restoration 

may result in a gain in function or acres, or both. 

 Establishment (Creation): The development of a resource where that resource did not 

previously exist through manipulation of the physical, chemical and/or biological 

characteristics of the site. Successful establishment results in a net gain in acres and 

function. 

 Enhancement: Activities conducted within existing resource that heighten, intensify, or 

improve one or more functions. Enhancement is often undertaken for a specific purpose 

such as to improve water quality, flood water retention or wildlife habitat. Enhancement 

results in a gain in function, but does not result in a net gain in acres. 

 Conservation: The permanent protection of ecologically important resources through 

the implementation of appropriate legal and physical mechanisms (i.e. conservation 

easements, title transfers). Preservation may include protection of areas adjacent to 

resource location as necessary to ensure protection or enhancement of the ecosystem. 

Preservation does not result in a net gain of acres and may only be used in certain 

circumstances, including when the resources to be preserved contribute significantly to 

ecological sustainability. 

There are times when mitigating project impacts through onsite mitigation alone, may not be 

possible or sufficient to adequately mitigate impacts and achieve resource objectives. In these 

cases, it may be appropriate to consider offsite mitigation as a feature of one or more of the 

alternatives in the impact analysis. Offsite mitigation is generally appropriate when the 

authorized officer determines that impacts cannot be mitigated to an acceptable level onsite and 

it is expected that the land use authorization as submitted would not be consistent with the 

BLM’s resource objectives. BLM may expressly condition its approval of an action on the 

applicant’s commitment to take actions, and the BLM may, if necessary, seek appropriate 

enforcement action to ensure the terms of the contract are met (BLM Instruction Memorandum 

No. 2012-043). 

Because of site-specific circumstances, some mitigation measures and conservation actions 

may not apply to some activities (e.g., a resource or conflict is not present on a given site) 

and/or may require slight variations from what is described in this appendix (AA, sections E & 

F). Proposed variations will be addressed as site specific mitigation applied in the permitting 

process. All variations in mitigation measures and conservation actions will require appropriate 
Billings and Pompeys Pillar National Monument 

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2-16 Chapter 2: Resource Management Alternatives

analysis and disclosure as part of activity authorization. It is anticipated that variations in the 

mitigation measures and conservation actions will be approved in very limited circumstances 

and only in coordination with state wildlife management agencies. Mitigation measures and 

conservation actions selected for implementation will be identified in the Record of Decision 

(ROD) or Decision Record (DR) for those activities. The proponent must implement those 

identified mitigations because they are commitments made as part of the BLM decision. 

Because these decisions create a clear obligation for the BLM to ensure any proposed 

mitigation adopted in the environmental review process is performed, there is assurance that 

mitigation will lead to a reduction of environmental impacts in the implementation stage and 

include binding mechanisms for enforcement (CEQ Memorandum for Heads of Federal 

Departments and Agencies 2011). The determination of adequate application of the mitigation 

measures and conservation actions for specific projects will remain with the BLM’s Authorized 

Officer. 

2.3.7 Land Health Standards 

Resources and Resource use programs would meet or move toward meeting the following 

standards to the extent practicable: 

1) Uplands are in proper functioning condition 

2) Riparian areas and wetlands are in proper functioning condition 

3) Water quality meets federal and Montana state standards 

4) Air quality meets Montana state standards 

5) Habitats are provided for healthy, productive, and diverse native plant and 

animal populations and communities. Habitats are improved or maintained for 

specials status species (federally threatened, endangered, candidate or Montana 

species of special concern). 

These standards, originally described as rangeland health standards (USDI BLM 1997), would 

be applied to BLM authorized activities as “Land Health Standards.” Detailed descriptions of 

the characteristics associated with these standards can be found in Appendix I. 

2.3.8 Activity Plans 

Program specific “activity plans,” such as habitat management plans or watershed restoration 

strategies, have been written over the years to apply a more focused approach to achieving land 

use planning goals. Activity plans provide direction for more site-specific actions. NEPA 

analysis is required for site-specific implementation actions. Program specific “activity plans” 

would be tiered to this document and are part of the implementation of this RMP/EIS 

(Appendix X).
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-17

2.3.9 Monitoring 

The BLM planning regulations (43 Code of Federal Regulations 1610.4-9) call for the 

monitoring of resource management plans on a continual basis with formal evaluation done at 

periodic intervals. The Billings and Pompeys Pillar National Monument RMP/EIS would be 

monitored on a continual basis. Plan evaluations would occur on 5 year intervals. Management 

actions arising from activity plan decisions would be evaluated to ensure consistency with the 

Approved RMP objectives (Appendix X). 

2.3.10 Greater Sage-Grouse Habitat Management 

In August 2011, the BLM convened the Sage-Grouse National Technical Team (NTT), which 

brought together resource specialists and scientists from the BLM, state fish and wildlife 

agencies, the USFWS, the U.S. Department of Agriculture Natural Resources Conservation 

Service (NRCS), and the U.S. Geological Survey. The NTT developed a series of sciencebased conservation measures to be considered and analyzed through the land use planning 

process. 

On December 9, 2011, a Notice of Availability was published in the Federal Register to initiate 

the BLM and U.S. Forest Service Greater Sage-Grouse Planning Strategy across ten western 

states, including California, Oregon, Nevada, Idaho, Utah, and Southwest Montana in the Great 

Basin Region and Northwest Colorado, Wyoming, Montana, South Dakota, and North Dakota 

in the Rocky Mountain Region. This EIS is one of fifteen separate EISs analyzing 

incorporation of specific conservation measures across the range of the Greater Sage-Grouse, 

consistent with BLM policy. 

The BLM Washington Office (WO) issued a National Greater Sage-Grouse Planning Strategy 

on December 27, 2011. WO Instruction Memorandum (IM) 2012-044 provides direction to the 

BLM on how to consider the NTT conservation measures in the land use planning process. 

The WO IM requires that the appropriate and applicable conservation measures in the NTT 

report be analyzed in at least one alternative in the land use planning EIS and that a “hard look” 

be given to the conservation measures, as applicable to local ecological site variability. 

Alternatives B and D in the Billings and Pompeys Pillar National Monument Proposed 

RMP/Final EIS contain conservation measures identified in the NTT report and incorporate the 

national strategy (WO IM 2012-044). 

2.3.10.1 BLM Programs for Addressing Greater Sage-Grouse Threats 

In 2013, the USFWS released their Conservation Objectives Team (COT) Report, which 

delineates reasonable objectives, based upon the best scientific and commercial data available 

at the time of its release, for the conservation and survival of Greater Sage-Grouse. The report 

also identified present and widespread and localized threats facing the Greater Sage-Grouse and 

their habitat in specific populations across the west. The ranges of management actions for 

managing Greater Sage-Grouse habitat analyzed in this EIS are directed toward responding to 

these threats. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

2-18 Chapter 2: Resource Management Alternatives

The direction for managing GRSG habitat in this document is focused on responding to the 

threats identified by the USFWS in its 2010 warranted but precluded finding on listing the 

GRSG, as well as its Conservation Objectives Team (COT) Report. The USFWS threats do not 

necessarily align with BLM or Forest Service resource program areas, and are often integrated 

into several different resource program areas. Table 2.1 , USFWS and COT Report Identified 

Threats to Greater Sage-Grouse and Their Habitat and Applicable BLM Program Areas, 

provides a cross-walk between the USFWS listing decision and COT-identified threats and the 

BLM program areas addressing these threats, with references to specific sections of the 

Proposed Plan to show how those threats were addressed in the BLM’s land use plan. 

On November 21, 2014 the USGS published “Conservation Buffer Distance Estimates for 

Greater Sage-Grouse—A Review” (USGS 2014). The USGS review provided a compilation 

and summary of published scientific studies that evaluate the influence of anthropogenic 

activities and infrastructure on GRSG populations. The BLM has reviewed this information and 

examined how lek buffer-distances were addressed through land use allocations and other 

management actions in the Draft Billings and Pompeys Pillar National Monument RMP/EIS. 

Based on this review, in undertaking BLM management actions, and consistent with valid and 

existing rights and applicable law in authorizing third party actions, the BLM will apply the 

lek buffer-distances in the USGS Report “Conservation Buffer Distance Estimates for Greater 

Sage Grouse-A Review (Open File Report 2014-1239)” in both GHMA and PHMA as detailed 

in Appendix AA (section G). 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-19

Table 2.1 Identified Threats to Greater Sage-Grouse and Their Habitat and Applicable 

BLM Proposed Plan Resource Program Areas Addressing These Threats 

Identified Threats to Greater Sage-Grouse and Their Habitat, and Applicable BLM Proposed Plan 

Resource Program Areas Addressing these Threats

USFWS-Identified Threats to 

Greater Sage-Grouse and Its 

Habitat (2010 warranted but 

precluded finding)

COT Report-Identified 

Threats to Greater SageGrouse and Its Habitat 

(2013)

Applicable BLM Proposed Plan Resource Program 

Addressing Threat

Wildland Fire Fire Fire Ecology and Management (Section 2.3.10.4.6)

Invasive Species Nonnative, Invasive Plants 

Species

Vegetation – Invasive Species and Noxious Weeds 

(Section 2.3.10.4.3) 

Vegetation – Rangeland and Shrubland (Section 

2.3.10.4.4)

Oil and Gas

(for wind/solar see 

Infrastructure)

Energy Development

Realty, Cadastral Survey, and Lands – Rights-of-Way, 

Leases, and Permits (Section 2.3.10.4.12)

Energy and Mineral Resources - Fluid Minerals (see 

Section 2.3.10.4.8)

Energy and Mineral Resources – Coal (Section 

2.3.10.4.7)

Wildlife Habitat and Special Status Species (Section 

2.3.10.4.5)

Prescribed Fire Sagebrush Removal

Vegetation - Rangeland and Shrubland (Section 

2.3.10.4.4)

Fire Ecology and Management (Section 2.3.10.4.6)

Grazing Grazing

Livestock Grazing (Section 2.3.8.1.3..14)

Vegetation – Rangeland and Shrubland (Section 

2.3.10.4.4)

Vegetation – Riparian and Wetland (Section 2.3.10.4.2)

See Grazing Management 

(above)

Range Management 

Structures Livestock Grazing (Section 2.3.10.4.14)

Conifer Encroachment Pinyon and/or Juniper 

Expansion

Fire Ecology and Management (Section 2.3.10.4.6)

Vegetation – Forests and Woodlands (Section 

2.3.10.4.1)

Agriculture and 

Urbanization

Agricultural Conversion 

and Ex-Urban 

Development

Realty, Cadastral Survey, and Lands – Land Tenure and 

Access (Section 2.3.10.4.11)

Hard Rock Mining Mining

Realty, Cadastral Survey, and Lands – Withdrawals 

(Section 2.3.10.4.13)

Energy and Mineral Resources – Locatable Minerals 

(Section 2.3.10.4.9)

Energy and Mineral Resources – Mineral Materials 

(2.3.10.4.10)

See Infrastructure, Roads Recreation Recreation and Visitor Services (Section 2.3.10.4.15)

Trails and Travel Management (Section 2.3.10.4.16)

Infrastructure

- Power lines/ 

pipelines

- Roads

- Communication sites

- Railroads

Range improvements (see 

below)

Infrastructure

Realty, Cadastral Survey, and Lands - Rights-of-Way, 

Permits, and Leases (Section 2.3.10.4.12)

Trails and Travel Management (Section 2.3.10.4.16)

Renewable Energy (Section 2.3.10.4.17)

Infrastructure – Range 

Improvements

Range Management 

Structures Livestock Grazing (Section 2.3.10.4.14)

Water Developments No similar threat identified All applicable programs
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Proposed Resource Management Plan and Final Environmental Impact Statement 

2-20 Chapter 2: Resource Management Alternatives

Climate Change No similar threat identified There is no BLM resource program in the proposed plan 

addressing this threat. 

Weather No similar threat identified

There is no BLM resource program in the proposed plan 

addressing this threat.

Predation No similar threat identified All applicable programs

Disease No similar threat identified All applicable programs

Hunting No similar threat identified There is no BLM resource program in the proposed plan 

addressing this threat.

Contaminants No similar threat identified Public Health and Safety (see Public Safety section)

Source: USFWS 2010, 2013

2.3.10.2 Range of Alternatives for Greater Sage-Grouse Management 

The action alternatives (Alternatives B, C, and D) offer a range of management approaches to 

maintain or increase Greater Sage-Grouse abundance and distribution of Greater Sage-Grouse 

by conserving, enhancing, or restoring the sagebrush ecosystem upon which Greater SageGrouse populations depend in collaboration with other conservation partners (Figure 2-3). The 

relative emphasis given to particular resources and resource uses differs as well, including 

allowable uses, restoration measures, and specific direction pertaining to individual resource 

programs. When resources or resource uses are mandated by law or are not tied to planning 

issues, there are typically few or no distinctions between alternatives. 

The meaningful differences among the alternatives are described in Table 2.10 through Table 

2.13 – Detailed Tables of Alternatives. This section also provides a complete description of the 

goals, objectives, and management actions for each alternative. In some instances, varying 

levels of management of Priority Habitat Management Areas (PHMA) and General Habitat 

Management Areas (GHMA) overlap a single area, or polygon, due to management 

prescriptions from different resource programs. In instances where varying levels of 

management prescriptions overlap a single polygon, the stricter of the management 

prescriptions would apply. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-21

Figure 2-3: BLM Managed Surface, Federal Mineral Estate, and Sage-Grouse Habitat Management Areas within the Billings Field Office Planning Area

BLM Managed Surface, Federal 

Minerals, and Sage-Grouse Habitat 

Management Areas within the 

Billings Field Office Planning Area 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-22 Chapter 2: Resource Management Alternatives

Table 2.2 Comparative Summary of Allocation Decisions of the Draft Alternatives and 

Proposed Plan (Proposed Alternative) for Greater Sage-Grouse Management 

(Acres) 

Resources/

Resource Uses

Alternative A

(Current Mgmt) Alternative B Alternative C

Alternative D

(Proposed)

Fluid Mineral

Leasing 

PH

Closed: 816

NSO: 9,203

CSU: 10,860

Timing: 150,341

Standard: 53,886

GH

Closed: 0

NSO: 0

CSU: 0

Timing: 0

Standard: 0

PHMA

Closed: 217,682

NSO: 193,490

CSU: 0

Timing: 0

Standard: 138

GHMA

Closed: 12,930

NSO: 62,922

CSU: 84,515

Timing: 10,162

Standard: 132

PHMA

Closed: 40

NSO: 34,950

CSU: 192,690

Timing: 0

Standard: 0

GHMA

Closed: 1,810

NSO: 18,891

CSU: 32,967

Timing: 58,681

Standard: 58,171

PHMA

Closed: 4,361

NSO: 218,075

CSU: 2,617

Timing: 345

Standard: 0

GHMA

Closed: 13,343

NSO: 154,273

CSU: 122,032

Timing: 10,063

Standard: 25,306

Wind and Solar 

ROWs

PH

Exclusion: 2,808

Avoidance: 877

Open: 158,720

GH

Exclusion: 7,843

Avoidance: 16,370

Open: 150,433

PHMA

Exclusion: 164,994

Avoidance: 240

Open: 9

GHMA

Exclusion: 176,683

Avoidance: 547

Open: 16

PHMA

Exclusion: 15,433

Avoidance:149,795

Open: 10

GHMA

Exclusion: 22,085

Avoidance: 154,949

Open: 215

PHMA

Exclusion:165,054

Avoidance: 0

Open: 0

GHMA

Exclusion: 24,615

Avoidance: 119,034

Open: 273

Corridors

PH

Open: 1,579

GHMA

Open: 0

PHMA

Open: 1,579

GHMA

Open: 0

PHMA

Open: 10,953

GHMA

Open: 2,838

PHMA

Open: 4,230

GHMA

Open: 268

Rights-of-Way

PH

Exclusion: 1,856

Avoidance: 877

Open: 162,425

GH

Exclusion: 5,088

Avoidance: 16,471

Open: 155,601

PHMA

Exclusion: 152,302

Avoidance: 12,687

Open: 166

GHMA

Exclusion:14,813

Avoidance: 133,756

Open: 28,592

PHMA

Exclusion: 811

Avoidance: 163,476

Open: 956

GHMA

Exclusion: 6,393

Avoidance: 119,919

Open: 50,939

PHMA

Exclusion: 1,360

Avoidance: 163,796

Open: 248

GHMA

Exclusion: 9,037 

Avoidance: 167,000 

Open: 26,770

Mineral Material 

Sales and Permits

PH

Open: 161,193

Closed: 1,617

GH

Open: 223,071

Closed: 5,112

PHMA

Open: 223,182

Closed: 223,792

GHMA

Open: 322,005

Closed: 107,258

PHMA

Open: 10,974

Closed: 216,333

GHMA

Open: 322,005

Closed: 7,385

PHMA

Open: 10,957

Closed: 216,350

GHMA

Open: 307,704

Closed: 21,689

Locatable 

Minerals

PH

Open: 161,142

Closed: 543

GH

Open: 223,469

Closed: 1,305

PHMA

Open: 9,411

Closed: 217,895

GHMA

Open: 303,370

Closed: 29,025

PHMA

Open: 161,235

Closed: 1,120

GHMA

Open: 227,180

Closed: 1,413

PHMA

Open: 160,534

Closed: 2,138

GHMA

Open: 218,208

Closed: 6,621

2.3.10.3 Development of the Proposed Plan for Greater Sage-Grouse Habitat 

Management 

In developing the Proposed Plan for GRSG management, the BLM made modifications to the 

Proposed Alternative identified in the Draft LUP/EIS. The modifications are based on public 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-23

comments received on the Draft LUP/EIS, internal BLM review, new information and best 

available science, the need for clarification in the plans, and ongoing coordination with 

stakeholders across the range of the GRSG. As a result, the Proposed Plan provides consistent 

GRSG habitat management across the range, prioritizes development outside of GRSG habitat, 

and focuses on a landscape-scale approach to conserving GRSG habitat. 

The BLM modified the Proposed Alternative, identified as Alternative D as presented in the 

Draft LUP/EIS, which is now considered the proposed plan for managing BLM-administered 

lands within the Billings Field Office planning area. 

Since release of the Draft LUP/EIS, the BLM has continued to work closely with a broad range 

of governmental partners, including Governors, State Fish and Game agencies, the USFWS, 

Indian tribes, county commissioners and many others. Through this cooperation, the BLM has 

developed a Proposed Plan that takes into account state, Tribal, and local strategies in 

accordance with applicable law and contributes to the long-term conservation of the GRSG. 

The BLM also received many substantive public comments on the Draft LUP (Chapter 5), 

which greatly informed the BLM’s development of the Proposed Plan for GRSG management. 

The BLM’s Proposed Plan considers documents related to the conservation of GRSG that have 

been released since the publication of the draft LUP/EIS. For example, this Proposed Plan 

considers the USFWS’ October 27, 2014 memorandum “Greater Sage-Grouse: Additional 

Recommendations to Refine Land Use Allocations in Highly Important Landscapes” 

(Appendix AA) and the USGS’s November 21, 2014 report “Conservation Buffer Distance 

Estimates for Greater Sage-Grouse—A Review” (USGS 2014). The BLM also updated the 

Proposed Plan to reflect new GRSG state conservation strategies, including recent State 

Executive Orders. 

The BLM has refined the Proposed Plan to provide a layered management approach that offers 

the highest level of protection for GRSG in the most valuable habitat. Land use allocations in 

the Proposed Plan would limit or eliminate new surface disturbance in PHMA, while 

minimizing disturbance in GHMA. In addition to establishing protective land use allocations, 

the Proposed Plan for GRSG management would implement a suite of management tools such 

as disturbance limits (see Section 2.3.10.6), GRSG habitat objectives and monitoring (see 

Table 2.3 and Section 2.3.10.7), mitigation approaches (see Section 2.3.10.8), adaptive 

management triggers and responses (see Section 2.3.10.5), and lek buffer-distances (see 

Appendix AA (Section G)) throughout the range. These overlapping and reinforcing 

conservation measures will work in concert to improve GRSG habitat condition and provide 

clarity and consistency on how the BLM will manage activities in GRSG habitat. 

2.3.10.4 BLM Proposed Plan for Greater Sage-Grouse Habitat Management 

Many of the proposed plan goals, objectives, management actions and allowable uses identified 

in this section originate from the specific BLM resource/program areas and have been 

determined to be applicable to the proposed management of Greater Sage-Grouse habitat. The 

information presented below is the same as that presented in the Current Management and 

Alternatives section of Chapter 2 and has simply been consolidated here to depict how the 

agency proposes to manage Greater Sage-Grouse habitat. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

2-24 Chapter 2: Resource Management Alternatives

Throughout the planning area, BLM-authorized activities associated with all resources and all 

resource use programs would be subject to impact mitigation/minimization guidelines and best 

management practices (BMPs) found in Appendix B. 

2.3.10.4.1 Vegetation – Forests and Woodlands 

Actions 

 Remove conifers encroaching into sagebrush habitats. Prioritize treatments closest to

occupied sage-grouse habitats and near occupied leks, and where juniper encroachment

is phase 1 or phase 2. Use of site-specific analysis and principles like those included in

the FIAT report (Chambers et. al., 2014) and other ongoing modeling efforts to address

conifer encroachment would help refine the location for specific priority areas to be

treated.

2.3.10.4.2 Vegetation – Riparian

Actions 

 Manage riparian communities to meet Standards for Rangeland Health (Standard 2) to

ensure riparian areas and wetlands are in Proper Functioning Condition (PFC).

 Riparian areas would be monitored on a prioritized basis. High priority areas would

include:

o Riparian areas adjacent to fish bearing waters.

o Riparian areas with existing cottonwood galleries or potential cottonwood

gallery habitat

o Riparian areas within Greater Sage-Grouse Priority Habitat

2.3.10.4.3 Vegetation – Invasive Species and Noxious Weeds 

The actions specific to the management of invasive and noxious weeds are listed below, by 

alternative. These “Action Alternatives” would primarily protect people, water, fish, wildlife, 

special status species and their habitats, prevent the introduction and spread of invasive and 

noxious weeds. Some actions associated with other resources (soils, water, fish and wildlife 

etc.) benefit the management of invasive and noxious weed program by limiting activities that 

would reduce soil and vegetation disturbance and reduce the spread and introduction of 

invasive and noxious weeds. 

Goals and Objectives 

 Use Integrated Pest Management to make progress towards a healthy plant community,

while meeting multiple land use objectives and meeting Standards for Rangeland Health

(Standards 1, 2, and 5).

Actions 

 Noxious and invasive weed control would not occur within 1⁄2 mile of nesting and brood

rearing areas for special status species during the nesting and brood rearing season
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-25

2.3.10.4.4 Vegetation – Rangeland and Shrubland 

Goals and Objectives 

 Maintain, improve, enhance, or restore habitat to facilitate the conservation, recovery,

and maintenance of populations of native and desirable nonnative plant and animal

species.

 Promote recovery and restoration of sagebrush communities after wildfire events.

Actions 

 Manage rangelands to meet health standards consistent with the Standards for

Rangeland Health (Standards 1 and 5) and Guidelines for Livestock Grazing

Management and apply appropriate guidelines where not meeting the standards.

 Identify priority treatment areas for conifer encroachment, including big game winter

range, WUIs, current and historic sagebrush habitat, forest meadows and bighorn sheep

habitat.

 Within Greater Sage-Grouse Priority Habitat Areas, only treatments that conserve,

enhance, or restore Greater Sage-Grouse habitat would be allowed. Treatment methods,

including prescribed burning and mechanical treatments would be used to eliminate

conifer encroachment and stimulate vegetative re-growth in grassland/shrub land

habitats; and to reduce fuels, thin under-stories, recycle nutrients, and create small

openings in forested vegetation types.

 A target of eight percent of crested wheatgrass acres (approximately 2,378 acres) would

be converted to native sagebrush/grassland over the life of the plan.

 Preferred treatment areas would be areas that are not currently being used in a grazing

system to provide early spring grazing and reduce grazing pressure from other areas

within a grazing allotment.

o Priority treatment areas would be in Greater Sage-Grouse PHMAs, RAs, and

GHMAs.

 In all Priority Habitat Management Areas, the desired condition is to maintain a

minimum of 70% of lands capable of producing sagebrush with 10 to 30% sagebrush

canopy cover. The attributes necessary to sustain these habitats are described in

Interpreting Indicators of Rangeland Health (BLM Tech Ref 1734-6).*

2.3.10.4.5 Wildlife Habitat and Special Status Species 

Sagebrush, native grasslands, seasonal or crucial wildlife ranges, special status species habitat, 

fisheries, cottonwood galleries, and riparian/wetlands would be priority habitats. All wildlife 

habitats would be managed to meet Rangeland Health Standards (Standards 1 and 5). BLM is 

responsible for managing habitats, whereas state and federal wildlife management agencies 

(e.g., MT FWP, USFWS) oversee management of wildlife species. BLM would coordinate 

with and support the conservation plans of those agencies on BLM administered lands. Priority 

wildlife species for management are described in Chapter 3. 

In 2010, the U.S. Fish and Wildlife Service determined that the Greater Sage-Grouse is a 

Candidate species and Warranted, but precluded, by other priorities, for listing under the 

Endangered Species Act. In 2009, the MT/DAKs BLM delineated three types of Greater SageGrouse habitat areas as part of the planning process (Map 23): 

 Greater Sage-Grouse Habitat - Priority Habitat Management Areas (PHMAs),

* Footnote: 70% of the lands capable of producing that level will be
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-26 Chapter 2: Resource Management Alternatives

 Greater Sage-Grouse Habitat - Restoration areas (RAs), and

 Greater Sage-Grouse Habitat -– General Habitat Management Areas (GHMA)

Each area would have varying degrees of management in order to achieve the goals or 

objectives for each Greater Sage-Grouse habitat area. The Greater Sage-Grouse habitat 

delineations may be modified as needed as local site conditions change or as new information 

becomes available. Refer to the Glossary for definitions of the three Greater Sage-Grouse 

habitat areas, Appendix AA (section F) for mitigation measures and conservation actions for 

Greater Sage-Grouse habitat, and Appendix AA (section A) for monitoring of Greater SageGrouse and Sagebrush Habitats. 

Goals and Objectives 

 Manage for net conservation gain and connectivity of habitats on BLM-administered

lands. The necessary habitat would be present to maintain, enhance, or restore T & E,

special status, and priority native species populations. Sagebrush, native grasslands,

seasonal or crucial wildlife ranges, special status species habitat, fisheries, cottonwood

galleries, and riparian/wetlands would be priorities.

 Manage all BLM actions or authorized activities to sustain wildlife populations and

their habitats and to avoid contributing to the listing of or jeopardizing the continued

existence or recovery of special status species and their habitats.

 Manage or restore habitat on BLM-administered lands within the planning area to

facilitate the conservation, recovery, and maintenance of populations of native,

desirable non-native, and special status species consistent with appropriate local, state,

and federal management plans.

 Manage habitats to support MT FWP in the attainment of objectives and welldistributed, healthy populations of wildlife species consistent with the MT FWP’s

Strategic Habitat Plan, Montana’s Comprehensive Fish and Wildlife Conservation

Strategy, and strategic population plans, and to achieve the stated purpose of designated

State of Montana Wildlife Management Areas.

 Provide for the long-term conservation, enhancement, and restoration of the sagebrush

steppe/mixed-grass prairie complex in a manner that supports sustainable Greater SageGrouse populations and a healthy diversity and abundance of wildlife species.

 These habitat objectives in Table 2.3 summarize the characteristics that research has

found represent the seasonal habitat needs for Greater Sage-Grouse. The specific

seasonal components identified in Table 2.3 were adjusted based on local science and

monitoring data to define the range of characteristics used in this subregion. Thus, the

habitat objectives provide the broad vegetative conditions we strive to obtain across the

landscape that indicate the seasonal habitats used by sage-grouse. These habitat

indicators are consistent with the rangeland health indicators used by the BLM.

 The habitat objectives will be part of the sage-grouse habitat assessment to be used

during land health evaluations (Monitoring Framework, Appendix AA, section B).

These habitat objectives are not obtainable on every acre within the designated GRSG

habitat management areas. Therefore, the determination on whether the objectives have

been met will be based on the specific site's ecological ability to meet the desired

condition identified in the table.
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Chapter 2: Resource Management Alternatives 2-27

 All BLM use authorizations will contain terms and conditions regarding the actions

needed to meet or progress toward meeting the habitat objectives. If monitoring data

show the habitat objectives have not been met nor progress being made towards

meeting them, there will be an evaluation and a determination made as to the cause. If

it is determined that the authorized use is a cause, the use will be adjusted by the

response specified in the instrument that authorized the use.

 This information should not be viewed as providing standards by which to judge the

overall quality of sagebrush habitats. Instead, these sage-grouse habitat characteristics

should be used as one tool for assessing habitats and guiding management actions.

There is a tendency to review each indicator and its suitability category independently,

but site suitability is determined by the relationship among the several indicator values

in each matrix and the relative abundance of habitat types across the landscape. It is

important to understand that the desired conditions described for these habitat types are

based on average plant productivity and structural data and expert opinion relative to

sage-grouse use of a subset of sagebrush communities and they may not apply to all

sagebrush communities in the planning area variation (Davies et al. 2006). These

measures also do not account for inter-annual climate variation (Davies et al. 2006).

Individual indicator values do not define site suitability and overall site suitability

descriptions require an interpretation of the relationships between the indicators and

other factors. Professional expertise and judgment are required. Measurement of these

objectives will follow the steps described in Appendix AA.

 As described above, the identified habitat objectives are averages and will vary based

on the individual ecological sites and their potential. Ecological sites are the basic

component of a land-type classification system that describes ecological potential and

ecosystem dynamics of land areas. All land/land use types are identified within the

ecological site system, including rangeland, pasture, and forest land. An ecological site

is defined as a distinctive kind of land with specific soil and physical characteristics that

differ from other kinds of land in its ability to produce a distinctive kind and amount of

vegetation and its ability to respond similarly to management actions and natural

disturbances. Lands are classified considering discrete physical and biotic factors.

Physical factors include soils, climate, hydrology, geology, and physiographic features.

Biotic factors include plant species occurrence, plant community compositions, annual

biomass production, wildlife-vegetation interactions, and other factors. Ecological

dynamics, primarily disturbance regimes, such as grazing; fire; drought; management

actions; and all resulting interactions are also a primary factor of ecological sites.

Information and data pertaining to a particular ecological site is organized into a

reference document known as an ESD. ESDs function as a primary repository of

ecological knowledge regarding an ecological site. ESDs are maintained on the NRCS

Ecological Site Information System (ESIS), which is the repository for information

associated with ESDs and the collection of all site data

(https://esis.sc.egov.usda.gov/Welcome/pgESDWelcome.aspx). The ESD can help

interpret if a site’s potential is less than or greater than the identified habitat objectives.

 In addition to the references identified in the following table, the Conservation Plans

developed for each of the Wyoming Local Sage-Grouse Working Groups will be

consulted to identify specific habitat objectives appropriate for site-specific conditions.

The Conservation Plans, updated in March 2014, are available on the Wyoming Game
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-28 Chapter 2: Resource Management Alternatives

and Fish Department (WGFD) website at: https://wgfd.wyo.gov/web2011/wildlife1000817.aspx. 

 All BLM use authorizations would contain terms and conditions regarding the actions

needed to meet or progress toward meeting the habitat objectives. If monitoring data

show the habitat objectives have not been met nor progress being made towards

meeting them, there would be an evaluation and a determination made as to the cause.

If it is determined that the authorized use is a cause, the use would be adjusted by the

response specified in the instrument that authorized the use.

Table 2.3 Billings Field Office Greater Sage-Grouse Habitat Objectives

ATTRIBUTE INDICATORS DESIRED 

CONDITION REFERENCE

Breeding, Nesting, and Early Brood-Rearing (Seasonal Use Period: March 1 – June 15)

Lek Security

Proximity of trees .65– Km2 (.388 

miles) avoidance of 

coniferous habitats

Doherty, K.E. 2008. Sage-grouse and 

Energy Development: Integrating Science 

with Conservation Planning to Reduce 

Impacts. (Doctoral dissertation, the 

University of Montana (Missoula). 

Available at: 

http://etd.lib.umt.edu/theses/available/etd03262009-

132629/unrestricted/doherty.pdf 

Collision Risks

Fences and other 

structures that pose a 

high collision risk 

are absent or 

mitigated with visual 

markers within 1.25 

miles of leks active 

within 5 years.

Connelly et al. 2000

Stevens 2011

Sage‐Grouse Habitat Assessment 

Framework, Multi-scale Habitat 

Assessment Tool (unpublished report). 

August 2010. BLM, Idaho State Office. 

Boise.

Proximity of 

sagebrush to leks

Adjacent protective 

sagebrush cover 

within 100 m (328 

ft.) of an active lek

Sage‐Grouse Habitat Assessment 

Framework, Multi-scale Habitat 

Assessment Tool (unpublished report). 

August 2010. BLM, Idaho State Office. 

Boise.

Cover

% of seasonal habitat 

meeting desired 

conditions

80% of the nesting 

habitat within 3.1 

miles of sage-grouse 

leks meets the 

recommended 

vegetation 

characteristics, 

where appropriate 

(relative to 

ecological site 

potential, etc.)

Knick, S.T. and J.W. Connelly, 2011. 

Greater Sage-grouse, Ecology and 

Conservation of a Landscape Species and 

its Habitats. Studies in Avian Biology 

No. 38. A Publication of the Cooper 

Ornithological Society, University of 

California Press. Berkeley. pp. 1–9.

Stiver, S. J., E. T. Rinkes, D. E. Naugle, 

2010. Sage-Grouse Habitat Assessment 

Framework. U.S. Bureau of Land 

Management, Idaho State Office, Boise, 

Idaho. 

Sagebrush canopy 

cover

5-25%

Herman – Brunson, K.M. 2007.

Swanson, C.C. 2009.

Doherty, K.E., Naugle, D.E., Walker, 

B.L. 2010

Hagen, C.A., Connelly, J.W., Schroedeer, 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-29

ATTRIBUTE INDICATORS DESIRED 

CONDITION REFERENCE

M.A. 2007

Doherty, K.E., Beck, J.L., Naugle, D.E. 

2011.

USDA, NRCS, Montana, Ecological Site 

Descriptions. Accessed January 28, 2014.

Foster, M.A, Ensign, J.T., Davis, W.N., 

Tribby, D.C. 2014.

Wright, P and Wegner, D. 2008

Lane , V.R. 2005

Sagebrush height 6-31 inches (15-

50cm)

Schroeder et al. 1999.

Swanson, C.C. 2009.

Holloran, M.J., Heath, B.J., Lyon, A.G. 

2005. Doherty, K.E., Beck, J.L., Naugle, 

D.E. 2011

USDA, NRCS, Montana, Ecological Site 

Descriptions. Accessed January 28, 2014.

Lane , V.R. 2005

Predominant 

sagebrush shape

Predominately 

spreading shape

Stiver, S. J., E. T. Rinkes, D. E. Naugle, 

2010.

Perennial grass cover ≥10%

Doherty, K.E., Beck, J.L., Naugle, D.E. 

2011.

USDA, NRCS, Montana, Ecological Site 

Descriptions. Accessed January 28, 2014.

Holloran, M.J., Heath, B.J., Lyon, A.G. 

2005

Doherty, K.E., Naugle, D.E., Walker, 

B.L. 2010

Hagen, C.A., Connelly, J.W., Schroedeer, 

M.A 2007

Lane, V.R. 2005

Perennial grass and 

forb height

Adequate nest cover 

based on ecological 

site potential and 

seasonal 

precipitation; 4.4-

11.3 inches (11.4-29 

cm)

K.E. Doherty, K.E. Naugle, J.D. Tack, 

B.L.Walker, J.M.Graham and J.L. Beck.

2014

Perennial forb canopy 

cover

≥3%

Doherty, K.E., Beck, J.L., Naugle, D.E. 

2011.

USDA, NRCS, Montana, Ecological Site 

Descriptions. Accessed January 28, 2014.

Holloran, M.J., Heath, B.J., Lyon, A.G. 

2005.

Doherty, K.E., Naugle, D.E., Walker, 

B.L. 2010.

Hagen, C.A., Connelly, J.W., Schroedeer, 

M.A. 2007

Brood-Rearing/Summer 1(Seasonal Use Period: June 16 – October 31)

Cover

% of Seasonal habitat 

meeting desired 

condition

>40% of the broodrearing/summer 

habitat meets 

recommended brood 

habitat 

Stiver, S. J., E. T. Rinkes, D. E. Naugle, 

2010. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-30 Chapter 2: Resource Management Alternatives

ATTRIBUTE INDICATORS DESIRED 

CONDITION REFERENCE

characteristics where 

appropriate, relative 

to site potential and 

seasonal 

precipitation.

Sagebrush canopy 

cover

5-25%

Herman – Brunson, K.M. 2007.

Swanson, C.C. 2009.

Doherty, K.E., Naugle, D.E., Walker, 

B.L. 2010

Doherty, K.E., Beck, J.L., Naugle, D.E. 

2011.

USDA, NRCS, Montana, Ecological Site 

Descriptions. Accessed January 28, 2014.

Foster, M.A., Ensign, J.T., Davis, W.N., 

Tribby, D.C., 2014.

Lane , V.R. 2005

Sagebrush height 6-31 inches (15-

50cm)

Schroeder et al. 1999

Holloran, M.J., Heath, B.J., Lyon, A.G. 

2005

Doherty, K.E., Beck, J.L., Naugle, D.E. 

2011.

USDA, NRCS, Montana, Ecological Site 

Descriptions. Accessed January 28, 2014.

Lane , V.R. 2005

Perennial grass and 

forb canopy cover ≥10%

Doherty, K.E., Beck, J.L., Naugle, D.E. 

2011.

Holloran, M.J., Heath, B.J., Lyon, A.G. 

2005.

Doherty, K.E., Naugle, D.E., Walker, 

B.L. 2010

Hagen, C.A., Connelly, J.W., Schroedeer, 

M.A. 2007

USDA, NRCS, Montana, Ecological Site 

Descriptions. Accessed January 28, 2014.

Riparian areas/mesic 

meadows

Proper Functioning 

Condition

BLM, 1997c.

Prichard, D., F. Berg, S. Leonard, M. 

Manning, W. Hagenbuck, R. Krapf, C. 

Noble, J. Staats, and R. Leinard. 1999.

Prichard, D., 1998

Upland and riparian 

perennial forb 

availability

Preferred forbs are 

common with 

several preferred 

species present.

Stiver, S. J., E. T. Rinkes, D. E. Naugle,

2010

Doherty, K.E., Beck, J.L., Naugle, D.E. 

2011.

USDA, NRCS, Montana, Ecological Site 

Descriptions. Accessed January 28, 2014.

Winter 1(Seasonal Use Period: November 1 – February 28)

Cover and Food

% of seasonal habitat 

meeting desired 

conditions

>80% of wintering 

habitat meets winter 

habitat 

characteristics where 

appropriate (relative 

to ecological site, 

etc.).

Stiver, S. J., E. T. Rinkes, D. E. Naugle, 

2010.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-31

ATTRIBUTE INDICATORS DESIRED 

CONDITION REFERENCE

Sagebrush canopy 

cover

≥10%

Schroeder et al. 1999.

Swanson, C.C. 2009.

Foster, M.A, Ensign, J.T., Davis, W.N., 

Tribby, D.C. 2014.

Sagebrush height ≥25cm Connelly et al. 2000

Actions 

 Assist in the restoration, reintroduction, augmentation, or re-establishment of T & E,

special status, and priority species and other populations and (or) habitats in

coordination with other agencies.

 Identify distribution, key habitat areas, and special management needs for development

of management plans and conservation measures, consistent with restoration,

conservation and recovery plans for threatened, endangered, and other special status

species. Priority habitats are riparian/ wetland areas, native grasslands, sagebrush

steppe, conifer forests, and seasonal ranges supporting life cycle requirements for

wildlife (i.e., winter, breeding, parturition, etc.).

 Fences identified as barriers to wildlife movement on BLM-administered lands would

be modified or removed to accommodate wildlife passage, unless the fences were built

specifically to keep native ungulates out of an area. Fences would also be placed and

marked, or modified, to reduce wildlife collisions or entanglements.

 Conditions of Approval (COAs) would be applied to all Applications for Permit to Drill

(APDs) for Special Status Species.

 Utilize appropriate offsite compensatory mitigation to reduce impacts to wildlife

habitat. This would be necessary if (1) all onsite mitigation has been accomplished and

adverse effects have not been mitigated; or (2) if onsite mitigation is not feasible. Off –

site mitigation would be applied as close to the affected area as possible and for the

same or similar impacted species or habitats.

 Areas that would be targeted for conversion from crested wheatgrass to native

sagebrush/grasslands would be areas that have high wildlife habitat potential,

particularly for Greater Sage-Grouse, big game, and other sagebrush obligate species,

and are currently monocultures with little vegetation diversity.

 Mitigation of surface-disturbing or disrupting activities (including operations and

maintenance associated with fluid mineral development) would be applied where

needed to minimize impacts of human activities on important seasonal wildlife habitats,

consistent with the wildlife stipulations outlined in the Wildlife / Special Status Species

and Fluid Minerals sections of Chapter 2. Mitigation measures would be applied during

activity level planning if an on-site evaluation of the project area indicates the presence

of important wildlife species.

 Exceptions may be granted by the authorized officer, if an environmental review

demonstrates that effects could be mitigated to an acceptable level, habitat for the

species is not present in the area, or portions of the area can be occupied without

affecting a particular species. Exceptions may also be granted where the short-term

effects are mitigated by the long-term benefits (e.g., prescribed fire, wildlife monitoring,

or forest health treatments).
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 As defined in the Glossary, surface-disturbing and disruptive activities would not

prohibit all activities or authorized uses. For example, emergency activities (e.g., fire

suppression, search and rescue), rangeland monitoring, routine maintenance associated

with an approved authorization, dispersed recreational activities (e.g., hunting, hiking),

and livestock grazing are not considered surface-disturbing or disruptive activities.

 Surface occupancy and use is prohibited (NSO) in crucial winter range (antelope, elk,

moose, bighorn sheep, mule deer, whitetail deer, and greater sage-grouse).

 Timing restrictions would be used in special status species habitat. Surface disturbing

and disruptive activities that impact special status species habitats during their seasons

of use, particularly during critical life cycles would be avoided or minimized.

 Lease Notice: Oil and gas surface occupancy and use is subject to the following

operating constraints:

 The lease area may now or hereafter contain plants, animals, or their habitats

determined to be threatened, endangered, or other special status species. BLM may

recommend modifications to exploration and development proposals to further its

conservation and management objective to avoid BLM approved activity that would

contribute to a need to list such a species or their habitat. BLM may require

modifications to or disapprove proposed activity that is likely to result in jeopardy to the

continued existence of a proposed or listed threatened or endangered species or result in

the destruction or adverse modification of a designated or proposed critical habitat.

BLM would not approve any ground-disturbing activity that may affect any such

species or critical habitat until it completes its obligations under applicable

requirements of the Endangered Species Act as amended, 16 U.S.C. § 1531 et seq.,

including completion of any required procedure for conference or consultation.

Greater Sage-Grouse: 

 Surface occupancy and use is prohibited within Greater sage-grouse crucial winter

range (NSO).

 The BLM would apply appropriate mitigation measures and conservation actions to

BLM authorized activities to avoid, minimize, rectify, reduce, or compensate for

impacts if an evaluation of the project area indicates the presence of important wildlife

species, seasonal wildlife habitat, or other resource concern.

 In all sage-grouse habitat, in undertaking BLM management actions, and consistent

with valid existing rights and applicable law, in authorizing third-party actions that

result in habitat loss and degradation, the BLM would require and ensure mitigation that

provides a net conservation gain to the species including accounting for any uncertainty

associated with the effectiveness of such mitigation. This would be achieved by

avoiding, minimizing, and compensating for impacts by applying beneficial mitigation

actions. Actions which result in habitat loss and degradation” include those identified as

threats which contribute to Greater Sage-Grouse disturbance as identified by the U.S.

Fish and Wildlife Service in its 2010 listing decision (75 FR 13910) and shown in Table

2 in the attached Monitoring Framework (Appendix AA, section B).

 If the 3% anthropogenic disturbance cap is exceeded on lands (regardless of land

ownership) within GRSG PHMAs in any given Biologically Significant Unit, then no

further discrete anthropogenic disturbances (subject to applicable laws and regulations,

such as the 1872 hard rock mining law, valid existing rights, etc.) would be permitted
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-33

by BLM within GRSG PHMAs in any given Biologically Significant Unit until the 

disturbance has been reduced to less than the cap. 

 If the 3% anthropogenic disturbance cap is exceeded on lands (regardless of land

ownership) or if anthropogenic disturbance and habitat loss associated with conversion

to agricultural tillage or fire exceed 5% within a project analysis area in PHMAs, then

no further discrete anthropogenic disturbances (subject to applicable laws and

regulations, such as the 1872 Mining Law, valid existing rights, etc.) would be

permitted by BLM within PHMA in a project analysis area until the disturbance has

been reduced to less than the cap. If the BLM determines that the State of Montana has

adopted a GRSG Habitat Conservation Program that contains comparable components

to those found in the State of Wyoming’s Core Area Strategy including an all lands

approach for calculating anthropogenic disturbances, a clear methodology for

measuring the density of operations, and a fully operational Density Disturbance

Calculation Tool, the 3% disturbance cap would be converted to a 5% cap for all

sources of habitat alteration within a project analysis area.

 Subject to applicable laws and regulations and valid existing rights, if the average

density of one energy and mining facility per 640 acres (the density cap) is exceeded on

all lands (regardless of land ownership) in the Priority Habitat Management Area within

a proposed project analysis area, then no further disturbance from energy or mining

facilities would be permitted by BLM: (1) until disturbance in the proposed project

analysis area has been reduced to maintain the limit under the cap; or (2) unless the

energy or mining facility is co-located into an existing disturbed area.

 In undertaking BLM management actions, and consistent with valid and existing rights

and applicable law in authorizing third-party actions, the BLM would apply the lek

buffer-distances identified in the USGS Report Conservation Buffer Distance Estimates

for Greater Sage-Grouse – A Review (Open File Report 2014-1239) in accordance with

Appendix AA (section G).

GRSG PHMA: to maintain or improve Greater Sage-Grouse populations by maintaining 

Greater Sage-Grouse habitat in good condition. 

 Establish Greater Sage-Grouse PHMAs (158,926 acres of BLM-administered lands and

60,569 acres of federal minerals). These PHMAs are generally consistent with MTFWP

Greater Sage-Grouse core area designations, with the exception of one small area in

southern Carbon County near Elk Basin Oil field (Map 23).

 Open to fluid mineral leasing and development (including geophysical exploration).

 To protect Greater Sage-grouse, a priority species for management, surface occupancy

and use would be prohibited within Greater Sage-Grouse Priority Habitat Management

Areas (NSO).

 Exclusion area for renewable and solar energy exploration and facility development.

 Avoidance area for major and minor ROWs.

 However ROWs would only be allowed in GRSG PHMAs where habitat functionality

would be maintained.

 In all Priority Habitat Management Areas, the desired condition is to maintain a

minimum of 70% of lands capable of producing sagebrush with 10 to 30% sagebrush

canopy cover. The attributes necessary to sustain these habitats are described in

Interpreting Indicators of Rangeland Health (BLM Tech Ref 1734-6).*

* Footnote: 70% of the lands capable of producing that level will be
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Proposed Resource Management Plan and Final Environmental Impact Statement 

2-34 Chapter 2: Resource Management Alternatives

 In undertaking BLM management actions, and consistent with valid and existing rights

and applicable law in authorizing third-party actions, the BLM would apply the lek

buffer-distances identified in the USGS Report Conservation Buffer Distance Estimates

for Greater Sage-Grouse – A Review (Open File Report 2014-1239) in accordance with

Appendix AA (section G).

 No waivers or modifications to a fluid mineral lease no-surface-occupancy stipulation

would be granted. The Authorized Officer may grant an exception to a fluid mineral

lease no-surface-occupancy stipulation only where the proposed action:

i. Would not have direct, indirect, or cumulative effects on GRSG or its habitat;

or,

ii. Is proposed to be undertaken as an alternative to a similar action occurring on a

nearby parcel, and would provide a clear conservation gain to GRSG.

 Exceptions based on conservation gain (ii) may only be considered in (a) PHMAs of

mixed ownership where federal minerals underlie less than fifty percent of the total

surface, or (b) areas of the public lands where the proposed exception is an alternative

to an action occurring on a nearby parcel subject to a valid Federal fluid mineral lease

existing as of the date of this RMP revision. Exceptions based on conservation gain

must also include measures, such as enforceable institutional controls and buffers,

sufficient to allow the BLM to conclude that such benefits would endure for the

duration of the proposed action’s impacts.

 Any exceptions to this lease stipulation may be approved by the Authorized Officer

only with the concurrence of the State Director. The Authorized Officer may not grant

an exception unless the applicable state wildlife agency, the USFWS, and the BLM

unanimously find that the proposed action satisfies (i) or (ii). Such finding shall

initially be made by a team of one field biologist or other GRSG expert from each

respective agency. In the event the initial finding is not unanimous, the finding may be

elevated to the appropriate BLM State Director, USFWS State Ecological Services

Director, and state wildlife agency head for final resolution. In the event their finding is

not unanimous, the exception would not be granted. Approved exceptions would be

made publically available at least quarterly.

GRSG Restoration Areas: In these areas, BLM would manage habitat so that Greater SageGrouse populations can be restored over the long-term. BLM would strive to restore historical 

Greater Sage-Grouse habitat functionality, or at a minimum, have no net loss of Greater SageGrouse habitat, to support Greater Sage-Grouse populations. 

 Establish RAs (78,927 acres of BLM-administered lands and 22,951 acres of federal

mineral estate). These areas would include one small polygon of core habitat in Carbon

County near Elk Basin Oil Field, as well as other areas (Map 23).

 Surface occupancy and use for oil and gas exploration and development would be

prohibited within 0.6 miles of Greater Sage-Grouse leks (NSO).

 Surface use for oil and gas exploration and development would be prohibited from

March 1 to June 15 in Greater Sage-Grouse nesting habitat within 3 miles of a lek (TL).

 Surface occupancy and use for oil and gas exploration and development would be

subject to the following special operating constraints that would maintain Greater SageGrouse habitat: surface disturbance density and mitigation plan (CSU).
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-35

 Geophysical exploration would be allowed on existing roads and trails with surface use

prohibited from March 1 to June 15 within 4 miles of a lek (TL).

 GRSG Restoration Areas outside of Elk Basin would be avoidance areas for renewable

and solar energy exploration, development and facilities with approved mitigation.

 The Elk Basin GRSG Restoration Area would be an avoidance area for renewable and

solar energy exploration, development and facilities with approved mitigation.

 Avoidance area for major and minor ROWs.

 However ROWs would only be allowed in GRSG RAs where habitat functionality

would be maintained.

GRSG GHMA: BLM would maintain habitat for viable Greater Sage-Grouse populations to 

promote movement and genetic diversity. Maintain, restore or enhance Greater Sage-Grouse 

habitat and connectivity between sagebrush habitats, with emphasis on those habitats occupied 

by Greater Sage-Grouse. 

 Establish General Habitat Management Areas (113,816 acres of BLM-administered

lands and 57,420 acres of federal mineral estate). These areas include a 3 mile buffer

around Greater Sage-Grouse leks, outside of the PHMA and RA areas (Map 23).

 Surface occupancy and use for oil and gas exploration and development would be

prohibited within 0.6 miles of the perimeter of Greater Sage-Grouse leks (NSO).

 To protect nesting Greater Sage-grouse, surface occupancy and use within 2 miles of a

lek may be restricted or prohibited. Prior to such activities, a plan to mitigate impacts to

nesting Greater Sage-grouse and Greater Sage-grouse nesting habitat would be prepared

by the proponent and implemented upon approval by the authorized officer (CSU).

 Geophysical exploration would be allowed on existing roads and trails with surface use

prohibited from March 1 to June 15 within 3 miles of a lek (TL).

 Avoidance area for renewable and solar energy exploration, development and facilities

with approved mitigation.

 GRSG GHMAs would be avoidance areas for major ROWs.

 GRSG GHMAs would be open to minor ROWs.

o Utilities and similar facilities would be located adjacent to other facilities where

practical and only when habitat can be maintained.

 In undertaking BLM management actions, and consistent with valid and existing rights

and applicable law in authorizing third-party actions, the BLM would apply the lek

buffer-distances identified in the USGS Report Conservation Buffer Distance Estimates

for Greater Sage-Grouse – A Review (Open File Report 2014-1239) in accordance with

Appendix AA (section G).

2.3.10.4.6 Fire Ecology and Management 

Goals and Objectives

 Manage wildfire and fuels for the protection of public health, safety, property, and

resource values

 Maintain desired mix of seral stages within vegetation communities, including desert

shrublands, forest and woodlands, grasslands, mountain shrublands, sagebrush (all subspecies), riparian/wetlands and aspen.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-36 Chapter 2: Resource Management Alternatives

 Utilize an integrated management technique unless otherwise restricted (defined as

prescribed fire, mechanical, chemical, or biological, followed by desired reseeding) to

reduce fuels to protect high priority areas or resource values.

Actions 

 Fuels treatments would be designed to protect or improve resource values

 Due to resource management constraints and considerations (i.e. Greater Sage-Grouse

habitat, other identified T&E issues and culturally sensitive areas), there are

approximately 14,000 acres available for restoring natural Fire Regime Condition

Classes in Musselshell, Stillwater, Carbon, and Sweet Grass Counties

 If prescribed fire is used in Greater Sage-Grouse habitat, the NEPA analysis for the

Burn Plan would address:

o why alternative techniques were not selected as a viable options;

o how Greater Sage-Grouse goals and objectives would be met by its use;

o how the COT Report objectives would be addressed and met;

o a risk assessment to address how potential threats to Greater Sage-Grouse

habitat would be minimized.

a) Prescribed fire as a vegetation or fuels treatment shall only be considered after the

NEPA analysis for the Burn Plan has addressed the four bullets outlined above.

Prescribed fire could be used to meet specific fuels objectives that would protect

Greater Sage-Grouse habitat in PHMAs (e.g., creation of fuel breaks that would

disrupt the fuel continuity across the landscape in stands where annual invasive

grasses are a minor component in the understory, burning slash piles from conifer

reduction treatments, used as a component with other treatment methods to combat

annual grasses and restore native plant communities).

b) Prescribed fire in known winter range shall only be considered after the NEPA

analysis for the Burn Plan has addressed the four bullets outlined above. Any

prescribed fire in winter habitat would need to be designed to strategically reduce

wildfire risk around and/or in the winter range and designed to protect winter range

habitat quality.”

 Heavy equipment would not be used to construct fire lines in crucial winter range,

habitat of candidate or special status species, riparian/wetlands or in areas of cultural

resource sensitivity or other designated areas (e.g., ACECs, WSAs). Exceptions would

be permitted for protection of human life, property and/or to protect resource values

from further loss due to unwanted/unplanned natural or human caused wildland fires.

 Cultural Resource Specialists, Wildlife Biologists, or Resource Advisors would be

consulted for locations of identified areas before use of or anticipated use of heavy

equipment.

 If heavy equipment is used, rehabilitation work on lines would begin immediately after

containment.

 Heavy equipment could be used in a WSA only if the exceptions in the nonimpairment standards are met.

 Prescribed fire would be allowed on up to 5 percent of the percent of BLM

administered acres within the planning area to achieve measurable landscape level

objectives from (1) other resources, including, but not limited to, forestry, wildlife,

range, vegetation, and watershed; (2) the reduction of hazardous fuels; and (3) the

introduction of fire into fire-adapted ecosystems.
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-37

 Within Greater Sage-Grouse PHMAs and RAs, only treatments that conserve, enhance,

or restore Greater Sage-Grouse habitat would be allowed.

 Treatment methods, including prescribed burning and mechanical treatments would be

used to eliminate conifer encroachment and stimulate vegetative re-growth in

grassland/shrub land habitats; and to reduce fuels, thin under-stories, recycle nutrients,

and create small openings in forested vegetation types.

 A fire risk assessment would be completed for implementation of prescribed fire in

relation to GRSG goals and objectives.

 When prescribed fire is used for vegetation treatments, the burn plan would clearly

indicate how COT objectives would be addressed and met by use of prescribed fire and

why alternative techniques for vegetation treatment were not selected.

2.3.10.4.7 Energy and Mineral Resources – Coal 

Actions

 Terms and conditions would be applied to mining activities to meet land health

standards for uplands, riparian areas and wetlands, water quality, air quality, and native

plant and animal species (see BMPs in Appendix B and Greater Sage-Grouse Appendix

AA).

 Within Greater Sage-Grouse PHMAs (Map 178) (including the Alternative B Greater

Sage-Grouse Habitat ACEC) and RAs solid mineral leasing (coal) would only be

allowed with the following lease stipulations:

o Mining may only occur via sub-surface methods

o All mine related appurtenant facilities would be placed outside of the Priority

Habitat Areas

 Remainder of Planning Area: Process lease by application (LBAs) for new coal leases

by applying the coal screening process to the application. The coal screening process

results would determine which lands may be available for further consideration for coal

leasing and development. Appropriate NEPA analysis would be required prior to

leasing. The existing RMP (BLM 1984) coal-screening management decisions are

current and relevant to the application area. (See Appendix M)

 At the time an application for a new coal lease or lease modification is submitted to the

BLM, the BLM would determine whether the lease application area is "unsuitable" for

all or certain coal mining methods pursuant to 43 CFR 3461.5. PHMA is essential

habitat for maintaining GRSG for purposes of the suitability criteria set forth at 43 CFR

3461.5(o)(1).

2.3.10.4.8 Energy and Mineral Resources – Fluid Minerals 

Goals and Objectives 

Priority would be given to leasing and development of fluid mineral resources, including 

geothermal, outside of PHMA and GHMA. When analyzing leasing and authorizing 

development of fluid mineral resources, including geothermal, in PHMA and GHMA, and 

subject to applicable stipulations for the conservation of Greater Sage-Grouse, priority would

be given to development in non-habitat areas first and then in the least suitable habitat for 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

2-38 Chapter 2: Resource Management Alternatives

Greater Sage-Grouse (Map 171). The implementation of these priorities would be subject to 

valid existing rights and any applicable law or regulation, including, but not limited to, 30 

U.S.C. 226(p) and 43 C.F.R. 3162.3-1(h). 

Where a proposed fluid mineral development project on an existing lease could adversely affect 

GRSG populations or habitat, the BLM would work with the lessees, operators, or other project 

proponents to avoid, reduce and mitigate adverse impacts to the extent compatible with lessees' 

rights to drill and produce fluid mineral resources. The BLM would work with the lessee, 

operator, or project proponent in developing an APD for the lease to avoid and minimize 

impacts to sage-grouse or its habitat and would ensure that the best information about the 

GRSG and its habitat informs and helps to guide development of such Federal leases. 

Actions

 Where the federal government owns the mineral estate in PHMAs and GHMAs, and the

surface is in non-federal ownership, apply the same stipulations, COAs, and/or

conservation measures and RDFs applied if the mineral estate is developed on BLMadministered lands in that management area, to the maximum extent permissible under

existing authorities, and in coordination with the landowner.

 Where the federal government owns the surface and the mineral estate is in non-federal

ownership in PHMA and GHMA, apply appropriate surface use COAs, stipulations, and

mineral RDFs through ROW grants or other surface management instruments, to the

maximum extent permissible under existing authorities, in coordination with the

mineral estate owner/lessee.

2.3.10.4.9 Energy and Mineral Resources – Locatable Minerals 

The BLM goals and objectives for energy and mineral resources (locatable minerals) is to allow 

the development of minerals in a manner that prevents degradation of sensitive resources and 

landscapes. The management actions below identify varying degrees of proposed development 

by identifying public lands that would be unavailable for locatable mineral development. (Map 

174) 

Actions 

 Terms and conditions would be applied to mining activities (within the constraints of

the mining law) to meet land health standards for uplands, riparian and wetlands, water

quality, air quality, and native plant and animal species (see Appendices H and AA) for

Greater Sage-Grouse specific measures). Note: All withdrawal actions (including

mineral withdrawals) are processed in the Realty, Cadastral Survey, and Lands

program.

2.3.10.4.10 Energy and Mineral Resources – Mineral Materials 

(Saleable) 

Provide land-use opportunities contributing to economic benefits and meet local infrastructure 

needs while protecting or minimizing adverse impacts to other resources and resource uses. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-39

Actions 

The following areas are closed to mineral material disposals (281,597 acres) (Maps 65 & 179):

 Four Dances ACEC 

 Petroglyph Canyon ACEC 

 Pompeys Pillar NM and ACEC 

 Pryor Foothills RNA/ACEC 

 Stark Site ACEC 

 Weatherman Draw ACEC 

 Lands with wilderness characteristics 

 Big Horn Tack-On WSA 

 Burnt Timber Canyon WSA 

 Pryor Mountain WSA 

 Twin Coulee WSA. (If Twin Coulee WSA is released from further consideration, the 

area may be open to mineral material disposals.) 

 Greater Sage-Grouse PHMAs - closed to new salable minerals sales; existing permits 

would be renewed with no increase in the permitted boundary. However, these areas 

remain “open” to free use permits and the expansion of existing active pits, only if the 

following criteria are met: 

o the activity is within the BSU and project area disturbance cap; 

o the activity is subject to the provisions set forth in the mitigation framework 

[Appendix AA, sections E and F];

o all applicable required design features are applied; and [if applicable] the 

activity is permissible under the specific sub-regional screening criteria 

 Shepherd Ah-Nei Recreation Area 

 Acton Recreation Area 

 Asparagus Point

2.3.10.4.11 Realty, Cadastral Survey, and Lands – Land Tenure 

Adjustment and Access 

The goals and objectives of land tenure adjustment and access would be to retain public lands 

with high resource values in public ownership, as well as provide for adjustments in land 

ownership to consolidate public land holdings, acquire lands with high public resource values, 

and meet public and community needs. All proposed land ownership adjustment actions would 

be considered at project specific environmental reviews. 

Actions

 Lands classified as priority habitat and general habitat (or habitat classification 

appropriate for the sub-region) for Greater Sage-Grouse would be retained in federal 

management unless: (1) the agency can demonstrate that disposal of the lands would

provide a net conservation gain to the Greater Sage-Grouse or (2) the agency can 

demonstrate that the disposal of the lands would have no direct or indirect adverse 

impact on conservation of the Greater Sage-Grouse. (Map 172) 

 Manage 353,829 acres in Category II (which includes GRSG habitat)- 

Retention/Limited Land Ownership Adjustment (no land disposals through direct sale). 

Land exchanges would be considered 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

2-40 Chapter 2: Resource Management Alternatives

2.3.10.4.12 Realty, Cadastral Survey, and Lands – Rights-of-Way, 

Leases, and Permits 

The BLM goals for the management of Rights-of-Way (ROW), leases, and permits within the 

Billings Field Office are to protect resources while meeting transportation and ROW needs in 

the planning area. To accomplish this, the Billings Field Office proposes to implement a variety 

of management activities that allow to various land actions or authorizations, with a range of 

restrictions based on resource concerns to help meet the goals and objectives of other resources. 

Actions 

 Avoidance area for major and minor ROWs. (Maps 175, 176) 

o However ROWs would only be allowed in GRSG PHMAs where habitat 

functionality would be maintained. 

 Avoidance area for major and minor ROWs. (Maps 175, 176) 

o However ROWs would only be allowed in GRSG RAs where habitat 

functionality would be maintained. 

 GRSG GHMAs would be avoidance areas for major ROWs. 

 GRSG GHMAs would be open to minor ROWs. 

o Utilities and similar facilities would be located adjacent to other facilities where 

practical and only when habitat can be maintained. 

 Silver Tip Road in Carbon County would be designated as a ROW corridor (1,750 feet 

on either side of the center line of Silver Tip Road). This corridor would have a total 

width of 3,500 feet and 6 miles in length on public land, with the exception of the 

portion of this corridor occurring in the Elk Basin GRSG Restoration Area which 

would be 1,320 feet on either side of the center line of Silver Tip Road (total width of 

2,640 feet) (Map 78 and 177).

 ROW avoidance areas would include 378,958 acres (Map 71): 

o Castle Butte ACEC 

o East Pryor ACEC 

o Four Dances ACEC 

o Grove Creek ACEC Pompeys Pillar ACEC (Zone C - restricts ROW to a 500’ 

wide path paralleling the southern boundary of the public lands along Highway 

312) 

o Pryor Foothills RNA/ACEC 

o Stark Site ACEC Weatherman Draw (expansion area) 

o Cave and karst areas would be managed as ROW avoidance areas. 

o L&CNHT and NPNHT corridors would managed as ROW avoidance areas 

o Asparagus Point, Steamboat Butte, portion of Acton, portion of Shepherd AhNei, Bad Canyon, East and Red Pryor Mountains 

o Hoskins Basin Archeological District, Demi-John Flat Archeological District, 

Beartooth Mountain Front (2 mile strip bordering the eastern boundary of the 

Custer National Forest) 

o WSR eligible segments 

o Big Horn Sheep Winter Range 

o Big Game Winter Range 

o Greater Sage-Grouse GHMA 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-41

o Greater Sage-Grouse PHMAs and RAs would remain avoidance areas. 

However ROWs would only be allowed in Greater Sage-Grouse PHMAs and 

RAs where habitat functionality would be maintained. 

2.3.10.4.13 Realty, Cadastral Survey, and Lands – Withdrawals 

Actions 

 Withdrawal proposals would be evaluated at the project level and would not be 

approved unless the land management is consistent with maintaining and protecting 

BLM resource values (see BMP (Appendix B) and GRSG (Appendix AA) Appendices 

as appropriate). 

2.3.10.4.14 Livestock Grazing 

Provide opportunities for livestock grazing as a part of multiple-use in a manner that meets 

and/or exceeds rangeland health standards. 

Actions 

 In areas of resource conflicts, installation of structural range improvements would only 

be considered where grazing practices (change in season of use, reduction of AUMs, 

increased rest, etc.) are unable to resolve the resource concern. Structural range 

improvements could be considered where necessary to facilitate the change in grazing 

management practices. Existing range improvements would be evaluated and modified 

to address impacts on wildlife populations (e.g. Greater Sage-Grouse/fence conflicts). 

 All allotments wholly located in Greater Sage-Grouse PHMAs would be considered for 

retirement, where the base property owner relinquishes their preference. 

 Site specific Greater Sage-Grouse habitat and management objectives would be 

developed for BLM land within Greater Sage-Grouse Priority Habitat Management 

Areas. These objectives would be incorporated into the respective allotment 

management plans or livestock grazing permits as appropriate. (Map 173) 

 The NEPA analysis for renewals and modifications of livestock grazing permits/leases 

that include lands within PHMAs would include specific management thresholds based 

on GRSG Habitat Objectives Table (Table 2.3 ) and Land Health Standards (43 CFR 

4180.2) and one or more defined responses that would allow the authorizing officer to 

make adjustments to livestock grazing that have already been subjected to NEPA 

analysis. 

 Priority Allotments for monitoring and evaluation would be allotments which: 

o Are not meeting standards for rangeland health 

o Contain special status species habitat (including Greater Sage-Grouse PHMAs / 

RAs) 

o Contain impaired streams 

o Contain non-functional or functioning at risk downward trend riparian areas. 

o Contain invasive plant species. 

o Allotments that have established and implemented management plans during the 

life of the plan. 

 The BLM would prioritize (1) the review of grazing permits/leases, in particular to 

determine if modification is necessary prior to renewal, and (2) the processing of 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

2-42 Chapter 2: Resource Management Alternatives

grazing permits/leases in PHMAs. In setting workload priorities, precedence would be 

given to existing permits/leases in these areas not meeting Land Health Standards, with 

focus on those containing riparian areas, including wet meadows. The BLM may use 

other criteria for prioritization to respond to urgent natural resource concerns (ex., fire) 

and legal obligations. 

 The NEPA analysis for renewals and modifications of livestock grazing permits/leases 

that include lands within PHMAs would include specific management thresholds based 

on GRSG Habitat Objectives Table (Table 2.3 ) and Land Health Standards (43 CFR 

4180.2) and ecological site potential, and one or more defined responses that would

allow the authorizing officer to make adjustments to livestock grazing that have already 

been subjected to NEPA analysis. 

 Allotments within PHMAs, and focusing on those containing riparian areas, including 

wet meadows, would be prioritized for field checks to help ensure compliance with the 

terms and conditions of the grazing permits. Field checks could include monitoring for 

actual use, utilization, and use supervision. 

 At the time a permittee or lessee voluntarily relinquishes a permit or lease, the BLM 

would consider whether the public lands where that permitted use was authorized 

should remain available for livestock grazing or be used for other resource management 

objectives, such as reserve common allotments or fire breaks. 

2.3.10.4.15 Recreation and Visitor Services 

Actions

 In PHMA, do not construct new recreation facilities (e.g., campgrounds, trails, 

trailheads, staging areas) unless the development would have a net conservation gain to 

GRSG habitat (such as concentrating recreation, diverting use away from critical areas, 

etc.), or unless the development is required for visitor health and safety or resource 

protection 

 The BLM would issue special recreation use permits as appropriate for commercial, 

competitive, and special events subject to guidelines in BLM Handbook 2930, resource 

capabilities, social conflict concerns, professional qualifications, public safety, and 

public needs. SRPs would only be allowed in priority habitat if they are consistent with 

the goals and objectives for that habitat or species. 

2.3.10.4.16 Trails and Travel Management 

Actions 

 Site specific travel planning within Greater Sage-Grouse PHMAs would be completed 

within a five (5) year period after the ROD is signed where it hasn’t already been 

completed as part of this plan. 

 In PHMA and GHMA, temporary closures would be considered in accordance with 43 

CFR subpart 8364 (Closures and Restrictions); 43 CFR subpart 8351 (Designated 

National Area); 43 CFR subpart 6320 (Use of Wilderness Areas, Prohibited Acts, and 

Penalties); 43 CFR subpart 8341 (Conditions of Use). 

 Temporary closure or restriction orders under these authorities are enacted at the 

discretion of the authorized officer to resolve management conflicts and protect persons, 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-43

property, and public lands and resources. Where an authorized officer determines that 

off-highway vehicles are causing or would cause considerable adverse effects upon soil, 

vegetation, wildlife, wildlife habitat, cultural resources, historical resources, threatened 

or endangered species, wilderness suitability, other authorized uses, or other resources, 

the affected areas shall be immediately closed to the type(s) of vehicle causing the 

adverse effect until the adverse effects are eliminated and measures implemented to 

prevent recurrence. (43 CFR 8341.2) A closure or restriction order should be 

considered only after other management strategies and alternatives have been explored. 

The duration of temporary closure or restriction orders should be limited to 24 months 

or less; however, certain situations may require longer closures and/or iterative 

temporary closures. This may include closure of routes or areas. 

Gage Dome/Colony Road TMA: 

Management Objectives: reduce road density to minimize impacts to Greater Sage-Grouse 

habitat and other resource values. Manage the TMA to provide recreational opportunities and 

access while protecting Greater Sage-Grouse habitat 

Cottonwood/Weatherman Draw TMA: 

This area would be delineated into three sub-regions to address varying resource issues, access 

and recreational opportunities. 

Sub-Region I - Weatherman Draw/Castle Coulee. Management objectives: protect cultural 

values and resources within the ACEC. Minimize impacts to cultural values, fragile and erosive 

soils and other resources within the sub-region 

Sub-Region II - Hollenbeck. Management objectives: provide recreational opportunities with 

emphasis on minimizing impacts to Greater Sage-Grouse habitat, fragile and erosive soils, and 

other resource values 

Sub-Region III - Silver Tip. Management objectives: provide for motorized recreational 

opportunities with emphasis on minimizing impacts to fragile and erosive soils, and other 

resource values 

Warren TMA: 

TMA Management Objectives: to provide recreational opportunities with emphasis on 

protecting key Greater Sage-Grouse habitat while minimizing impacts to other resources 

values. Maintain current level of access. 

Grove Creek TMA: 

Management Objectives: to minimize impacts to geologic and visual resources, special status 

plants, and cultural and wildlife values, including Greater Sage-Grouse, while providing casual, 

non-commercial public recreational access. 

2.3.10.4.17 Renewable Energy (Wind/Solar) 

Actions 

Manage 231,755 acres as exclusion areas (closed) to renewable energy authorizations, 

including: 

 WSAs* 

o Big Horn Tack-On WSA 

o Burnt Timber Canyon WSA 

o Pryor Mountain WSA 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

2-44 Chapter 2: Resource Management Alternatives

o Twin Coulee WSA 

 *If released by an Act of Congress, lands within WSA boundaries would 

remain closed. 

 National Historic Trails 

o Nez Perce NHT 

o Lewis & Clark NHT 

 Pompeys Pillar NM 

 ACECs 

o Bridger Fossil Area ACEC 

o Castle Butte ACEC 

o East Pryor ACEC 

o Four Dances ACEC 

o Grove Creek ACEC 

o Meeteetse Spires ACEC 

o Petroglyph Canyon ACEC 

o Pompeys Pillar ACEC 

o Pryor Foothills RNA ACEC 

o Stark Site ACEC 

o Weatherman Draw ACEC 

 Wild and Scenic River Eligible/Suitable Segments 

 Lands with wilderness characteristics 

 Pryor Mountain Wild Horse Range (PMWHR) 

 Cultural Sites 

o Steamboat Butte 

o Bruder-Janich Site 

o Paul Duke Site 

o Demi-John Flat NR District 

o Bighorn Mouth North Cliffs Rock Art Site 

o Hoskins Basin Archaeological District 

 VRM Class I areas 

 Greater Sage-Grouse PHMAs 

 Elk Basin GRSG Restoration Area 

Manage 200,278 acres as avoidance areas for renewable energy authorizations, subject to 

special stipulations and mitigation beyond standard stipulations and BMPs applied through sitespecific analysis. 

Special stipulations and mitigation include provisions such as timing limitations, controlled 

surface use, and other constraints/restrictions consistent with fluid minerals stipulations that 

would be applied to protect the following particular resources/habitats: 

 Greater Sage-Grouse GHMAs 

 Greater Sage-Grouse Restoration Areas outside of Elk Basin 

 Bald/Golden Eagles 

 Ferruginous Hawks 

 Greater Sage-Grouse Winter Range 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-45

 Big Game Winter Range 

 Big Game Parturition 

 Bighorn Sheep Habitat 

 Sharp-tailed grouse 

 Peregrine Falcon 

 Mountain Plover 

 Raptor Nests 

 Other avoidance areas include: 

 Asparagus Point, Steamboat Butte, Portion of Acton, Portion of Shepherd Ah-Nei, Bad 

Canyon, East and Red Pryor Mountains, 

 Cave and Karst areas 

 VRM Class II areas 

 Within 1⁄4 mile of riparian areas and wetlands, designated 100 year flood plains and on 

water bodies and streams, unless activities are not in conflict with desired outcomes. 

 Surface disturbance on slopes >30%, soils with low reclamation potential, and highly 

erodible characteristics would be avoided whenever possible. If disturbance could not 

be avoided an approved mitigation and reclamation plan would be required prior to 

activities taking place. 

 Timing limitations apply to development of facilities, but not to operation or 

maintenance. 

2.3.10.5 Adaptive Management Strategy for Greater Sage-Grouse Habitat 

Management 

Adaptive Management is a decision process that promotes flexible resource management 

decision making that can be adjusted in the face of uncertainties as outcomes from management 

actions and other events become better understood. Careful monitoring of these outcomes both 

advances scientific understanding and helps with adjusting resource management directions as 

part of an iterative learning process. Adaptive management also recognizes the importance of 

natural variability in contributing to ecological resilience and productivity. It is not a ‘trial and 

error’ process, but rather emphasizes learning while doing. Adaptive management does not 

represent an end in itself, but rather a means to more effective decisions and enhanced benefits. 

On February 1, 2008, the DOI published its Adaptive Management Implementation Policy (522 

DM 1). The adaptive management strategy presented within this EIS complies with this policy 

and direction. 

In relation to the BLM’s National Greater Sage-grouse Planning Strategy, adaptive 

management would help identify if sage-grouse conservation measures presented in this EIS 

contain the needed level of certainty for effectiveness. Principles of adaptive management 

would be incorporated into the conservation measures in the plan to ameliorate threats to a 

species, thereby increasing the likelihood that the conservation measure and plan would be 

effective in reducing threats to that species. The following provides the BLM adaptive 

management strategy for the Billings and Pompeys Pillar National Monument Proposed RMP 

and Final EIS. 
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2-46 Chapter 2: Resource Management Alternatives

Adaptive Management and Monitoring 

This EIS contains a monitoring framework plan (Appendix AA (section A) that includes an 

effectiveness monitoring component. The agencies intend to use the data collected from the 

effectiveness monitoring to identify any changes in habitat conditions related to the goals and 

objectives of the plan and other range-wide conservation strategies (U.S. Department of the 

Interior 2004; Stiver et al. 2006; U.S. Fish and Wildlife Service 2013). The information 

collected through the Monitoring Framework Plan outlined in Appendix AA would be used by 

the BLM to determine when adaptive management hard and soft triggers (discussed below) are 

met. The GRSG adaptive management plan provides regulatory assurance that a means of 

addressing and responding to unintended negative impacts to greater sage-grouse and its habitat 

before consequences become severe or irreversible. 

2.3.10.6 Montana Greater Sage-Grouse Adaptive Management Plan 

The Greater Sage-Grouse adaptive management plan provides regulatory assurance that 

unintended negative impacts to Greater Sage-Grouse habitat would be addressed before 

consequences become severe or irreversible. This adaptive management plan: 

 utilizes science based soft and hard adaptive management triggers, and 

 addresses multiple scales of data 

Adaptive Management Triggers

Adaptive management triggers are essential for identifying when potential management 

changes are needed in order to continue meeting Greater Sage-Grouse conservation objectives. 

The BLM would use soft and hard triggers. 

A Biologically Significant Unit (BSU) is the summary of all the Priority Habitat Management 

Areas within a Greater Sage-Grouse population as delineated in the COT report. The BSU for 

Management Zone 1 (MZ1) are those PHMAs in the northern half of the Billings Field Office 

(see map 184). The BSU for Management Zone 2 (MZ2) are those PHMAs in the southern half 

of the Billings Field Office (Carbon County) (see map 184). 

Soft Triggers: 

Soft triggers are indicators that management or specific activities may not be achieving the 

intended results of conservation action. The soft trigger is any negative deviation from normal 

trends in habitat or population in any given year, or if observed across two to three consecutive 

years. Metrics include, but are not limited to, annual lek counts, wing counts, aerial surveys, 

habitat monitoring, and DDCT evaluations. BLM field offices, local Montana Fish, Wildlife 

and Parks (FWP) offices, and sage-grouse working groups would evaluate the metrics. The 

purpose of these strategies is to address localized Greater Sage-Grouse population and habitat 

changes by providing the framework in which management would change if monitoring 

identifies negative population and habitat anomalies. 

Each major project (EIS level) would include adaptive management strategies in support of the 

population management objectives for Greater Sage-Grouse set by the State of Montana, and 

would be consistent with this Greater Sage-Grouse Adaptive Management Plan. These adaptive 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-47

management strategies would be developed in partnership with the State of Montana, project 

proponents, partners, and stakeholders, incorporating the best available science. 

Soft Triggers Response: 

Soft triggers require immediate monitoring and surveillance to determine causal factors and 

may require curtailment of activities in the short- or long-term, as allowed by law. The project 

level adaptive management strategies would identify appropriate responses where the project’s 

activities are identified as the causal factor. The management agency (BLM and/or FS) and the 

adaptive management group would implement an appropriate response strategy to address 

causal factors not addressed by specific project adaptive management strategies, not 

attributable to a specific project, or to make adjustments at a larger regional or state-wide level. 

Hard Triggers: 

Hard triggers are indicators that management is not achieving desired conservation results. 

Hard triggers would be considered an indicator that the species is not responding to 

conservation actions, or that a larger-scale impact is having a negative effect. 

Hard triggers are focused on three metrics: 1) number of active leks, 2) acres of available 

habitat, and 3) population trends based on annual lek counts. 

Within the context of normal population variables, hard triggers shall be determined to take 

effect when two of the three metrics exceeds 60% of normal variability for the area under 

management in a single year, or when any of the three metrics exceeds 40% of normal 

variability for a three year time period within a five-year range of analysis. A minimum of three 

years is used to determine trends, with a five- year period preferred to allow determination of 

three actual time periods (Y1-2-3, Y2-3-4, Y3-4-5). Baseline population estimates are 

established by pre-disturbance surveys, reference surveys and account for regional and 

statewide trends in population levels. Population count data in Montana are maintained by 

Montana Fish, Wildlife, and Parks (FWP). Estimates of population are determined based upon 

survey protocols determined by FWP, and are implemented consistently throughout the state. 

Population counts are tracked for individual leks and are then summarized for each Priority 

Habitat Management Area (PHMA). 

Hard Trigger Response: 

Hard triggers represent a threshold indicating that immediate action is necessary to stop a 

severe deviation from GRSG conservation objectives set forth in the BLM plans. As such, the 

Proposed Plan Amendment/Final EIS includes a “hard-wired” plan-level response; that is, it 

provides that, upon reaching the trigger, a more restrictive alternative, or an appropriate 

component of a more restrictive alternative analyzed in the EIS would be implemented without 

further action by the BLM. Specific “hard-wired” changes in management are identified in 

Table 2.4 Specific Management Responses In addition to the specific changes identified in 

Table 2.4 , the BLM would review available and pertinent data, in coordination with GRSG 

biologists and managers from multiple agencies including the FWS, NRCS, and the State of 

Montana, to determine the causal factor(s) and implement a corrective strategy. The corrective 

strategy would include the changes identified in Table 2.4 , and could also include the need to 

amend or revise the RMP to address the situation and modify management accordingly. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-48 Chapter 2: Resource Management Alternatives

Following the NPT Adaptive Management Guidance and Sideboards, when a hard trigger is hit 

in a BSU, the designated response will be put in place in that BSU. Triggers and responses 

have been developed with local, state, and USFWS experts. 

When a hard trigger is hit in a BSU, including those that cross state lines, the WAFWA 

Management Zone Greater Sage-Grouse Conservation Team would convene to determine the 

causal factor, put project level responses in place, as appropriate and discuss further appropriate 

actions to be applied. The team will also investigate the status of the hard triggers in other 

BSUs within the PAC and will invoke the appropriate plan response (BSU for this Proposed 

RMP/Final EIS is the total of all the PHMA within a GRSG population as delineated in the 

COT report). Adoption of any further actions at the plan level may require initiating a plan 

amendment process. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

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Table 2.4 Specific Management Responses

Program Adaptive Management Response1

Sage-Grouse 

Management

Areas within and adjacent to PHMA where a hard 

trigger has been reached would be the top priority for 

regional mitigation habitat restoration and fuels 

reduction treatments.

Vegetation 

Management

PHMA would be the top priority for regional 

mitigation, habitat restoration and fuels reduction 

treatments.

Wildland Fire 

Management

Reassess GRSG habitat needs to determine if priorities 

for at risk habitats, fuels management areas, 

preparedness, suppression and restoration have 

changed.

Livestock Grazing

For areas not achieving the GRSG habitat objectives 

due to grazing, apply adjustments to livestock grazing 

to achieve objectives. 

Rights of Way –

Existing Corridors

Retain the corridors as mapped, but limit the size of 

new lines within the corridors to same as existing 

structures, or not larger than 138kV.

Wind Energy 

Development

No change from Proposed Plan.

Industrial Solar No change from Proposed Plan.

Comprehensive 

Travel and 

Transportation 

Management

If travel management planning has not been completed 

within GRSG habitat, PHMA areas where the hard 

trigger was met would be the highest priority for 

future travel management planning efforts.

If travel management has been completed within 

GRSG habitat in the PHMA where the hard trigger 

was met, re-evaluate designated routes to determine 

their effects on GRSG. If routes are found to be 

causing population-level impacts, revise their 

designation status to reduce the effect.

Fluid Minerals No change from Proposed Plan.

Locatable Minerals No change from Proposed Plan.

Salable Minerals No change from Proposed Plan.

Nonenergy Leasable 

Minerals

No change from Proposed Plan.

In addition to implementing the hard wired plan-level response, in the event that new scientific 

information becomes available demonstrating that the hard wired response would be 

insufficient to stop a severe deviation from sage grouse conservation objectives set forth in the 

BLM plans, the BLM would immediately implement a formal directive to protect GRSG and 

its habitat and to ensure that conservation options are not foreclosed. To the extent that it is 

supported scientifically, this formal directive would be drawn from the range of alternatives 

analyzed in the RMP Revision. 
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2.3.10.7Monitoring for the Greater Sage-grouse Habitat Management

BLM’s planning regulations, specifically 43 CFR 1610.4-9, require that land use plans 

establish intervals and standards for monitoring based on the sensitivity of the resource 

decisions. Land use plan monitoring is the process of tracking the implementation of land use 

plan decisions (implementation monitoring) and collecting data/information necessary to 

evaluate the effectiveness of land use plan decisions (effectiveness monitoring). For GRSG, 

these types of monitoring are also described in the criteria found in the Policy for Evaluation of 

Conservation Efforts When Making Listing Decisions (50 CFR Vol. 68, No. 60). One of the 

Policy for Evaluation of Conservation Efforts When Making Listing Decisions criteria 

evaluates whether provisions for monitoring and reporting progress on implementation (based 

on compliance with the implementation schedule) and effectiveness (based on evaluation of 

quantifiable parameters) of the conservation effort are provided. 

A guiding principle in the BLM National Sage-grouse Conservation Strategy (US Department 

of the Interior 2004) is that “the Bureau is committed to sage-grouse and sagebrush 

conservation and would continue to adjust and adapt our National Sage-grouse Strategy as new 

information, science, and monitoring results evaluate effectiveness over time.” In keeping with 

the WAFWA Sage-grouse Comprehensive Conservation Strategy (Stiver et al. 2006) and the 

Greater Sage-grouse Conservation Objectives: Final Report (USFWS 2013), the BLM and 

Forest Service would monitor implementation and effectiveness of conservation measures in 

GRSG habitats. 

On March 5, 2010, USFWS’ 12-Month Findings for Petitions to List the Greater Sage-Grouse 

(Centrocercus urophasianus) as Threatened or Endangered were posted as a Federal Register 

notice (75 Federal Register 13910-14014, March 23, 2010). This notice stated: 

“...the information collected by BLM could not be used to make broad generalizations about

the status of rangelands and management actions. There was a lack of consistency across the 

range in how questions were interpreted and answered for the data call, which limited our 

ability to use the results to understand habitat conditions for sage-grouse on BLM lands.”

Standardization of monitoring methods and implementation of a defensible monitoring 

approach (within and across jurisdictions) would resolve this situation. The BLM, Forest 

Service, and other conservation partners use the resulting information to guide implementation 

of conservation activities. 

Monitoring strategies for GRSG habitat and populations must be collaborative, as habitat 

occurs across jurisdictional boundaries (52 percent on BLM-administered lands, 31 percent on 

private lands, 8 percent on National Forest System lands, 5 percent on state lands, 4 percent on 

tribal and other federal lands) (75 Federal Register 13910, March 23, 2010), and state fish and 

wildlife agencies have primary responsibility for population level wildlife management, 

including population monitoring. Therefore, population efforts would continue to be conducted 

in partnership with state fish and wildlife agencies. The BLM and Forest Service have finalized 

a monitoring framework, which can be found in Appendix AA (section B). This framework 

describes the process that the BLM and Forest Service would use to monitor implementation 

and effectiveness of RMP/LUP decisions. The monitoring framework includes methods, data 
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standards, and intervals of monitoring at broad and mid scales; consistent indicators to measure 

and metric descriptions for each of the scales; analysis and reporting methods; and the 

incorporation of monitoring results into adaptive management. The need for fine-scale and sitespecific habitat monitoring may vary by area depending on existing conditions, habitat 

variability, threats, and land health. Indicators at the fine and site scales would be consistent 

with the Habitat Assessment Framework; however, the values for the indicators could be 

adjusted for regional conditions. 

More specifically, the framework discusses how the BLM and Forest Service would monitor 

and track implementation and effectiveness of planning decisions (e.g., tracking of waivers, 

modifications, site-level actions). The two agencies would monitor the effectiveness of 

RMP/LUP decisions in meeting management and conservation objectives. Effectiveness 

monitoring would include monitoring disturbance in habitats, as well as landscape habitat 

attributes. To monitor habitats, the BLM and Forest Service would measure and track attributes 

of occupied habitat, priority habitat, and general habitat at the broad scale, and attributes of 

habitat availability, patch size, connectivity, linkage/connectivity habitat, edge effect, and 

anthropogenic disturbances at the mid-scale. Disturbance monitoring would measure and track 

changes in the amount of sagebrush in the landscape and changes in the anthropogenic 

footprint, including change energy development density. The framework also includes 

methodology for analysis and reporting for field offices, states, ranger districts, BLM districts, 

National Forests, and Forest regions, including geospatial and tabular data for disturbance 

mapping (e.g., geospatial footprint of new permitted disturbances) and management actions 

effectiveness. 

The monitoring data would provide the indicator estimates for adaptive management. The BLM 

would adjust management decisions through an adaptive management process. 

2.3.10.8 Regional Mitigation for the Greater Sage-grouse Habitat 

Management 

Consistent with the proposed plan’s goal outlined in [Table 2.10 through Table 2.13], the intent 

of the Billings and Pompeys Pillar National Monument Proposed RMP and Final EIS is to 

provide a net conservation gain to the species. To do so, in undertaking BLM management 

actions, and, consistent with valid existing rights and applicable law, in authorizing third party 

actions that result in habitat loss and degradation, the BLM would require and ensure 

mitigation that provides a net conservation gain to the species including accounting for any 

uncertainty associated with the effectiveness of such mitigation. Actions which result in habitat 

loss and degradation” include those identified as threats which contribute to Greater SageGrouse disturbance as identified by the U.S. Fish and Wildlife Service in its 2010 listing 

decision (75 FR 13910) and shown in Table 2 in the attached Monitoring Framework 

(Appendix AA, section B). This would be achieved by avoiding, minimizing, and 

compensating for impacts by applying beneficial mitigation actions. This is also consistent with 

BLM Manual 6840 – Special Status Species Management, Section .02B, which states “to 

initiate proactive conservation measures that reduce or eliminate threats to Bureau sensitive 

species to minimize the likelihood of the need for listing of these species under the ESA.”
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Proposed Resource Management Plan and Final Environmental Impact Statement 

2-52 Chapter 2: Resource Management Alternatives

Mitigation 

Mitigation Standards: In undertaking BLM management actions, and, consistent with valid 

existing rights and applicable law, in authorizing third party actions that result in habitat loss 

and degradation, the BLM would require and ensure mitigation that provides a net conservation 

gain to the species including accounting for any uncertainty associated with the effectiveness of 

such mitigation. Actions which result in habitat loss and degradation” include those identified 

as threats which contribute to Greater Sage-Grouse disturbance as identified by the U.S. Fish 

and Wildlife Service in its 2010 listing decision (75 FR 13910) and shown in Table 2 in the 

attached Monitoring Framework (Appendix AA, section B). This would be achieved by 

avoiding, minimizing, and applying compensatory mitigation for impacts by applying 

beneficial mitigation actions. Mitigation would follow the regulations from the White House 

Council on Environmental Quality (CEQ) (40 CFR 1508.20; e.g. avoid, minimize, and 

compensate), hereafter referred to as the mitigation hierarchy. If impacts from BLM 

management actions and authorized third party actions that result in habitat loss and 

degradation remain after applying avoidance and minimization measures (i.e. residual impacts), 

then compensatory mitigation projects would be used to provide a net conservation gain to the 

species. Any compensatory mitigation would be durable, timely, and in addition to that which 

would have resulted without the compensatory mitigation (see the concepts of durability, 

timeliness, and additionality as described further in Appendix AA, section D). 

 

Greater Sage-Grouse Conservation Team 

The BLM would establish a WAFWA Management Zone Greater Sage-Grouse Conservation 

Team (hereafter, Team) to help guide the conservation of greater sage-grouse, within 90 days 

of the issuance of the Record of Decision. This Team would develop a WAFWA Management 

Zone Regional Mitigation Strategy (hereafter, Regional Mitigation Strategy). The Team would

also compile and report on monitoring data (including data on habitat condition, population 

trends, and mitigation effectiveness) from States across the WAFWA Management Zone (see 

Monitoring section). Subsequently, the Team would use these data to either modify the 

appropriate Regional Mitigation Strategy or recommend adaptive management actions (see 

Adaptive Management section). 

The BLM would invite governmental and Tribal partners to participate in this Team, including 

the State Wildlife Agency and U.S. Fish and Wildlife Service, in compliance with the 

exemptions provided for committees defined in the Federal Advisory Committee Act and the 

regulations that implement that act. The BLM would strive for a collaborative and unified 

approach between Federal agencies (e.g. FWS, BLM, and USFS), Tribal governments, state 

and local government(s), and other stakeholders for greater sage-grouse conservation. The 

Team would provide advice, and would not make any decisions that impact Federal lands. The 

BLM would remain responsible for making decisions that affect Federal lands. 

Developing a Regional Mitigation Strategy 

The Team would develop a Regional Mitigation Strategy to inform the mitigation components 

of NEPA analyses for BLM management actions and third party actions that result in habitat 

loss and degradation. The Strategy would be developed within one year of the issuance of the 

Record of Decision. The BLM’s Regional Mitigation Manual MS-1794 would serve as a 

framework for developing the Regional Mitigation Strategy. The Regional Mitigation Strategy 
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Chapter 2: Resource Management Alternatives 2-53

would be applicable to the States/Field Offices/Forests within the WAFWA Management 

Zone’s boundaries. 

Regional mitigation is a landscape-scale approach to mitigating impacts to resources. This 

involves anticipating future mitigation needs and strategically identifying mitigation sites and 

measures that can provide a net conservation gain to the species. The Regional Mitigation 

Strategy developed by the Team would elaborate on the components identified above (i.e. 

avoidance, minimization, and compensation; additionality, timeliness, and durability) and 

further explained in Appendix AA (section E). 

In the time period before the Strategy is developed, BLM would consider regional conditions, 

trends, and sites, to the greatest extent possible, when applying the mitigation hierarchy and 

would ensure that mitigation is consistent with the standards set forth in the first paragraph of 

this section. 

Incorporating the Regional Mitigation Strategy into NEPA Analyses 

The BLM would include the avoidance, minimization, and compensatory recommendations 

from the Regional Mitigation Strategy in one or more of the NEPA analysis’ alternatives for 

BLM management actions and third party actions that result in habitat loss and degradation and 

the appropriate mitigation actions would be carried forward into the decision. 

Implementing a Compensatory Mitigation Program 

Consistent with the principles identified above, the BLM need to ensure that compensatory 

mitigation is strategically implemented to provide a net conservation gain to the species, as 

identified in the Regional Mitigation Strategy. In order to align with existing compensatory 

mitigation efforts, this compensatory mitigation program would be implemented at a State-level 

(as opposed to a WAFWA Management Zone, a Field Office, or a Forest), in collaboration with 

our partners (e.g. Federal, Tribal, and State agencies). 

To ensure transparent and effective management of the compensatory mitigation funds, the 

BLM would enter into a contract or agreement with a third-party to help manage the State-level 

compensatory mitigation funds, within one year of the issuance of the Record of Decision. The 

selection of the third-party compensatory mitigation administrator would conform to all 

relevant laws, regulations, and policies. The BLM would remain responsible for making 

decisions that affect Federal lands. 

2.4 Alternatives Considered But Not Analyzed in Detail 

The following alternative(s) were considered, but not carried forward for detailed analysis 

because (1) they would not fulfill requirements of the Federal Land Policy and Management 

Act (FLPMA) or other existing laws or regulations, (2) they did not meet the purpose and need, 

(3) they were already part of an existing plan, policy, or administrative function, or (4) they did 

not fall within the limits of the planning criteria. The FLPMA requires the BLM to manage the 

public lands and resources in accordance with the principles of multiple use and sustained 

yield, including recognizing the Nation’s needs for domestic sources of minerals, food, timber, 

and fiber. Moreover, the BLM is required by law to recognize existing valid rights on public 
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2-54 Chapter 2: Resource Management Alternatives

lands and manage public lands in accordance with existing laws (see Appendix A), including 

but not limited to, the General Mining Law of 1872 and the Mining and Minerals Policy Act of 

1970. 

2.4.1 Eliminate Livestock Grazing from BLM public lands 

An alternative that proposes to make the entire Billings Field Office unavailable for grazing 

would not meet the purpose and need of this RMP/EIS. The NEPA requires that agencies study, 

develop, and describe appropriate alternatives to recommended courses of action in any 

proposal that involves unresolved conflicts concerning alternative uses of available resources. 

No issues or conflicts have been identified during this land use planning effort that requires the 

complete elimination of grazing within the planning area for their resolution and, in the absence 

of such conflicts, such an alternative would be inconsistent with the multiple-use policy 

objectives of the planning area. Where appropriate, removal of livestock and adjustments to 

livestock use has been incorporated in this planning effort. Because the BLM has considerable 

discretion through its grazing regulations to determine and adjust stocking levels, seasons-ofuse, and grazing 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. Additional 

consideration for not fully analyzing a No Grazing Alternative is described below. 

A majority of the Billings RMP planning area is located in the northern portion of the Great 

Plains Ecoregion (U.S. Environmental Protection Agency 2010) and the rangelands in the 

planning area are classified as mixed-grass prairie. 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). There 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 (Grasslands National Park Management Plan 2001). 

From 1956 through 1972, the BLM conducted a classification of public lands to estimate the 

amount of available forage within these planning areas. These are typically referred to as the 

“Missouri River Basin Surveys”. From this effort, multiple sub-basin reports were generated, 

which provided the carrying capacities by Animal Unit Months (AUMs) for all BLM lands at 

the time of survey. 

The measurement of the available forage for livestock grazing was conducted by trained 

professionals and involved intensive vegetation sampling (clipping, weighing, and ocular 

estimation). The BLM, in cooperation with grazing advisory boards, used the information to 

make adjustments to the AUMs allocated to a grazing permit. This cooperative effort resulted 

in implementation of appropriate changes to grazing permits in the planning areas. These 

changes were implemented in a timely manner and completed prior to 1975. 

These historical grazing allocations were included in the 1984 RMP and are carried forward in 

the current analysis. Validation of the historical forage allocations occurs on a periodic basis 

which coincides with the renewal of each ten year grazing permit. This periodic review has 

resulted in the suspension of 7,746 AUMs, from a total permitted use of 62,619 AUMs (12.3% 
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Chapter 2: Resource Management Alternatives 2-55

reduction). This periodic review has also resulted in the site specific environmental analysis of 

a “No Grazing” alternative on 106 allotments.

Resource conditions on the BLM-administered public lands in the planning area, including 

range vegetation, watershed, and wildlife habitat, do not warrant prohibition of livestock 

grazing throughout the planning area. Of the 370 allotments managed by the Billings Field 

Office, 83.5% of the allotments that have been assessed (309,658 acres) meet the Standards for 

Rangeland Health (see Table 3-17) and 9.1% of the allotments assessed (41,153 acres) are 

making significant progress towards meeting the Standards for Rangeland Health. Only 11 

allotments (3,835 acres total) are not meeting Standards for Rangeland Health or are not 

making significant progress towards meeting these Standards. Of the 11 allotments that are not 

currently meeting the Standards (with livestock having been determined as the causal factor for 

nine of the allotments), changes to the grazing systems have already been implemented on eight 

allotments. Of the remaining three allotments, substandard conditions are a result of factors 

other than livestock grazing on two and the lease on the third allotment has expired and the 

permittee has yet to apply for renewal. Further reduction or elimination of livestock grazing 

could become necessary in specific situations where livestock grazing causes or contributes to 

conflicts with the protection and/or management of other resource values or uses. Such 

determinations would be made during site-specific activity planning and associated 

environmental analysis (106 site-specific environmental analyses completed to date). These 

determinations would be based on several factors, including monitoring studies, current range 

management science, input from livestock operators and the interested public, and the ability of 

particular allotments to meet the Standards for Rangeland Health. Acres not available for 

permitted livestock use for the life of the plan range from 37,408 acres (Alt A), 38,373 acres 

(Alt B), 28,622 acres (Alt C), to 28,387 acres (Alt D). 

In accordance with BLM’s Land Use Planning Handbook and BLM IM No. 2012-169, BLM 

considered a range of alternatives with respect to both areas that are available or unavailable for 

livestock grazing and the amount of forage allocated to livestock on an area-wide basis. The 

analysis considers a range of alternatives necessary to address unresolved conflicts among 

available resources and includes a meaningful reduction in livestock grazing across the 

alternatives, both through reduction in areas available to livestock grazing and forage 

allocation. 

The BLM developed a range of alternatives that sharply defines the issues and provides a clear 

basis for choice among options by the decision-maker. The BLM analyzed closing a range of 

33,334 to 135,645 acres to sheep and goat grazing and closing a range of 28,387 to 38,373 

acres to all livestock grazing, where the BLM identified unresolved conflicts concerning 

various uses of available resources such as between livestock grazing and recreation, ACECs, 

Wilderness Study Areas, and Pryor Mountain Wild Horse Range. 

Suitable measures, which could include reduction or elimination of livestock grazing, are 

provided for in this RMP/EIS, which could become necessary in specific situations where 

livestock grazing causes or contributes to conflicts with the protection and/or management of 

other resource values or uses. Such determinations would be (and have been) made during sitespecific activity planning or permit renewal and their associated environmental review (106 

completed to date, whereby a ‘no grazing’ alternative has been analyzed). These 
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2-56 Chapter 2: Resource Management Alternatives

determinations would be based on several factors, including monitoring studies, review of 

current range management science, input from livestock operators and interested parties, and 

ability to meet the Standards for Rangeland Health and Guidelines for Livestock Grazing 

Management. 

Livestock grazing is and has been an important use of the public lands in the planning area for 

many years, and is a continuing government program. The CEQ guidelines for compliance with 

NEPA require that agencies analyze the “No Action Alternative” in all EISs (40 CFR 

1502.14(d)). For the purposes of this NEPA analysis, the “no action alternative” is to continue 

the status quo, which includes livestock grazing. For this reason and those stated above, a no 

grazing alternative for the entire planning area was dismissed from detailed consideration in 

this RMP/EIS. 

The scattered pattern of land ownership in the planning area would require extensive fencing to 

eliminate livestock use from public lands. In some cases, maintenance of fences along public 

property boundaries would be very difficult due to steep terrain features. Additionally, the 

extensive fencing would create many new barriers for wildlife movements increasing habitat 

fragmentation. 

Finally, the alternatives analyzed in detail do include various considerations for eliminating or 

maximizing individual resource values or uses in specific areas where conflicts exist. For these 

reasons, the BiFO dismissed a no grazing alternative for the entire planning area from further 

consideration in this RMP/EIS. 

2.4.2 OHV Rock Crawl Area Proposed in Petroglyph Canyon 

An OHV Rock Crawl Area in Petroglyph Canyon ACEC was proposed during the 2009 travel 

management meetings. This proposal is not being analyzed in the Billings and Pompeys Pillar 

National Monument RMP/EIS under any alternative for the following reasons: 

1) It would not be compatible with the current ACEC designation. The 1999 ACEC 

Amendment Record of Decision states that the Petroglyph Canyon area (240 

acres) would be closed to OHV use. 

2) The rock art is fragile and vibrations from vehicles can cause rock spalling 

(causing irreversible damage the rock art). The dust caused by OHVs (or other 

vehicles) can build up on the petroglyphs and cause erosion damage as dust gets 

incorporated into the petroglyph and causes the rock art to fade. 

3) The resource damage related to vehicle use in a sensitive area such as 

Petroglyph Canyon includes long-lasting vehicle scars upon the land, loss of 

soils and vegetation, gullying, deflation of cultural deposits, deplacement and 

damage to artifacts and geologic features, and others. 

4) In addition, motorized public access directly to a cultural site (including rock art 

sites such as this) leads to a higher potential for vandalism and destruction of the 

cultural resource. In addition, the staging area required for the rock crawl area 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-57

(driving off the existing road into the canyon) would create visual scars, damage 

to the fragile soil resources and could lead to a proliferation of user-created 

routes in the area. 

2.4.3 Steamboat Butte ACEC Proposal 

During the 90-day public comment period on the Draft Billings and Pompeys Pillar National 

Monument RMP/EIS, a comment was received proposing Steamboat Butte as an Area of 

Critical Environmental Concern for cultural values. 

Steamboat Butte was considered as an ACEC during the 1998 ACEC amendment, but either 

did not meet relevance or importance or did not need special management and as a result was 

not analyzed as part of the 1998 ACEC amendment. In the Fall of 2013, Steamboat Butte was 

reevaluated for relevance and importance. It met relevance, but not importance and as a result 

is not recommended to be considered for ACEC nomination (see Appendix E). 

2.4.4 Sykes Ridge ACEC Proposal 

During the 2008 public scoping for the Billings and Pompeys Pillar National Monument 

RMP/EIS, a proposal was received for an area of critical environmental concern (ACEC) on 

Sykes Ridge for special status plants. 

As proposed the Sykes Ridge ACEC area was determined to be located entirely within the 

existing East Pryor ACEC and within the Pryor Mountain Wild Horse Range. In addition, 

portions of the proposed Sykes Ridge ACEC were determined to be located within a WSA. 

After careful review and consideration, it was determined no new special management was 

needed to protect special status plants on Sykes Ridge. (See Appendix E for rationale and 

evaluation of this nomination).

2.4.5 Conservation Groups Alternative 

During the range-wide scoping effort for Greater Sage-Grouse, several conservation 

organizations submitted scoping comments and proposed management actions and alternatives 

for Greater Sage-Grouse conservation (referred to here as the Conservation Groups 

Alternative). In summary, the primary intent of these proposed alternatives and management 

actions was to: (1) add additional measures (beyond those conservation measures identified in 

the National Technical Team (NTT) report (disseminated by BLM WO-IM-2012-044) in order 

to maintain and increase Greater Sage-Grouse abundance and, (2) designate two additional 

habitat types – Greater Sage-Grouse Areas of Critical Environmental Concern (ACECs) and 

“restoration” habitat areas. 

These proposed actions and alternatives submitted by these organizations were determined to 

be substantially similar to those actions and habitat areas considered within the range of 

alternatives in this DRMP/EIS. As described in the Wildlife and Special Status Species section 

in Chapter 2, this DRMP/EIS delineates three types of Greater Sage-Grouse habitat areas as 

part of the planning process (refer to maps/sections here), including: Greater Sage-Grouse 

Habitat - Priority Habitat Management Areas (PHMAs), Greater Sage-Grouse Habitat - 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

2-58 Chapter 2: Resource Management Alternatives

Restoration Areas (RAs), and Greater Sage-Grouse Habitat – General Habitat Management 

Areas (GHMAs). Varying degrees of management is considered and analyzed as part of the 

range of alternatives within each of these habitat delineations in this DRMP/EIS in order to 

achieve the goals or objectives for each Greater Sage-Grouse habitat area, as well as address 

the conservation measures and management practices to conserve Greater Sage-Grouse 

consistent with the NTT report. Additionally, this DRMP/EIS includes Mitigation Measures 

and Conservation Actions for Greater Sage-Grouse (Appendix AA, section F). The appendix 

identifies best practices, design features and proactive management activities to conserve 

Greater Sage-Grouse that would be applied during project specific activities through 

subsequent environmental review and analysis. 

Specific to the organization’s proposed alternative to designate Greater Sage-Grouse ACECs 

and ‘restoration’ areas, this DRMP/EIS does include, within the range of alternatives for 

detailed study, a Greater Sage-Grouse ACEC (Alternative B) and restoration areas for Greater 

Sage-Grouse. Table 2.5 provides a summary of the range of acreages for priority, general, and 

restoration habitat for Greater Sage-Grouse and Table 2.10 provides a summary of the range of 

alternatives for Greater Sage-Grouse (e.g., allowable uses, constraints, etc.). This range of 

alternatives is adequate to compare impacts to Greater Sage-Grouse from different conservation 

measures as well as the size of habitat classifications. 

In summary, the additional alternatives and actions proposed through the Conservation Groups 

Alternative were considered but eliminated from detailed study from this RMP revision 

because the range of alternatives adequately addresses conservation measures for Greater SageGrouse. For example, the alternatives range from open to fluid mineral leasing and right-ofway development, to a no-lease stipulation for new oil and gas development and exclusion 

areas for rights-of-way 

2.5 Summary of Alternatives Considered in Detail 

This section summarizes the four alternatives (A through D) considered in the EIS in detail. A 

description of the alternatives considered requires (1) a narrative to describe what decisions 

each alternative will establish and (2) maps to show where each decision will occur. With 167

maps and multiple special designations, resource uses, and management actions for more than 

30 individual resources and resource uses, an exhaustive narrative description of each 

alternative would result in a lengthy and potentially confusing chapter. To reduce the length 

and avoid confusion, only select meaningful differences (those with the most potential to affect 

resources) among alternatives are summarized in this section. 

Combined with the appendices and maps, Table 2.5 and Table 2.6 highlight the meaningful 

differences among the alternatives relative to what they establish and where they occur. 

Following these tables, a narrative description of each alternative is provided under the 

following headings 

 Overview of the Alternative 

 Physical, Biological and Cultural/Heritage Resources 

 Resource Uses and Support 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-59

 Special Designations 

Other than Overview of the Alternative, the above headings reflect categories through which 

program specific guidance for land use planning decisions must be applied (BLM 2005 – LUP 

Handbook). Table 2.5 summarizes meaningful differences (typically relative to acres) among 

alternatives for the first two categories: Physical, Biological and Cultural/Heritage Resources 

and Resource Uses and Support. Table 2.6 summarizes meaningful differences (typically 

relative to designation and acres) among alternatives for Special Designations. Viewed in 

conjunction with the narrative for each alternative, Table 2.5 and Table 2.6 highlight what

meaningful decisions each alternative will establish. A complete description of all decisions 

proposed for each alternative, as well as a description of goals and objectives are included in 

Table 2.10 through Table 2.13. 

Decisions made by this RMP revision are anticipated to be subsequently implemented. 

Restrictions on resource uses (e.g., closed to leasing) apply to the life of the RMP, unless 

changed through an RMP amendment and public involvement. The timing and degree of 

implementation will depend on available budget, staffing, and agency priorities (see 

Appendix X). Actions taken or authorized by the BLM during RMP implementation would 

comply with standard practices and best management practices (BMPs; Appendix B). 

Therefore, these practices and guidelines are considered part of each alternative. 

Table 2.5 Comparative Summary of Proposed Land Use Decisions for Physical, 

Biological, and Cultural/Heritage Resources and Resource Uses by 

Alternative 

Topic Acreage Type Alternative A

(No Action) Alternative B Alternative C

Alternative D

(Proposed

Alternative)

Physical, Biological, and Cultural/Heritage Resources 

Sensitive Soils and 

Rock Outcrops

(acres of surface 

disturbance restrictions)

BLM 

Administered 

Surface

33,908 47,795 16,782 169,719

Forests and Woodlands

(# of available acres for 

potential treatment, 

based on slope 

restrictions)

BLM 

Administered 

Surface

20,806

(68% of forested 

lands)

18,375

(60% of forested 

lands)

24,443

(79% of forested 

lands)

18,375

(60% of forested 

lands)

Rangelands

(acres crested 

wheatgrass treated over 

life of the plan)

BLM 

Administered 

Surface

160 4,459 1,486 2,378

Riparian and 

Floodplains

(acres surface 

disturbance restricted)

BLM 

Administered 

Surface

10,114 24,373 6,666 7,563

Riparian 

(miles of high priority 

recovery area)

BLM 

Administered 

Surface

0 189 13 51

Invasive Species and 

Noxious Weed Treated

(acres treated per year)

BLM 

Administered 

Surface 

366 to 5,548 200 to 800 1,500 to 3,000 400 to 2,000
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-60 Chapter 2: Resource Management Alternatives

Table 2.5 Comparative Summary of Proposed Land Use Decisions for Physical, 

Biological, and Cultural/Heritage Resources and Resource Uses by 

Alternative 

Topic Acreage Type Alternative A

(No Action) Alternative B Alternative C

Alternative D

(Proposed

Alternative)

Greater Sage-Grouse 

General Habitat 

Management Areas

BLM 

Administered 

Surface

0 78,575 acres 113,816 acres

BLM 

Administered 

Federal Mineral 

Estate

0 116,452 acres 57,420 acres

Greater Sage-Grouse 

Priority Habitat 

Management Areas

BLM 

Administered 

Surface

0 154,452 acres 158,926 acres

BLM 

Administered 

Federal Mineral 

Estate

0 191,543 acres 60,569 acres

Greater Sage-Grouse 

Restoration Areas

BLM 

Administered 

Surface

0 45,555 acres 78,927 acres

BLM 

Administered 

Federal Mineral 

Estate

0 63,437 acres 22,951 acres

Fisheries 

(acres surface 

disturbance restrictions)

BLM 

Administered 

Surface

0 15,693 * 806 ** 2,068 **

Wild Horses:

Herd Management Area 

(acres)

BLM 

Administered

Surface

24,595 23,204 28,622 27,094 

Total Acres All 

Surface 

Ownerships 

(BLM, USFS, 

NPS and private)

within the Herd 

Area 

37,494 31,153 44,855 39,944

Cultural Sites (acres of 

restrictions on surface 

development on or 

near)

BLM 

Administered 

Surface

4,847 11,384 5,407 14,988

Visual Resource 

Management Class I 

(acres)

BLM 

Administered 

Surface

VRI Class A 56,700 56,700 29, 714 29,714

Visual Resource 

Management Class II 

(acres)

BLM 

Administered 

Surface

VRI Class B

13,507 14,377 26,569 55,883

Visual Resource 

Management Class III 

(acres)

BLM 

Administered 

Surface

VRI Class B/C

391,113 362,905 378,751 349,441
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-61

Table 2.5 Comparative Summary of Proposed Land Use Decisions for Physical, 

Biological, and Cultural/Heritage Resources and Resource Uses by 

Alternative 

Topic Acreage Type Alternative A

(No Action) Alternative B Alternative C

Alternative D

(Proposed

Alternative)

Visual Resource 

Management Class IV 

(acres)

BLM 

Administered 

Surface

VRI Class C

816 0 0 0

Wildfire to meet 

resource objectives 

(# acres in a 10year

period)

BLM 

Administered 

Surface

0 52,548 0 62,937

Fuels Treatment

(prescribed fire and 

non-prescribed fire) 

(# acres in a 10-yr 

period)

BLM 

Administered 

Surface

6,280 21,700

Lands with Wilderness 

Characteristics 

(# tracts /acres)

BLM 

Administered 

Surface

1,925 acres

13 tracts

27,507 acres

4 tracts

3,379 acres

9 tracts

13,653 acres

Resource Uses and Support

Fluid Minerals 

(acres available NSO)

BLM 

Administered 

Federal Mineral 

Estate

34,145 196,033 70,980 420,126

Fluid Minerals 

(acres available TL)

BLM 

Administered 

Federal Mineral 

Estate

543,078 15,875 134,016 17,116

Fluid Minerals 

(acres available CSU) 

BLM 

Administered 

Federal Mineral 

Estate

81,883 406,720 371,306 398,452

Fluid Minerals 

(acres available 

standard lease terms)

BLM 

Administered 

Federal Mineral 

Estate

237,336 41,103 319,133 44,142

Fluid Minerals 

(acres unavailable nondiscretionary)

BLM 

Administered 

Federal Mineral 

Estate

28,681 28,681 28,681 28,681

Fluid Minerals 

(acres unavailable 

discretionary)

BLM 

Administered 

Federal Mineral 

Estate

32,419 272,226 37,768 31,678

Coal Leasing 

(acres closed)

BLM 

Administered 

Federal Mineral 

Estate

26,131 290,048 264,450 225,655

Locatable Minerals

(acres closed and 

recommend for 

withdrawal)

BLM 

Administered 

Federal Mineral 

Estate

39,709

(1,855 currently 

withdrawn)

291,151 48,623 62,059
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-62 Chapter 2: Resource Management Alternatives

Table 2.5 Comparative Summary of Proposed Land Use Decisions for Physical, 

Biological, and Cultural/Heritage Resources and Resource Uses by 

Alternative 

Topic Acreage Type Alternative A

(No Action) Alternative B Alternative C

Alternative D

(Proposed

Alternative)

Mineral Materials 

(acres closed)

BLM 

Administered 

Federal Mineral 

Estate

44,588 343,749 261,260 281,597

Forest and Woodlands 

(average # acres for 

sale of forest products)

BLM 

Administered 

Surface

42 acres per year 67 acres per year 112 acres per year 89 acres per year

Land Tenure: Disposal 

– Category III

(acres available)

BLM 

Administered 

Surface

7,529 acres 

(with 2,088 acres 

identified for further 

study)

50 4,223 264

Land Tenure: Retention 

– Category I (acres)

BLM 

Administered 

Surface 26,616 acres

(no Category I 

or II )

68,300 108,184 83,507

Land Tenure: Retention 

– Category II (acres)

BLM 

Administered 

Surface

365,804 321,747 357,140

ROW Exclusion Areas 

(acres)

BLM 

Administered 

Surface

44,014 211,384 39,491 48,258

ROW Avoidance Areas 

(acres)

BLM 

Administered 

Surface

24,203 185,607 355,601 378,958

ROW Corridors 

(# corridors/acres)

BLM 

Administered 

Surface

1 / 1,579 acres 1 / 1,579 acres 2 / 13,832 acres 2 / 4,511 acres

Renewable Energy

(# acres open and 

percent open) 

BLM 

Administered 

Surface

361,514 acres 

(83% open)

Wind Potential:

H: 50,135

M: 132,040

L: 178,916

(WY – 423 acres)

0 acres 

Wind Potential:

H: 0

M: 0

L: 0

21,349 acres

(5% open) 

Wind Potential:

H: 757

M: 10,750

L: 9,842

1,512 acres 

(0.4% open)

Wind Potential:

H: 360

M: 502

L: 650

Renewable Energy 

(# acres closed and 

percent closed)

BLM 

Administered 

Surface

47,496 acres

(11% closed)

Wind Potential:

H: 12,372

M: 6,350

L: 26,271

(WY – 2,503 acres)

345,491 acres

(80% closed)

Wind Potential:

H: 53,537

M: 111,742

L: 179,530

(WY – 4,242 acres)

82,019 acres

(19% closed)

Wind Potential:

H: 19,960

M: 15,358

L: 46,421

(WY – 3,822 acres)

231,755 acres

(53 % closed)

Wind Potential:

H: 38,559

M: 74,464

L: 118,952

(WY – 3,822 

acres)

Renewable Energy 

(# acres avoidance and 

percent avoidance)

BLM 

Administered 

Surface

25,141 acres

(6% avoidance)

Wind Potential:

H:1,040

M: 7,677

L: 15,055

(WY – 1,372 acres)

85,461 acres

(20% avoidance)

Wind Potential: 

H: 10,690

M: 34,202

L: 40,513

(WY – 56 acres)

326,722 acres

(75% avoidance)

Wind Potential: 

H: 42,830

M: 119,570

L: 163,846

(WY – 476 acres)

200,278 acres

(46% avoidance)

Wind Potential: 

H: 7,149

M: 17,600

L: 175,529

(WY – 476 acres)

Livestock Grazing (total 

acres available)

BLM 

Administered 

Surface

434,154 acres
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-63

Table 2.5 Comparative Summary of Proposed Land Use Decisions for Physical, 

Biological, and Cultural/Heritage Resources and Resource Uses by 

Alternative 

Topic Acreage Type Alternative A

(No Action) Alternative B Alternative C

Alternative D

(Proposed

Alternative)

Livestock Grazing (total 

acres permitted)

BLM 

Administered 

Surface

387,057 386,092 386,822 387,057

Isolated parcels not 

included within grazing 

allotments

BLM 

Administered 

Surface

9,522 acres

Livestock Grazing 

(total acres closed to 

permitted livestock use 

for the life of the plan)

BLM 

Administered 

Surface

37,408 38,373 28,622 28,387

Livestock Grazing (total 

acres available for 

prescriptive use of 

livestock grazing)

BLM 

Administered 

Surface

0 0 9,021 9,021

SRMAs

(# SRMAs/acres)

BLM 

Administered 

Surface

2 SRMAs

1,171 acres

6 SRMAs

90,783 acres

11 SRMAs

147,181 acres

9 SRMAs

110,862 acres

Four Dances Natural 

Area ACEC SRMA

BLM 

Administered 

Surface

784 acres 784 acres 784 acres 784 acres

Sundance Lodge 

Recreation Area SRMA

BLM 

Administered 

Surface

387 acres 387 acres 387 acres 387 acres

Acton SRMA

BLM 

Administered 

Surface

0 3,697 acres 3,697 acres 3,697 acres

Asparagus Point SRMA

BLM 

Administered 

Surface

0 0 158 acres 158 acres

Bundy Island SRMA

BLM 

Administered 

Surface

0 98 acres 0 0

Horsethief TMA SRMA

BLM 

Administered 

Surface

0 0 12,261 acres 12,261 acres

Mill Creek/Bundy TMA

SRMA

BLM 

Administered 

Surface

0 0 34,239 acres 0

Pryor Mountain TMA

SRMA

BLM 

Administered 

Surface

0 81,277 acres 81,277 acres 81,277 acres

17-Mile SRMA

BLM 

Administered 

Surface

0 0 2,080 acres 0

Shepherd Ah-Nei 

SRMA

BLM 

Administered 

Surface

0 4,680 acres 4,680 acres 4,680 acres
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-64 Chapter 2: Resource Management Alternatives

Table 2.5 Comparative Summary of Proposed Land Use Decisions for Physical, 

Biological, and Cultural/Heritage Resources and Resource Uses by 

Alternative 

Topic Acreage Type Alternative A

(No Action) Alternative B Alternative C

Alternative D

(Proposed

Alternative)

South Hills TMA SRMA

BLM 

Administered 

Surface

0 0 1,357 acres 1,357 acres

Yellowstone River 

Corridor SRMA

BLM 

Administered 

Surface

0 0 6,311 acres 6,311 acres

ERMAs 

(# ERMAs/acres)

BLM 

Administered 

Surface

7 ERMAs

105,460 acres

5 ERMAs

7,668 acres 0 ERMAs 2 ERMAs36,319 acres

Shepherd Ah-Nei 

ERMA

BLM 

Administered 

Surface

4,680 acres 0 0 0

Acton Recreation Area 

ERMA

BLM 

Administered 

Surface

3,697 acres 0 0 0

South Hills TMA ERMA

BLM 

Administered 

Surface

1,357 acres 1,357 acres 0 0

Pryor Mountain TMA 

ERMA

BLM 

Administered 

Surface

81,227 acres 0 0 0

Horsethief TMA ERMA

BLM 

Administered

Surface

12,261 acres 12,261 acres 0 0

17 Mile ERMA

BLM 

Administered 

Surface

2,080 acres 2,080 acres 0 2,080 acres

Asparagus Point ERMA

BLM 

Administered 

Surface

158 acres 158 acres 0 0

Yellowstone River 

Corridor ERMA

BLM 

Administered 

Surface

0 6,213 acres 0 0

Mill Creek Area ERMA

BLM 

Administered 

Surface

0 0 0 34,239 acres

Non-Designated areas 

(public lands not 

identified as SRMAs or 

ERMAs)

BLM 

Administered 

Surface

All lands not 

designated as 

SRMAs would be 

managed as ERMAs 

(327,518 acres)

327,421 acres 288,495 acres 322,418 acres

Acres Open to Target 

Shooting

BLM 

Administered 

Surface

422,185 400,045 410,105 402,568

Acres Closed to Target 

Shooting

BLM 

Administered 

Surface

11,348 34,109 24,049 31,586
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-65

Table 2.5 Comparative Summary of Proposed Land Use Decisions for Physical, 

Biological, and Cultural/Heritage Resources and Resource Uses by 

Alternative 

Topic Acreage Type Alternative A

(No Action) Alternative B Alternative C

Alternative D

(Proposed

Alternative)

Miles Closed to 

Motorized Vehicle Use 

in 11 TMAs

BLM 

Administered 

Surface

No established TMAs 391.5 miles 5.6 miles 59.9 miles

Miles Open to 

Motorized Vehicle Use 

in 11 TMAs

BLM 

Administered 

Surface

No established TMAs

Travel limited to 

existing roads and 

trails: 844.1 miles

348.1 miles 831.1 miles 616.7 miles

Special Designations

ACECs 

BLM 

Administered 

Surface

9 ACECs

37,896 acres

12 ACECs

181,175 acres

11 ACECs

67,079 acres

11 ACECs

38,786 acres

Wilderness Study Areas

BLM 

Administered 

Surface

4 WSAs

28,631 acres

Wild and Scenic River 

(acres surface 

disturbance restrictions)

BLM 

Administered 

Surface 

0 5,454 2,840 5,454

National Historic Trails

(acres restrictions on 

surface development)

BLM 

Administered 

Surface

0 9,247 9,247 9,247

Notes: 

ACEC Area of Critical Environmental Concern BLM Bureau of Land Management 

CSU Controlled Surface Use ERMA Extensive Recreation Management Area 

NHT National Historic Trail NSO No Surface Occupancy 

ROW Right-of-Way SRMA Special Recreation Management Area 

TL Timing Limitation TMA Travel Management Area 

VRI Visual Resource Inventory VRM Visual Resource Management 

WSA Wilderness Study Area WSR Wild and Scenic River 

YCT Yellowstone Cutthroat Trout 

* Blue Ribbon Streams, Red Ribbon Streams, YCT Conservation Population, YCT Suitable Habitat 

** Blue Ribbon Streams, YCT Conservation Population 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-66 Chapter 2: Resource Management Alternatives

Table 2.6 Comparative Summary of Proposed Special Designations by Alternative

Name Emphasis

Acreage 

Type

Alternative A

(No Action) Alternative B Alternative C

Alternative D

(Proposed

Alternative)

Existing DesignationAcreageProposed DesignationAcreageProposed DesignationAcreageProposed DesignationAcreage

Pompeys Pillar 

National Monument 

and ACEC

Cultural and Historic 

Values BLM–AS ACEC 432 ACEC 432 ACEC 432 ACEC 432

ACECs

Bridger Fossil Area 

ACEC Paleontological Values BLM–AS ACEC 577 ACEC 577 ACEC 577 ACEC 577

Castle Butte ACEC Cultural Values BLM–AS ACEC 184 ACEC 184 ACEC 184 ACEC 184

East Pryor ACEC

Wild Horses & Wildlife 

Habitat, Historic, Cultural,

Paleontological, and 

Special Status Plants and 

Animals

BLM–AS ACEC 29,550 ACEC 8,301 ACEC 32,767 ACEC 11,122

Four Dances Natural 

Area ACEC

Safety Hazards, Cultural, 

Historic, and Scenic 

Values, Peregrine Falcon 

Nesting

BLM–AS ACEC 784 ACEC 784 ACEC 784 ACEC 784

Grove Creek ACEC Cultural Values and 

Special Status Plants BLM–AS None 0 ACEC 8,251 ACEC 9,445 ACEC 8,251

Meeteetse Spires 

ACEC

Scenic Values and Rare 

Plant Protection BLM–AS ACEC 965 ACEC 1,523 ACEC 2,173 ACEC 1,523

Petroglyph Canyon 

ACEC Cultural Values BLM–AS ACEC 240 AECE 240 ACEC 240 ACEC 240

Pryor Foothills RNA 

ACEC

Special Status Plants, 

Rare Plant Communities, 

Cultural Values

BLM–AS None 0 ACEC 958 ACEC 7,401 ACEC 2,606

Stark Site ACEC Cultural Values BLM–AS ACEC 799 ACEC 799 ACEC 799 ACEC 799

Weatherman Draw 

ACEC Cultural Values BLM–AS ACEC 4,365 ACEC 4,986 ACEC 12,277 ACEC 12,277

Greater Sage-Grouse

Habitat ACEC

Protect Greater SageGrouse priority habitat BLM-AS None 0 ACEC 154,452 No SD 0 No SD 0

Horse Range

Pryor Mountain Wild 

Horse Range

Wild Horses BLM–AS HR 24,595 HR 23,204 HR 28,622 HR 27,094

Wilderness Study Areas

Big Horn Tack-On 

WSA Wilderness values BLM–AS WSA / 2,689

Burnt Timber Canyon 

WSA Wilderness values BLM–AS WSA / 3,516

Pryor Mountain WSA Wilderness values BLM–AS WSA / 15,590

Twin Coulee WSA Wilderness values BLM–AS WSA / 6,836
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-67

Table 2.6 Comparative Summary of Proposed Special Designations by Alternative

Name Emphasis

Acreage 

Type

Alternative A

(No Action) Alternative B Alternative C

Alternative D

(Proposed

Alternative)

Existing DesignationAcreageProposed DesignationAcreageProposed DesignationAcreageProposed DesignationAcreage

Wild and Scenic Rivers

Bad Canyon (4.5 

miles) Scenic BLM–AS WSR eligible

4.5 

miles

WSR 

eligible

and 

suitable

4.5 

miles

WSR 

eligible

4.5 

miles No SD 0 miles

Bear Canyon (1.62 

miles) Recreational BLM–AS WSR eligible

1.62 

miles

WSR 

eligible

and 

suitable

1.62 

miles

WSR 

eligible

1.62 

miles No SD 0 miles

Crooked Creek (upper) 

(1.59 miles) Wild BLM–AS WSR eligible

1.59 

miles

WSR 

eligible

and 

suitable

1.59 

miles

WSR 

eligible

1.59 

miles

WSR 

suitable 

(Wild)

1.59 

miles

Crooked Creek (lower) 

(1.56 miles) Scenic BLM–AS WSR eligible

1.56 

miles

WSR 

eligible

and 

suitable

1.56 

miles

WSR 

eligible

1.56 

miles

WSR 

suitable 

(Scenic)

1.56 

miles

Gyp Springs (0.46 

miles) Recreational BLM–AS WSR eligible

0.46 

miles

WSR 

eligible

and 

suitable

0.46 

miles

WSR 

eligible

0.46 

miles No SD 0 miles

Piney Creek

(0.16 miles) Recreational BLM–AS WSR 

eligible

0.16 

miles

WSR 

eligible

and 

suitable

0.16 

miles

WSR 

eligible

0.16 

miles No SD 0 miles

Yellowstone River / 

Pompeys Pillar 

(4.19 miles)

Recreational BLM–AS WSR 

eligible

4.19 

miles

WSR 

eligible

and 

suitable

4.19 

miles

WSR 

eligible

4.19 

miles No SD 0 miles

National Historic Trails

Lewis and Clark NHT National Historic Trail 

values BLM–AS NHT / 3 miles

Nez Perce NHT National Historic Trail 

values BLM–AS NHT / 5 miles

Notes: 

ACEC Area of Critical Environmental Concern BLM Bureau of Land Management 

BLM–AS Bureau of Land Management Administered Surface HR Horse Range 

No SD No Special Designation NHT National Historic Trail 

WSA Wilderness Study Area WSR Wild and Scenic River 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-68 Chapter 2: Resource Management Alternatives

2.5.1 Alternative A (No Action Alternative)

2.5.1.1 Overview of Alternative A 

Alternative A represents the continuation of current management under the existing land use 

plan (1984), as amended. Direction contained in existing laws, regulation and policy would also 

continue to be implemented. This alternative provides the baseline against which to compare 

the other alternatives. Under Alternative A, resources, resource uses, and sensitive habitats 

would receive management emphasis (methods and mix of multiple use management of public 

land) at present levels. In general, most activities would be analyzed on a case-by-case basis, 

and few uses would be limited or excluded as long as land health standards would be met. 

2.5.1.2 Physical, Biological, and Cultural/Heritage Resources 

Alternative A restricts surface disturbance on 33,908 acres of highly erosive soils, surface 

disturbance is restricted on 10,114 acres in riparian areas and floodplains, surface disturbing 

activities are not restricted in fisheries, and there are restrictions on 4,847 acres on or near 

cultural sites. 

Under Alternative A, there would be no established Greater Sage-Grouse Priority Habitat 

Management Areas or Restoration Areas. 

Wildfire would not be used to meet resource objectives and prescribed fire and non-prescribed 

fire fuels treatments would treat 6,280 acres over a 10 year period. 

Over the 20 year life of this plan, approximately 20,806 acres of forest and woodlands would 

be available for potential treatment, with an estimated 840 acres available for the sale of wood 

products, 160 acres of crested wheatgrass in rangelands would be treated, and 366 to 5,548 

acres of invasive species and noxious weeds would be treated per year under Alternative A, 

The Herd Management Area would consist of 24,595 acres of the BLM administered surface 

(37,494 total acres of all federal surface ownerships (BLM, USFS, and NPS)). 

Under Alternative A, approximately 56,700 acres are identified as Visual Resource 

Management (VRM) Class I, 13,507 acres are identified as VRM Class II, 391,113 acres are 

identified as VRM Class III, and 816 acres are identified as VRM Class IV. There are 1,925

acres containing lands with wilderness characteristics under Alternative A. 

2.5.1.3 Resource Uses and Support 

Fluid minerals are available for leasing on 237,336 acres of the BLM administered federal 

mineral estate with standard lease terms. Fluid minerals are available for leasing on 369,048 

acres of the BLM administered federal mineral estate with major and moderate constraints. 

Fluid minerals are not available for leasing on 61,100 acres of the BLM administered federal 

mineral estate. Coal is not available for leasing on 26,131 acres. A total of 1,855 acres of the 

BLM administered federal mineral estate (locatable minerals) are withdrawn from mineral 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-69

entry and an additional 39,709 acres are recommended for closure to the mining laws. Under 

Alternative A, a total of 44,583 acres are closed to mineral material sales. 

Under Alternative A, the sale of forest and woodland products would be allowed on 

approximately 42 acres per year. 

Approximately 7,463 acres of public land would be available for disposal with an additional 

2,088 acres identified for further study. Rights-of-Way (ROW) exclusion and avoidance areas 

encompass 68,217 acres of the BLM administered surface (ROW exclusion: 44,014 acres, 

ROW avoidance: 24,203 acres). There would be one designated ROW corridor under this 

Alternative, encompassing 1,579 acres of the BLM administered surface. 

Livestock grazing would be permitted on 387,057 acres and 37,408 acres would be closed to 

livestock grazing. 

Under Alternative A, the BLM maintains two Special Recreation Management Areas 

(SMRAs): Sundance Lodge Recreation Area (387 acres) and Four Dances Natural Area ACEC 

(784 acres). The other seven areas receiving concentrated recreation are managed as Extensive 

Recreation Management Areas: Shepherd Ah-Nei Recreation Area (4,680 acres), Acton 

Recreation Area (3,697 acres), South Hills TMA (1,357 acres), Pryor Mountain TMA (81,227 

acres), Horsethief TMA (12,261 acres), 17 Mile (2,080 acres), and Asparagus Point (158 

acres). 

Travel Management Areas are not delineated in the decision area. Off-highway vehicle use 

would be limited to existing roads and trails in the planning area, however in the following 

areas: Pryors, Acton, Shepherd Ah-Nei, and Horsethief, motorized travel would be restricted to 

designated routes. South Hills would be designated open for motorcycle use only. 

Under Alternative A, the BLM responds to proposals for renewable wind energy development 

within the decision area on a case-by-case basis. Although interests in wind energy have 

increased, no wind farms currently exist in the planning area on the BLM administered surface. 

The area of the BLM administered surface open to renewable wind energy development, but 

still subject to terms and conditions identified during the right-of-way application process is 

361,514 acres. The area of the BLM administered surface closed to renewable wind energy 

development is 47,496 acres. Alternative A has the highest number of acres available for 

renewable energy development. 

2.5.1.4 Special Designations

Nine ACECs would be retained totaling 37,896 acres. Currently, special designations in the 

decision area include Pompeys Pillar National Monument and ACEC (432 acres), eight 

additional ACECs: Bridger Fossil Area ACEC (577 acres), Castle Butte (184 acres), East Pryor 

ACEC (29,550 acres), Four Dances Natural Area ACEC (784 acres), Meeteetse Spires ACEC 

(965 acres), Petroglyph Canyon ACEC (240 acres), Stark Site ACEC (799 acres), and 

Weatherman Draw ACEC (4,365 acres). Special designations also include the Pryor Mountain 

Wild Horse Range (37,494 acres) and the Lewis and Clark and Nez Perce National Historic 

Trails. Under Alternative A, the seven eligible river segments (14.08 miles) would be managed 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-70 Chapter 2: Resource Management Alternatives

to protect their outstandingly remarkable values and free-flowing nature. These designations 

continue and there would be no additional special designations are established under 

Alternative A. 

2.5.2 Alternative B

2.5.2.1 Overview of Alternative B 

Alternative B would emphasize the conservation of physical, biological, and/or cultural 

resources over commodity production, mineral extraction, and motorized recreation. Relative to 

all alternatives, Alternative B conserves the most land area for physical, biological, and cultural 

resources, closes the most miles of roads in TMAs, and is the most restrictive to coal and fluid 

mineral leasing and the most restrictive to renewable energy development. Management actions 

would focus on maintaining those ecological systems that are functioning and healthy and the 

restoration of ecological systems that have been degraded or altered. Production of food, fiber, 

minerals and services would be more constrained than in most other alternatives, and in some 

cases and in some areas, uses would be excluded to protect sensitive or fragile resources. 

2.5.2.2 Physical, Biological, and Cultural/Heritage Resources

Alternative B restricts surface disturbance on 169,119 acres of highly erosive soils, surface 

disturbance is restricted on 24,373 acres in riparian areas and floodplains, surface disturbing 

activities are restricted on 15,693 acres in fisheries: Blue Ribbon Streams, Red Ribbon Streams, 

YCT Conservation populations, and YCT suitable habitat, and there are restrictions on surface 

development on 11,384 acres on or near cultural sites. 

Greater Sage-Grouse General Habitat Management Areas consists of 78,575 acres of the BLM 

administered surface and 116, 452 acres of the BLM administered federal mineral estate. 

Greater Sage-Grouse Priority Habitat Management Areas consist of 154,452 acres of the BLM 

administered surface and 191,543 acres of the BLM administered federal mineral estate. 

Greater Sage-Grouse Restoration Areas consist of 45,555 acres of the BLM administered 

surface and 63,437 acres of the BLM administered federal mineral estate. These acres are the 

same for the Action Alternatives (B and C). Under this alternative only, the Greater SageGrouse Priority Habitat Management Areas (BLM administered surface – 154,452 acres) would 

be administered as an ACEC. 

Over a 10 year period wildfire would be used to meet resource objectives on 52,548 acres and 

prescribed and non-prescribed fire fuels treatments would treat 21,700 acres over a 10 year 

period. 

Over the 20 year life of this plan, approximately 18,375 acres of forest and woodlands would 

be available for potential treatment, with an estimated 1,340 acres available for the sale of 

wood products, 22,414 acres of crested wheatgrass would be treated, and 200 to 800 acres of 

invasive species and noxious weeds would be treated per year under Alternative B. 

The Herd Management Area would consist of 23,204 acres of the BLM administered surface 

(31,153 total acres of all federal surface ownerships (BLM, USFS, and NPS)). 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-71

Under Alternative B, approximately 56,700 acres would be designated as Visual Resource 

Management Class I and 14,377 acres would be designated as Visual Resource Management 

Class II. There are 13 tracts totaling 27,507 acres of land that would be managed for wilderness 

characteristics. 

2.5.2.3 Resource Uses and Support

Fluid minerals are available for leasing on 41,103 acres of the BLM administered federal 

mineral estate with standard lease terms. Fluid minerals are available for leasing on 618,628

acres of the BLM administered federal mineral estate with major and moderate constraints. 

Fluid minerals are not available for leasing on 300,907 acres of the BLM administered federal 

mineral estate. Coal is not available for leasing on 290,048 acres. A total of 1,855 acres of the 

BLM administered federal mineral estate (locatable minerals) are currently withdrawn from 

mineral entry and an additional 291,151 acres are recommended for closure to the mining laws,

totaling 270,977 acres. Under Alternative B, a total of 343,749 acres are closed to mineral 

material sales. 

Under Alternative B, the sale of forest and woodlands products would be allowed on 

approximately 67 acres per year. 

Approximately 50 acres of public land would be available for disposal. Rights-of-Way (ROW) 

exclusion and avoidance areas encompass 369,991 acres of the BLM administered surface 

(ROW exclusion: 211,384 acres, ROW avoidance: 185,607 acres). There is one designated 

ROW corridor under this Alternative, encompassing 1,579 acres of the BLM administered 

surface and Silver Tip Road would not be designated a ROW corridor under Alternative B. 

Livestock grazing would be permitted on 386,092 acres and 38,373 acres would be closed to 

livestock grazing. 

Under Alternative B, the BLM would maintain two Special Recreation Management Areas 

(SMRAs): Sundance Lodge Recreation Area (387 acres) and Four Dances Natural Area ACEC 

(784 acres) and propose four additional SRMAs: Acton Recreation Area (3,697 acres), Bundy 

Island (98 acres), Pryor Mountain TMA (81,277 acres), and Shepherd Ah-Nei Recreation Area 

(4,680 acres). The other areas receiving concentrated recreation use would be managed as 

Extensive Recreation Management Areas (ERMAs): South Hills TMA (1,357 acres), 

Horsethief TMA (12,261 acres), 17 Mile (2,080 acres), Asparagus Point (158 acres), and the 

Yellowstone River Corridor (6,213 acres). 

Travel Management Areas are delineated in the decision area. OHV use is limited to existing 

roads and trails except in the 11 TMAs where OHV use is limited to designated routes (391.5 

miles closed to motorized vehicle use in the 11 TMAs and 348.1 miles open to motorized 

vehicle use in 11 TMAs). South Hills would be closed to motorized travel. 

Under Alternative B, the area of the BLM administered surface open to renewable wind energy 

development is 0 acres. The area of the BLM administered surface closed to renewable wind 

energy development is 345,491 acres. Alternative B has the fewest acres open to renewable 

energy development. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

2-72 Chapter 2: Resource Management Alternatives

2.5.2.4 Special Designations 

Nine ACECs would be retained and three new ACECs would be designated totaling 185,961

acres. Currently, special designations in the decision area include Pompeys Pillar National 

Monument and ACEC (432 acres), ten additional ACECs: Bridger Fossil Area ACEC (577 

acres), Castle Butte (184 acres), East Pryor ACEC (8,301 acres), Four Dances Natural Area 

ACEC (784 acres), Grove Creek ACEC (8,251 acres), Meeteetse Spires ACEC (1,523 acres), 

Petroglyph Canyon ACEC (240 acres), Pryor Foothills RNA ACEC (958 acres), Stark Site 

ACEC (799 acres), Weatherman Draw ACEC (4,986 acres), and Greater Sage-Grouse Habitat 

ACEC (158,926 acres). Under Alternative B, the proposed management of the ACECs is the 

most restrictive for resource uses. 

The Greater Sage-Grouse PHMAs (BLM administered surface only) would be designated an 

ACEC (154,452 acres) to protect priority habitat for the Greater Sage-Grouse (see maps 168 

and 169). The area would be managed consistent with the specific management actions and 

direction described under the Greater Sage-Grouse PHMAs (refer to Table 2.10 Wildlife and 

Special Status Species) to protect habitat and minimize fragmentation. 

Special designations also include the Pryor Mountain Wild Horse Range (31,153 acres), four 

WSAs (28,631 acres) and the Lewis and Clark and Nez Perce National Historic Trails. 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. 

2.5.3 Alternative C

2.5.3.1 Overview of the Alternative 

Alternative C would emphasize commodity production (forage, minerals, etc.), motorized 

recreational access, and services. Among the three action alternatives (B, C, and D), Alternative 

C closes the least miles of roads in TMAs, is the least restrictive to coal and fluid mineral 

leasing. Under this alternative, constraints on commodity production for the protection of 

sensitive resources would be the least restrictive possible within the limits defined by law, 

regulation and BLM policy, including the ESA, cultural resource protection laws and wetland 

preservation. In this alternative, constraints to protect sensitive resources would tend to be 

implemented in specified geographic areas rather than across the entire planning area. 

2.5.3.2 Physical, Biological, and Cultural/Heritage Resources

Alternative C restricts surface disturbance on highly erosive soils on the least number of acres 

of all the alternatives (16,782 acres). Surface disturbance is restricted on only 6,666 acres in 

riparian areas and floodplains, and on 806 acres in fisheries: Blue Ribbon Streams and YCT 

suitable habitat. There are restrictions on surface development on 5,407 acres on or near 

cultural sites. 

The acreages for Greater Sage-Grouse PHMAs, RAs, and GHMAs have remained the same for 

Alternatives B and C. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-73

Wildfire would not be used to meet resource objectives and prescribed fire and non-prescribed 

fire fuels treatments would treat 21,700 acres over a 10 year period. 

Over the 20 year life of this plan, approximately 24,443 acres of forest and woodlands would 

be available for potential treatment, with an estimated 2,240 acres available for the sale of 

wood products, 7,500 acres of crested wheatgrass would be treated, and 1,500 to 3,000 acres of 

invasive species and noxious weeds would be treated per year under Alternative C. 

The Herd Management Area would consist of 28,622 acres of the BLM administered surface 

(44,855 total acres of all federal surface ownerships (BLM, USFS, and NPS)).

Under Alternative C, approximately 29,714 acres would be designated as Visual Resource 

Management Class I and 26,569 acres would be designated as Visual Resource Management 

Class II. There are four tracts totaling 3,379 acres of land that would be managed for wilderness 

characteristics. 

2.5.3.3 Resource Uses and Support

Fluid minerals are available for leasing on 319,133 acres of the BLM administered federal 

mineral estate with standard lease terms. Fluid minerals are available for leasing on 576,302 

acres of the BLM administered federal mineral estate with major and moderate constraints. 

Fluid minerals are not available for leasing on 66,449 acres of the BLM administered federal 

mineral estate. Coal is not available for leasing on 264,450 acres. A total of 1,855 acres of the 

BLM administered federal mineral estate are withdrawn from mineral entry and an additional 

48,623 acres are recommended for closure to the mining laws. Under Alternative C, a total of 

261,260 acres are closed to mineral material sales. 

Under Alternative C, the sale of forest and woodland products would be allowed on 

approximately 112 acres per year. 

Approximately 4,223 acres of public land would be available for disposal. Rights-of-Way 

(ROW) exclusion and avoidance areas encompass 395,092 acres of the BLM administered 

surface (ROW exclusion: 39,491 acres, ROW avoidance: 355,601 acres). There are two 

designed ROW corridors under this alternative, encompassing 13,832 acres of the BLM 

administered surface. 

Livestock grazing would be permitted on 386,822 acres and 28,622 acres would be closed to 

livestock grazing. 

Under Alternative C, the BLM would maintain two Special Recreation Management Areas 

(SMRAs): Sundance Lodge Recreation Area (387 acres) and Four Dances Natural Area ACEC 

(784 acres) and propose nine additional SRMAs: Acton Recreation Area (3,697 acres), 

Asparagus Point (158 acres), Horsethief TMA (12,261 acres), Mill Creek/Bundy TMA (34,239 

acres), Pryor Mountain TMA (81,277 acres), 17 Mile (2,080 acres), Shepherd Ah-Nei 

Recreation Area (4,680 acres), South Hills TMA (1,357 acres), and the Yellowstone River 

Corridor (6,213 acres). No Extensive Recreation Management Areas (ERMAs) are proposed 

under Alternative C. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

2-74 Chapter 2: Resource Management Alternatives

Travel Management Areas (TMAs) are delineated in the decision area. OHV use is limited to 

existing roads and trails except in the 11 TMAs where OHV use is limited to designated routes 

(5.6 miles closed to motorized vehicle use in the 11 TMAs and 831.1 miles open to motorized 

vehicle use in 11 TMAs). South Hills would be designated open for motorcycle use only. 

Under Alternative C, the area of BLM administered surface open to renewable wind energy 

development, but still subject to terms and conditions identified during the right-of-way 

application review process, is 21,349 acres. The area of BLM administered surface closed to 

renewable wind energy development is 82,019 acres. 

2.5.3.4 Special Designations

Nine ACECs would be retained and two new ACECs would be designated totaling 67,079

acres. 

The special designations in the decision area include Pompeys Pillar National Monument and 

ACEC (432 acres), ten additional ACECs: Bridger Fossil Area ACEC (577 acres), Castle Butte 

(184 acres), East Pryor ACEC (32,767 acres), Four Dances Natural Area ACEC (784 acres), 

Grove Creek ACEC (9,445 acres), Meeteetse Spires ACEC (2,173 acres), Petroglyph Canyon 

ACEC (240 acres), Pryor Foothills RNA ACEC (7,401 acres), Stark Site ACEC (799 acres), 

and Weatherman Draw ACEC (12,277 acres). Under Alternative C the proposed management 

of the ACECs is the least restrictive for resource uses. 

Under Alternative C, the Greater Sage-Grouse PHMA area would not be designated an ACEC. 

Priority habitat for Greater Sage-Grouse in the planning area would be protected as described in 

the Greater Sage-Grouse PHA areas and associated management actions (refer to Table 2.10

Wildlife and Special Status Species, Greater Sage-Grouse PHMA management). 

Special designations also include the Pryor Mountain Wild Horse Range (44,855 acres), four 

WSAs (28,631 acres) and the Lewis and Clark and Nez Perce National Historic Trails. Under 

Alternative C, the seven eligible river segments (14.08 miles) would be managed to protect 

their outstandingly remarkable values and free-flowing nature, however, none of the seven 

eligible river segments would be recommended as suitable for inclusion in the National Wild 

and Scenic River System. 

2.5.4 Alternative D (Proposed Alternative) 

2.5.4.1 Overview of the Alternative 

Alternative D addresses the key planning issues identified in Chapter 1 by incorporating 

elements from each of the other alternatives to strike a balance between long-term conservation 

of public land and resources within the planning area with commodity production, recreational 

access, and services. Regarding the conservation of physical, biological, and cultural resources 

and restrictions on mineral leasing, Alternative D is generally between alternatives B and C. 

Alternative D represents an approach to land management that address the issues, management 

concerns and purpose and need while balancing resources and resource uses. Among the action 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-75

alternatives (B, C, and D), Alternative D has the most acres available for renewable energy 

development and the fewest acres closed to renewable energy development. 

2.5.4.2 Physical, Biological, and Cultural/Heritage Resources

Alternative D restricts surface disturbance on sensitive soils and rock outcrops (169,719 acres), 

however surface disturbance is restricted on 7,563 acres in riparian areas and floodplains, and 

on 2,068 acres in fisheries: Blue Ribbon Streams and YCT suitable habitat. There are 

restrictions on surface development on 14,988 acres on or near cultural sites. 

Greater Sage-Grouse General Habitat Management Areas consists of 113,816 acres of the BLM 

administered surface and 57,420 acres of the BLM administered federal mineral estate. Greater 

Sage-Grouse Priority Habitat Management Areas consist of 158,926 acres of the BLM 

administered surface and 60,569 acres of the BLM administered federal mineral estate. Greater 

Sage-Grouse Restoration Areas consist of 78,927 acres of BLM administered surface and 

22,951 acres of the BLM administered federal mineral estate. 

Over a 10 year period, wildfire would be used to meet resource objectives on 62,937 acres and 

prescribed and non-prescribed fire fuels treatments would treat 21,700 acres over a 10 year 

period. 

Over the 20 year life of this plan, approximately 18,375 acres of forest and woodlands would 

be available for potential treatment, with an estimated 1,780 acres available for the sale of 

wood products; and 12,000 acres of crested wheatgrass would be treated. Under Alternative D, 

400 to 2,000 acres of invasive species and noxious weeds would be treated per year. 

The Herd Management Area would consist of 27,094 acres of the BLM administered surface 

(39,944 total acres of all federal surface ownerships (BLM, USFS, and NPS)). 

Under Alternative D, approximately 29,714 acres would be designated as Visual Resource 

Management Class I and 55,883 acres would be designated as Visual Resource Management 

Class II. There are nine tracts totaling 13,653 acres of land that would be managed for 

wilderness characteristics. 

2.5.4.3 Resource Uses and Support

Fluid minerals are available for leasing on 44,142 acres of the BLM administered federal 

mineral estate with standard lease terms. Fluid minerals are available for leasing on 835,720

acres of the BLM administered federal mineral estate with major and moderate constraints. 

Fluid minerals are not available for leasing on 60,359 acres of the BLM administered federal 

mineral estate. Coal is not available for leasing on 225,655 acres of the BLM administered 

federal mineral estate. A total of 1,855 acres of the BLM administered federal mineral estate 

(locatable minerals) are withdraw from mineral entry and an additional 52,906 acres are 

recommended for closure to the mining laws. Under Alternative D, a total of 281,597 acres are 

closed to mineral material sales. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

2-76 Chapter 2: Resource Management Alternatives

Under Alternative D, the sale of forest and woodland products would be allowed on 

approximately 89 acres per year. 

Approximately 264 acres of public land would be available for disposal under Alternative D. 

Rights-of-Way (ROW) exclusion and avoidance areas encompass 397,616 acres of the BLM 

administered surface (ROW exclusion: 48,258 acres, ROW avoidance: 378,958 acres). There 

are two designated ROW corridors under this Alternative, encompassing 4,511 acres of the 

BLM administered surface. 

Livestock grazing would be permitted on 387,057 acres and 28,387 acres would be closed to 

livestock grazing. 

Under Alternative D, the BLM would maintain two Special Recreation Management Areas 

(SRMAs): Sundance Lodge Recreation Area (387 acres) and Four Dances Natural Area ACEC 

(784 acres) and propose seven additional SRMAs: Acton Recreation Area (3,697 acres), 

Asparagus Point (158 acres), Horsethief TMA (12,261 acres), Pryor Mountain TMA (81,277 

acres), Shepherd Ah-Nei Recreation Area (4,680 acres), South Hills TMA (1,357 acres), and 

the Yellowstone River Corridor (6,213 acres). The other areas receiving concentrated recreation 

use would be managed as Extensive Recreation Management Areas (ERMAs): 17 Mile (2,080 

acres) and the Mill Creek area (34,239 acres). 

Travel Management Areas (TMAs) area delineated in the decision area. OHV use is limited to 

existing roads and trails except in the 11 TMAs where OHV use is limited to designated routes 

(59.9 miles closed to motorized vehicle use in the 11 TMAs and 616.7 miles open to motorized 

vehicle use in 11 TMAs). South Hills would be designated open for motorcycle use only. 

Under Alternative D, the area of BLM administered surface open to renewable wind energy 

development, but still subject to terms and conditions identified during the right-of-way 

application process, is 1,512 acres. The area of BLM administered surface closed to renewable 

wind energy development is 231,775 acres. 

2.5.4.4 Special Designations

Nine ACECs would be retained and two new ACECs would be designated totaling 38,786

acres. 

The special designations in the decision area include Pompeys Pillar National Monument and 

ACEC (432 acres), ten additional ACECs: Bridger Fossil Area ACEC (577 acres), Castle Butte 

(184 acres), East Pryor ACEC (11,122 acres), Four Dances Natural Area ACEC (784 acres), 

Grove Creek ACEC (8,251 acres), Meeteetse Spires ACEC (1,523 acres), Petroglyph Canyon 

ACEC (240 acres), Pryor Foothills RNA ACEC (2,606 acres), Stark Site ACEC (799 acres), 

and Weatherman Draw ACEC (12,277 acres). 

Under Alternative D, the Greater Sage-Grouse PHMA area would not be designated an ACEC. 

Priority habitat for Greater Sage-Grouse in the planning area would be protected as described in 

the Greater Sage-Grouse PHMA areas and associated management actions (refer to Table 2.10

Wildlife and Special Status Species, Greater Sage-Grouse PHMA management). 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-77

Special designations also include the Pryor Mountain Wild Horse Range (39,944 acres), four 

WSAs (28,703 acres) and the Lewis and Clark and Nez Perce National Historic Trails. Under 

Alternative D, only two river segments (3.15 miles) would be recommended as suitable for 

inclusion in the National Wild and Scenic River System. 

2.6 Alternatives Considered in Detail 

RMPs are broad-scale land management plans that establish desired outcomes for resource 

management, and identify the measures deemed likely to achieve those outcomes. The 

following format of the alternatives identifies the desired outcomes for each resource and 

resource use. The goals and objectives are followed by different sets of management actions, 

allowable uses, and use allocations for each alternative—these identify areas and acreages 

where certain land uses would be prohibited, restricted, or allowed, as well as proactive 

management measures- that would achieve those goals and objectives. 

Once an alternative is selected, the broad, plan-level decisions included in that alternative 

would become the RMP and provide the framework for site-specific management decisions and 

actions. Some implementation-level decisions have been included within the alternatives (e.g., 

travel management route designations, management actions within Areas of Critical 

Environmental Concern (ACECs), etc.), and are analyzed as part of each alternative. Though 

all future implementation decisions and administrative actions are influenced by the alternative 

ultimately selected by the BLM as the new RMP, these do not need to be determined as part of 

the planning process for this RMP. 

Table 2.10 through Table 2.13 identifies goals and objectives, management actions common to 

all alternatives, and management actions by alternative. These are arranged according to the 

following resource topics: (see Table 2.7) 

A detailed narrative, including tables, for Fluid Minerals is included in Chapter 2 to describe 

the changes by alternative for fluid mineral leasing restrictions. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-78 Chapter 2: Resource Management Alternatives

Table 2.7 Organization of Comprehensive Alternatives Table 

Physical, Biological, and 

Heritage Resources Resource Uses Special Designations Social andEconomic Conditions

 Air 

 Climate Change

 Geology

 Soil 

 Water 

 Vegetation

 Forests and Woodlands

 Rangelands

 Riparian and Wetlands

 Invasive Species and 

Noxious Weeds

 Special Status Plants

 Wildlife Habitat and 

SSS

 Fisheries Habitat and 

SSS

 Wild Horses 

 Cultural/Heritage

Resources 

 Paleontological 

Resources

 Visual Resources

 Fire Ecology & 

Management 

 Lands with Wilderness 

Characteristics

 Cave and Karst 

Resources

 Energy and Mineral 

Resources

 Coal

 Fluid Minerals

 Locatable Minerals

 Mineral Materials 

 Forestry and Woodland 

Products

 Realty, Cadastral 

Survey, and Lands

 Land Tenure 

Adjustment and Access

 Rights-of-Way, Leases, 

and Permits 

 Withdrawals

 Livestock Grazing

 Recreation and Visitor 

Services

 Trails and Travel 

Management

 Renewable Energy

 Transportation and 

Facilities

 Pompeys Pillar National 

Monument and ACEC 

 Areas of Critical Environmental 

Concern

 Bridger Fossil Area ACEC

 Castle Butte ACEC

 East Pryor ACEC

 Four Dances Natural Area ACEC

 Grove Creek ACEC

 Meeteetse Spires ACEC

 Petroglyph Canyon ACEC

 Pryor Foothills RNA ACEC

 Stark Site ACEC

 Weatherman Draw ACEC

 Wilderness Study Areas

 Big Horn Tack-On WSA 

 Burnt Timber WSA

 Pryor Mountain WSA 

 Twin Coulee WSA

 Wild and Scenic Rivers

 Bad Canyon

 Bear Canyon

 Crooked Creek (2 segments)

 Gyp Springs

 Piney Creek

 Yellowstone River/Pompeys Pillar

 Pryor Mountain Wild Horse Range

 National Historic Trails

 Nez Perce NHT

 Lewis and Clark NHT

 Economic Conditions

 Social Conditions

 Environmental Justice

 Tribal Concerns/ Tribal 

Treaty Rights

2.6.1 Format of the Alternatives 

Management actions are anticipated to achieve the goals and objectives identified for each 

resource topic. Some Management actions are constant across all alternatives, whereas others 

vary by alternative. Management actions that apply to all alternatives are listed for each 

resource topic under the heading Management Actions Common to All Alternatives

immediately following the desired outcomes (goals and objectives) for each resource topic. 

Management actions common to Alternatives B, C, and D are listed under the heading 

Management Common to Action Alternatives. Management actions that vary by alternative are 

listed under the heading Management Actions by Alternative. 

The following apply under all alternatives: 

 Standards for Healthy Rangelands and Guidelines for Livestock Grazing 

Management for Public Lands Administered by the Bureau of Land 

Management in the State of Montana (Appendix I) 

 Best Management Practices (Appendix B) 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-79

Restrictions on resource uses apply to the life of the RMP, but can be changed by amending the 

RMP. For example, areas identified as closed to leasing refer to minerals deferred from leasing 

for the life of the RMP unless changed through an RMP amendment and public involvement. 

Moreover, where seasonal or other restrictions or limitations are placed on development, 

exception, wavier, or modification of these limitations may be approved in writing, including 

documented supporting analysis, by the authorized officer. This applied to all restrictions and 

limitations. 

2.6.2 Energy and Minerals

The general mining laws give the public the right to locate and develop mining claims on 

public land. The Mining and Minerals Policy Act of 1970 declares that it is the continuing 

policy of the federal government to foster and encourage private enterprise in the development 

of domestic mineral resources. Section 102 of the Federal Land Policy and Management Act of 

1976 directs that the public land would be managed in a manner that recognizes the Nation’s 

need for domestic sources of minerals and other commodities from the public lands, while 

protecting scientific, scenic, historic, archeological, ecological, environmental, air and 

atmospheric and hydrologic values. The BLM’s mineral and national energy policy states that 

public lands shall remain open and available for mineral exploration and development unless 

withdrawal or other administrative action is justified in the national interest. 

Federally owned minerals in the public domain are classified into three categories: leasable 

minerals, locatable minerals, and mineral materials as discussed below. The classifications are 

based on acts passed by the U.S. Congress. These acts provide the opportunity for the public to 

explore for, develop, and produce publicly owned minerals. 

Leasable minerals are those minerals on public lands where the land is leased to individuals for 

their exploration and development. The leasable minerals have been subdivided into two 

classes, fluid and solid. Fluid minerals include oil and gas; geothermal resources and associated 

by-products; and oil shale, native asphalt, oil impregnated sands, and any other material in 

which oil is recoverable only by special treatment after the deposit is mined or quarried. Solid 

leasable minerals are those leased under the mineral leasing acts and those hardrock minerals 

leased under Reorganization Plan No. 3 of 1946 (acquired lands). Solid leasable minerals are 

specific minerals such as coal and phosphates. All minerals on acquired lands are considered to 

be leasable minerals. Leasable minerals are associated with the following laws: Mineral 

Leasing Act of 1920, as amended and supplemented, Mineral Leasing Act for Acquired Lands 

of 1947, as amended, and the Geothermal Steam Act of 1970, as amended. 

Locatable minerals are those “minerals acquired through the General Mining Law of 1872, as 

amended” (National Research Council 1999). Locatable minerals can include gold, silver, 

platinum, lead, zinc, magnesium, nickel, tungsten, bentonite, barite, feldspar, uranium, and 

uncommon varieties of sand, gravel, and stone. Locatable minerals on public lands (if open to 

mineral entry) can be acquired by initially staking claims over the deposits. However, before 

mining can occur, permits from various state and federal agencies must be obtained. 

Mineral materials are common varieties of minerals such as sand, gravel, rock, cinders, and 

common clay. Mineral materials are disposed of through sales contracts or free use permits and 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-80 Chapter 2: Resource Management Alternatives

are regulated under the Mineral Material Act of July 23, 1947, as amended, and the Surface 

Use and Occupancy Act of July 23, 1955. Disturbance of public lands in association with 

mineral material sales is considered a discretionary activity. This means that the action may be 

denied if resource concerns cannot be protected or mitigated. 

2.6.2.1 Leasable Fluid Minerals

2.6.2.1.1 Management Common to All Alternatives 

Goals and Objectives (Fluid Leasable Minerals) 

 Provide opportunities for exploration and development of fluid mineral 

resources on available public lands 

 Provide opportunities for exploring, leasing, and developing conventional oil 

and gas, coal bed natural gas, and geothermal resources while applying the 

appropriate lease stipulations and conditions of approval to mitigate 

environmental impacts from development 

 Provide opportunities for geophysical (e.g. seismic) exploration for oil and gas 

subject to the appropriate mitigating measures 

Oil and Gas 

Federal oil and gas leasing authority for public lands is found in the Mineral Leasing Act of 

1920, as amended; and for acquired lands in the Acquired Lands Leasing Act of 1947, as 

amended. Leasing of federal oil and gas is affected by other acts such as the National 

Environmental Policy Act of 1969, the National Historic Preservation Act of 1966, FLPMA 

(1976), the Wilderness Act of 1964, the Endangered Species Act of 1973, as amended, and the 

Federal Onshore Oil and Gas Leasing Reform Act of 1987. Regulations and other guidance 

governing federal oil and gas leasing and lease operations are contained in 43 CFR Group 

3100, Onshore Operating Orders, Notices to Lessees, and BLM handbooks manuals and 

instruction memorandums. Regulations governing geophysical exploration are found at 43 CFR 

3150.

An oil and gas lease grants the lessee the right to explore for, extract, remove, and dispose of 

oil and gas deposits that may be found on the leased lands. The lessee may exercise the rights 

conveyed by the lease, subject to lease terms and any lease stipulations (modifications of the 

lease), and permit approval requirements. 

The terms of existing oil and gas leases cannot be changed by the decisions in this document. 

When the lease expires, the area would be managed for oil and gas according to the decisions 

reached in this document. 

The BLM planning process determines availability of federal mineral estate lands for oil and 

gas leasing (Table 2.8 ). 
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Chapter 2: Resource Management Alternatives 2-81

Table 2.8 Acres of Federal Mineral Estate Available or Not for Oil and Gas Leasing

Alternative A 

(No Action) Alternative B Alternative C

Alternative D

(Proposed

Alternative)

Acres Available for Oil and Gas Leasing1 896,442 659,731 615,435 879,836

No Surface Occupancy 34,145 196,033 70,980 420,126

Timing Limitations 543,078 15,875 134,016 17,116

Controlled Surface Use 81,883 406,720 371,306 398,452

Standard Lease Terms 237,336 41,103 319,133 44,142

Areas Unavailable for Oil and Gas Leasing 61,100 300,907 66,449 60,359

Non-discretionary 28,681 28,681 28,681 28,681

Discretionary 32,419 272,226 37,768 31,678

Note:

1 Acreages by subcategory were calculated such that each column of subcategories under each alternative adds up to the total available 

acres for leasing based on the following general concepts where multiple stipulations overlapped: No Surface Occupancy stipulations 

override and are more restrictive than Timing Limitations, Controlled Surface Use, and Standard Lease Terms. Timing Limitation 

stipulations override and are more restrictive than Controlled Surface Use and Standard Lease Terms. Controlled Surface Use 

stipulations override and are more restrictive than Standard Lease Terms. Non-overlapping individual stipulation-specific acreages are 

displayed by alternative in Chapter 4 in Tables 4-29 through 4-40. 

For federal oil and gas where the surface is managed by another federal agency, the BLM 

would consult with that agency before issuing leases. In areas where oil and gas development 

may conflict with other resources, the areas may be closed to leasing in accordance with 

decisions made from this document. 

Regulations at part 43 CFR 3100.0-3(d); the Secretary’s general authority to prevent the waste 

and dissipation of public property; and the Attorney General’s Opinion of April 2, 1941 (Vol. 

40 Op. Atty. Gen 41) allow the BLM to lease lands that are otherwise unavailable for leasing if 

oil and gas is being drained from such lands. If the unavailable lands were under the 

jurisdiction of another agency, leasing of such lands would only occur following consultation, 

and consent if necessary, from the surface managing agency. Unavailable lands for this RMP 

(refer to table above) would be leased only if a state or fee well is proposed or completed 

within the same spacing unit, or if the lands are within a producing unit. These lands would be 

leased with a no surface occupancy and no subsurface occupancy stipulation with no waiver, 

modification, or exception provisions. There would only be a paper transaction with no 

physical impacts on the unavailable lands. There would be no exploration or development 

(drilling or production) within the unavailable lands. After issuance of a lease, the lease would 

be committed to a communitization agreement and the United States would then receive 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-82 Chapter 2: Resource Management Alternatives

revenue in proportion to its acreage interest as it bears to the entire acreage interest committed 

to the agreements. 

Areas where oil and gas development could coexist with other resource uses would be open to 

leasing under standard lease terms or with added stipulations. Stipulations are a part of the lease 

only when environmental and planning records show the need for them. Three types of 

stipulations describe how lease rights are modified: no surface occupancy, timing limitation 

(seasonal restriction), and controlled surface use (for descriptions, see Leasing Process in the 

Oil and Gas section of Appendices C and D – Fluid Minerals). Stipulations may be changed by 

application of waivers, exceptions, or modifications. The decision whether to grant waivers, 

exceptions, or modifications generally occurs during the Application for Permit to Drill 

approval process. If the authorized officer determines the change to be substantial, the proposed 

alternative would be subject to a 30-day public review period. Waivers are a permanent 

exemption from a lease stipulation. This occurs when the resource does not require the 

protection of stipulation. Exceptions are granted on a case-by-case basis. Each time the lessee 

applies for an exception, the resource objective of the stipulation must be met. Modifications 

are fundamental changes to the provisions of a lease stipulation either temporarily or for the 

term of the lease. 

On Bureau of Reclamation or Corps of Engineers lands, in addition to the resource specific 

stipulations under each alternative (e.g., wildlife, recreation); stipulations that are 

recommended by the Bureau of Reclamation would be used (see Oil and Gas section in 

Appendix C – Fluid Minerals).

Additional information can be provided to the lessee in the form of a lease notice. This notice 

does not place restrictions on lease operation, but does provide information about applicable 

laws and regulations, and the requirements for additional information to be supplied by the 

lessee. 

New information may lead to changes in existing resource inventories. New use areas and 

resource locations may be identified or use areas and resource locations that are no longer valid 

may be identified. These resources usually cover small areas requiring the same protection or 

mitigation as identified in this plan. Identification of new areas or removal of old areas that no 

longer have those resource values would result in the use of the same lease stipulation 

identified in this plan. These areas would be added to the existing data inventory without a plan 

amendment. In cases where the changes constitute a change in resource allocation outside the 

scope of this plan, a plan amendment would be required. 

After lease issuance, the lessee may conduct lease operations with an approved permit. 

Proposed drilling and associated activities must be approved before beginning operations. The 

operator must file an Application for Permit to Drill or Sundry Notice that must be approved 

according to (1) lease stipulations, (2) Onshore Oil and Gas Order, and (3) regulations and laws 

(see Permitting in the Oil and Gas section of Appendix C – Fluid Minerals). 

None of the lands within the Wilderness Study Areas (WSA) would be available for oil and gas 

leasing under any of the alternatives unless they are released from their existing status, at which 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-83

point they would be managed under the terms and conditions of the selected alternative 

identified from this RMP. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-84 Chapter 2: Resource Management Alternatives

Table 2.9 Lease Terms and Stipulations by Alternative

Key

CSU = Controlled Surface Use Stipulation NSO = No Surface Occupancy Stipulation

LN = Lease Notice SLT = Standard Lease Terms

NA = Not Applicable TL = Timing Limitation Stipulation

NL = No Lease 

Distances are enumerated and those equal or greater than 100 are feet and those 3 or less are miles. Time periods are month/day

Resource Alt A

(No Action Alternative) Alt B Alt C Alt D(Proposed Alternative)

Wildlife

Black-tailed and 

White-tailed Prairie 

Dogs

CSU – Prior to surface-disturbing 

activities, prairie dog colonies and 

complexes 80 acres or more in size 

and containing 5 burrows per acre 

would be examined to determine the 

presence or absence of black-footed 

ferrets.

NSO – Oil and gas leasing, 

development, and exploration, and 

geophysical operations would be 

prohibited within 1⁄2 mile of black-tailed 

or white-tailed prairie dog colonies, 

active within the past 10 years.

CSU – Oil and gas leasing, 

development and exploration, and 

geophysical operations would be 

allowed with within black-tailed or whitetailed prairie dog colonies with a 

mitigation plan

NSO – Surface occupancy and use is 

prohibited within 1⁄4 mile of prairie dog 

colonies active within the past 10 years.

Potential Black-Footed 

Ferret Areas

CSU - Surface occupancy or use is 

subject to the following operating 

constraints.

Prior to surface disturbance, a surface 

use plan of operations (SUPO) for oil 

and gas activities must be approved 

for black-footed ferret reintroduction

areas by the authorized officer in 

consultation with the U.S. Fish and 

Wildlife Service (USFWS).

CSU - Prior to surface disturbance, 

prairie dog colonies and complexes 80 

acres or more in size would be 

examined to determine the presence or 

absence of black-footed ferrets. 

Same as B NSO - Surface occupancy and use is 

prohibited within 1⁄4 mile of black-footed 

ferret habitat

Mountain Plover NSO – Surface use is prohibited within 

0.25 mile of active mountain plover 

nest sites. Disturbance to prairie dog 

towns would be avoided where 

possible. Any active prairie dog town 

occupied by mountain plovers would

have no surface use between April 1 

and July 31. 

NSO – within 1⁄2 mile of mountain plover 

nests. 

CSU –mountain plover habitat within 1⁄4 

mile. 

NSO - Oil and gas surface occupancy 

and use is prohibited within mountain 

plover habitat 

TL – No surface use between April 1 

and July 31.

NSO only NSO only TL - Surface use is prohibited within 1⁄4 

mile of mountain plover habitat from 

April 1 through July 15.

Piping Plover NSO – Surface occupancy and use is 

prohibited within 1⁄4 mile of wetlands 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-85

Table 2.9 Lease Terms and Stipulations by Alternative

Key

CSU = Controlled Surface Use Stipulation NSO = No Surface Occupancy Stipulation

LN = Lease Notice SLT = Standard Lease Terms

NA = Not Applicable TL = Timing Limitation Stipulation

NL = No Lease 

Distances are enumerated and those equal or greater than 100 are feet and those 3 or less are miles. Time periods are month/day

Resource Alt A

(No Action Alternative) Alt B Alt C Alt D(Proposed Alternative)

identified as piping plover habitat

Colonial-nesting 

Waterbirds 

(Clark’s Grebe, American 

White Pelican, Great Blue 

Heron, Black-crowned 

Night-heron, White-faced 

Ibis, Franklin’s Gull, 

Caspian Tern, Forster’s 

Tern, Common Tern, 

Black Tern, Doublecrested Cormorant)

No similar action NSO - Surface occupancy and use is prohibited within 1⁄4 mile of waterbird nesting colonies.

Colonial-nesting 

Waterbirds 

(Clark’s Grebe, American 

White Pelican, Great Blue 

Heron, Black-crowned 

Night-heron, White-faced 

Ibis, Franklin’s Gull, 

Caspian Tern, Forster’s 

Tern, Common Tern, 

Black Tern, Doublecrested Cormorant)

No similar action TL – Surface use is prohibited within 1⁄2 mile of waterbird nesting colonies from April 1 through July 15.

Interior Least Tern No similar action NSO – 1⁄4 mile of wetlands identified as Interior Least Tern habitat

Peregrine Falcon NSO – 1 mile of peregrine falcon 

nesting sites. 

NSO – 1 mile of peregrine falcon 

nesting sites. 

NSO – 1⁄4 mile of active peregrine falcon 

nesting sites.

NSO –Surface occupancy and use is 

prohibited within 1 mile of peregrine 

falcon nest sites active within the 

preceding 7 years. 

Bald Eagle Nests & 

Habitat

NSO – within 1⁄2 mile of eagle nest 

sites which have been active within the 

past 7 years and within eagle nesting 

habitat in riparian areas. 

NSO – within 1 mile of eagle nest sites 

which have been active in the past 7 

years and within eagle nesting habitat in 

riparian areas. 

NSO – within 1⁄4 mile of active eagle 

nest sites. 

NSO – within 1⁄2 mile of active and 

alternate eagle nests (for territories 

occupied within the last five years) 

unless the activity complies with 

USFWS National Bald Eagle 

Management Guidelines (2007). 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-86 Chapter 2: Resource Management Alternatives

Table 2.9 Lease Terms and Stipulations by Alternative

Key

CSU = Controlled Surface Use Stipulation NSO = No Surface Occupancy Stipulation

LN = Lease Notice SLT = Standard Lease Terms

NA = Not Applicable TL = Timing Limitation Stipulation

NL = No Lease 

Distances are enumerated and those equal or greater than 100 are feet and those 3 or less are miles. Time periods are month/day

Resource Alt A

(No Action Alternative) Alt B Alt C Alt D(Proposed Alternative)

Greater Sage-Grouse 

Habitats

LN – The lease may in part or in total 

contain important Greater SageGrouse habitats as identified by the 

BLM either currently or prospectively.

CSU – surface occupancy and use 

within all identified sage-grouse habitat 

is subject to operating constraints

LN – The lease may in part or in total 

contain important Greater Sage-Grouse 

habitats as identified by the BLM either 

currently or prospectively.

CSU – surface occupancy and use 

within all identified sage-grouse habitat 

is subject to operating constraints

Greater Sage-Grouse 

Winter Range Site 

Density

No similar action CSU – Surface occupancy and use is subject to operating constraints. 

Greater Sage-Grouse

Priority Habitat

Management Areas 

(PHMAs) 

NSO – within 1⁄4 mile of Greater SageGrouse leks NL – Closed to future oil and gas 

leasing, exploration and/or development 

NSO – within 0.6 miles of Greater SageGrouse leks.NSO – To protect Greater Sage-grouse, 

a priority species for management, 

surface occupancy and use is prohibited 

within Greater Sage-Grouse Priority 

Habitat Management Areas.

TL – Surface use would be prohibited 

from March 1 to June 15 in Greater 

Sage-Grouse nesting habitat within 2 

miles of a lek.

CSU – Surface occupancy and use 

would be subject to the following special 

operating constraints: surface 

occupancy and surface disturbance 

density and mitigation plan.

Greater Sage-Grouse 

Restoration Areas

(RAs) – Nesting 

Habitat

NSO – within 1⁄4 mile of Greater SageGrouse leks NSO – within 0.6 miles of Greater SageGrouse lek.NSO – within 1⁄4 mile of Greater SageGrouse lek. NSO – Surface occupancy and use is 

prohibited within 0.6 miles of Greater 

Sage-Grouse lek. 

TL – March 1 to June 15 in sagegrouse nesting habitat within 4 miles of 

a lek

TL – March 1 to June 15 in sagegrouse nesting habitat within 2 miles of 

a lek

TL – March 1 to June 15 in sagegrouse nesting habitat within 2 miles of 

a lek. 

CSU – Surface occupancy and use for 

oil and gas exploration and 

development would be subject to the 

following special operating constraints 

CSU – Surface occupancy and use for 

oil and gas exploration and 

development would be subject to the 

following special operating constraints 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-87

Table 2.9 Lease Terms and Stipulations by Alternative

Key

CSU = Controlled Surface Use Stipulation NSO = No Surface Occupancy Stipulation

LN = Lease Notice SLT = Standard Lease Terms

NA = Not Applicable TL = Timing Limitation Stipulation

NL = No Lease 

Distances are enumerated and those equal or greater than 100 are feet and those 3 or less are miles. Time periods are month/day

Resource Alt A

(No Action Alternative) Alt B Alt C Alt D(Proposed Alternative)

that would maintain Greater SageGrouse habitat: surface disturbance 

density and mitigation plan.

that would maintain Greater SageGrouse habitat: surface disturbance 

density and mitigation plan.

Greater Sage-Grouse 

Restoration Areas 

(RAs) – Nesting 

Habitat

(continued)

Open to geophysical exploration, 

subject to the following:

 Surface occupancy and use 

would be prohibited within 0.25 

miles of Greater Sage-Grouse

leks. (NSO; 4,876 acres)

 Surface use is prohibited from 

March 1 to June 15 in grouse 

nesting habitat within 2 miles of a 

lek (TL). 

Geophysical exploration would be 

allowed on existing roads and trails with 

surface use prohibited from March 1 to 

June 15 within 4 miles of a lek. (TL)

Geophysical exploration would be 

allowed if the applicant demonstrates 

that Greater Sage-Grouse habitat 

suitability would be maintained.

TL - Geophysical exploration would be 

allowed on existing roads and trails with 

surface use prohibited from March 1 to 

June 15 within 4 miles of a lek.

Greater Sage-Grouse 

Habitat: General

Habitat Management

Areas 

NSO – within 1⁄4 mile of Greater SageGrouse leks NSO – within 0.6 miles of Greater SageGrouse leksNSO – within 1⁄4 mile of Greater SageGrouse leksNSO – To protect general Greater 

Sage-grouse breeding activities, surface 

occupancy and use is prohibited within 

0.6 miles of the perimeter of Greater 

Sage-Grouse leks

TL – March 1 to June 15 in sagegrouse nesting habitat within 2 miles of 

a lek (TL). 

TL – March 1 to June 15 in Greater 

Sage-Grouse nesting habitat within 3 

miles of a lek. 

TL – March 1 to June 15 in Greater 

Sage-Grouse nesting habitat within 2 

miles of a lek. 

CSU– To protect nesting Greater Sagegrouse, surface occupancy and use 

within 2 miles of a lek may be restricted 

or prohibited. Prior to such activities, a 

plan to mitigate impacts to nesting 

Greater Sage-grouse and Greater 

Sage-grouse nesting habitat would be 

prepared by the proponent and 

implemented upon approval by the 

authorized officer. 

Crucial Winter Range 

(antelope, elk, moose, 

bighorn sheep, mule 

deer, whitetail deer, and 

No similar action NSO - Surface Occupancy and use 

would be prohibited in crucial winter 

range (antelope, elk, moose, bighorn 

sheep, mule deer, whitetail deer, and 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-88 Chapter 2: Resource Management Alternatives

Table 2.9 Lease Terms and Stipulations by Alternative

Key

CSU = Controlled Surface Use Stipulation NSO = No Surface Occupancy Stipulation

LN = Lease Notice SLT = Standard Lease Terms

NA = Not Applicable TL = Timing Limitation Stipulation

NL = No Lease 

Distances are enumerated and those equal or greater than 100 are feet and those 3 or less are miles. Time periods are month/day

Resource Alt A

(No Action Alternative) Alt B Alt C Alt D(Proposed Alternative)

Greater Sage-Grouse) Greater Sage-Grouse).

Elk Calving TL – from April 1 to June 15 within 

established spring calving range for 

elk. 

TL – from April 1 to July 1 within 

established big game parturition habitat. 

CSU – within big game parturition 

habitat. 

CSU - Prior to surface occupancy and 

use a plan would be prepared by the 

proponent as a component of the APD, 

Sundry Notice, etc., and approved by 

the authorized officer in coordination 

with the state wildlife management 

agency. The operator would not initiate 

surface disturbing activities unless the 

authorized officer has approved the 

plan, The plan must demonstrate to the 

authorized officer’s satisfaction that the 

function and suitability of the habitat 

would not be impaired.

Big Game Winter 

Range

(antelope, elk, moose, 

bighorn sheep, mule 

deer, and whitetail deer)

TL –December 1 to March 31 within 

big game winter range to avoid 

disturbance of white-tailed deer, mule 

deer, elk, pronghorn antelope, moose, 

and bighorn sheep during the winter 

use season.

TL – December 1 to March 31 within 

CAPS SCORE 1 and 2 areas of big 

game winter range. 

CSU – The following special operating 

constraints apply in big game winter 

habitat: surface occupancy and surface 

disturbance density and / or mitigation 

plan.

TL – December 1 to March 31 within

CAPS SCORE 2 areas of big game 

winter range to avoid disturbance of 

white-tailed deer, mule deer, elk, 

pronghorn antelope, moose, and 

bighorn sheep during the winter use 

season.

CSU - Prior to surface occupancy and 

use a plan would be prepared by the 

proponent as a component of the APD, 

Sundry Notice, etc. and approved by the 

Authorized Officer in coordination with 

the state wildlife management agency. 

The operator would not initiate surfacedisturbing activities unless the 

Authorized Officer has approved the 

plan. The plan must demonstrate to the 

Authorized Officer’s satisfaction the 

function and suitability of the habitat 

would not be impaired. 

Bighorn Sheep Range

And Bighorn Sheep 

Lambing and Winter 

NSO – designated bighorn sheep 

lambing and winter range

NSO – designated bighorn sheep

lambing and winter range

CSU – bighorn sheep habitat NSO – designated bighorn sheep 

lambing and winter range
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-89

Table 2.9 Lease Terms and Stipulations by Alternative

Key

CSU = Controlled Surface Use Stipulation NSO = No Surface Occupancy Stipulation

LN = Lease Notice SLT = Standard Lease Terms

NA = Not Applicable TL = Timing Limitation Stipulation

NL = No Lease 

Distances are enumerated and those equal or greater than 100 are feet and those 3 or less are miles. Time periods are month/day

Resource Alt A

(No Action Alternative) Alt B Alt C Alt D(Proposed Alternative)

Range Bighorn Sheep Range: 

CSU - Prior to surface occupancy and

use a plan shall be prepared by the 

proponent of the APD, Sundry Notice, 

etc., and approved by the authorized 

officer in coordination with the state 

wildlife management agency. The 

operator shall not initiate surface 

disturbing activities unless the 

authorized officer has approved the 

plan. The plan must demonstrate to the 

authorized officer’s satisfaction the 

function and suitability of the habitat 

would not be impaired

Raptor Nests (SSS)

(Golden Eagle, Northern 

Goshawk, Ferruginous

Hawk, Red-tailed hawk, 

Sharp-shinned Hawk, 

Swainson’s Hawk, Prairie 

Falcon, Merlin, Osprey, 

Burrowing Owl, Longeared Owl, Short-eared 

Owl)

TL – March 1 to August 1 within 1⁄2 mile 

of raptor nest sites which have been 

active the past 2 years.

NSO – within 1⁄2 mile of raptor nest sites 

which have been active in the past 7 

years

NSO – within 1⁄4 mile of raptor nest sites 

which have been active in the past 7 

years. 

NSO - Surface occupancy and use is 

prohibited within 1⁄4 mile of raptor nest 

sites active within the preceding 7 

years. 

TL - Surface occupancy and use is 

prohibited within 1⁄2 mile of active raptor 

nest sites from March 1 through July 31. 

Sharp-tail Grouse and 

greater prairie chicken 

Leks

NSO – within 1⁄4 mile of sharp-tail 

grouse leks.

NSO – within 2 miles of sharp-tailed 

grouse leks.

CSU – within 1⁄4 mile of sharp-tailed 

grouse lek sites and nesting habitats.

NSO - Surface occupancy and use is 

prohibited on and within 1⁄2 mile of the 

perimeter of leks. 

CSU – for noise levels and minimizing 

disturbance levels around leks and 

nesting habitat

Sharp-tail Grouse and 

greater prairie chicken 

Nesting Zone

TL – March 1 to June 15 in sharptailed grouse nesting habitat within 2 

miles of a lek. 

NSO – within 2 miles of sharp-tailed 

grouse leks.

TL – March 1 to June 15 in sharp-tailed 

grouse nesting habitat within 1⁄2 mile of a 

lek. 

TL - Surface use is prohibited within 2 

miles of the perimeter of sharp-tailed 

grouse and/or greater prairie chicken 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-90 Chapter 2: Resource Management Alternatives

Table 2.9 Lease Terms and Stipulations by Alternative

Key

CSU = Controlled Surface Use Stipulation NSO = No Surface Occupancy Stipulation

LN = Lease Notice SLT = Standard Lease Terms

NA = Not Applicable TL = Timing Limitation Stipulation

NL = No Lease 

Distances are enumerated and those equal or greater than 100 are feet and those 3 or less are miles. Time periods are month/day

Resource Alt A

(No Action Alternative) Alt B Alt C Alt D(Proposed Alternative)

leks from April 1 through July 15. 

Sprague’s Pipit LN TL - Surface-disturbing and disruptive activities would be avoided from April 15 through July 15 in Sprague’s pipit habitat

TL - Surface use for oil and gas exploration, (including geophysical exploration) is prohibited from April 15 through July 15 in 

Sprague’s pipit habitat. 

Threatened &

Endangered Species

LN LN LN LN

Migratory Birds No similar action LN LN LN

State Lands No similar action NL - Where federal mineral estate 

exists, designate all State Wildlife 

Management Areas, Fishing Access 

Sites, and State Parks as No Lease 

areas. 

CSU - Oil and gas leasing, 

development, and exploration would be 

allowed, if habitat suitability within 

designated State Wildlife Management 

Areas, Fishing Access Sites, and State 

Parks is maintained.

NSO – Surface occupancy and use is 

prohibited within the State of Montana 

Wildlife management Areas, Game 

Ranges, Fishing Access Sites, and 

State Parks.

Designated Reservoirs 

with Fisheries

NSO - within 1⁄4 mile of designated 

reservoirs with fisheries. 

NSO - Surface occupancy and use for 

oil and gas exploration (including 

geophysical operations) would be 

prohibited within 1⁄2 mile of designated 

reservoirs with fisheries.

Same as A Same as A

Riparian Areas, 

Wetlands, Floodplains, 

and Streams

NSO – within riparian areas or 

wetlands; within 100 year flood plains 

of major rivers and on water bodies 

and streams.

NSO –within 1⁄4 mile of riparian areas 

and wetlands, water bodies, perennial 

streams, and flood plains of perennial 

streams. 

NSO – within riparian areas and 

wetlands, water bodies, perennial 

streams, and flood plains of perennial 

streams. 

NSO - Surface occupancy and use for 

oil and gas exploration (including 

geophysical operations) would be 

prohibited within riparian areas and 

wetlands, water bodies, perennial and 

intermittent streams, and floodplains of 

perennial streams. 

CSU - Surface occupancy and use 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-91

Table 2.9 Lease Terms and Stipulations by Alternative

Key

CSU = Controlled Surface Use Stipulation NSO = No Surface Occupancy Stipulation

LN = Lease Notice SLT = Standard Lease Terms

NA = Not Applicable TL = Timing Limitation Stipulation

NL = No Lease 

Distances are enumerated and those equal or greater than 100 are feet and those 3 or less are miles. Time periods are month/day

Resource Alt A

(No Action Alternative) Alt B Alt C Alt D(Proposed Alternative)

would be controlled within 300 feet of 

riparian and/or wetland areas. Surfacedisturbing activities would require a plan 

with design features that demonstrate 

how all actions would maintain and/or 

improve the functionality of riparian and 

wetland areas, The plan would

address: (a) potential impacts to riparian 

and wetland resources, (b) mitigation to 

reduce impacts to acceptable levels 

(including timing restrictions), (c) post 

project restoration, and (d) monitoring 

(the operator must conduct monitoring 

capable of detecting early signs of 

change in riparian and/or wetland 

conditions.

Red and Blue Ribbon 

Streams/YCT

No similar action NSO – within 1⁄2 mile of Blue and Red 

Ribbon streams, YCT conservation/core 

populations, YCT streams with 

restoration potential, and YCT suitable 

habitat. 

NSO – within 1⁄4 mile of Class I (Blue 

Ribbon) streams and YCT populations. 

NSO – within 1⁄2 mile of Class I (Blue 

Ribbon) streams and YCT core 

populations. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-92 Chapter 2: Resource Management Alternatives

Table 2.9 Lease Terms and Stipulations by Alternative

Key

CSU = Controlled Surface Use Stipulation NSO = No Surface Occupancy Stipulation

LN = Lease Notice SLT = Standard Lease Terms

NA = Not Applicable TL = Timing Limitation Stipulation

NL = No Lease 

Distances are enumerated and those equal or greater than 100 are feet and those 3 or less are miles. Time periods are month/day

Resource Alt A

(No Action Alternative) Alt B Alt C Alt D(Proposed Alternative)

Cultural & Paleontological Resources

Cultural Resources NSO – The following sites include a 

small buffer zone for protection from oil 

and gas actions:

 Steamboat Butte 

 Bruder-Janich Site

 Paul Duke Site 

 Demi-John Flat NR District 

 Young’s Point 

 Bighorn Mouth North Cliffs Rock 

Art Site 

 Gyp Springs Site 

 Hoskins Basin Archaeological 

District 

NL –

 Steamboat Butte 

 Bruder-Janich Site 

 Paul Duke Site 

 Demi-John Flat NR District 

 Bighorn Mouth North Cliffs Rock 

Art Site 

 Gyp Springs Site 

 Hoskins Basin Archaeological 

District

NSO – on the following sites, districts, or 

areas:

 Steamboat Butte 

 Bruder-Janich Site 

 Paul Duke Site 

 Demi-John Flat NR District 

 Bighorn Mouth North Cliffs Rock Art

 Gyp Springs Site 

 Hoskins Basin Archaeological 

District

 Bandit Site

NSO – on the following sites, districts, 

or areas:

 Steamboat Butte 

 Bruder-Janich Site 

 Paul Duke Site 

 Demi-John Flat NR District 

 Bighorn Mouth North Cliffs Rock 

Art 

 Gyp Springs Site 

 Hoskins Basin Archaeological 

District

 Bandit Site

NSO – within sites or areas designated 

for conservation use, public use or 

socio-cultural use

NSO within National Register eligible

sites or areas designated for 

conservation use, public use, scientific 

use, or traditional use.

NSO within National Register Eligible 

sites or areas designated for 

conservation use, public use, scientific 

use, or traditional use, including those 

areas determined to be sacred sites, 

traditional cultural properties, and/or 

designated for traditional use.

NSO within National Register Eligible 

sites or areas designated for 

conservation use, public use, scientific 

use, or traditional use, including those 

areas determined to be sacred sites, 

traditional cultural properties, and/or 

designated for traditional use

No Similar Action NSO 1⁄2 mile 

Bridger Cut-Off Trail 

Meeteetse Trail 

CSU - 1⁄4 mile 

Bridger Cut-Off Trail 

Meeteetse Trail 

CSU – 1⁄4 mile 

Bridger Cut-Off Trail 

Meeteetse Trail

Historic Properties

(NHPA, AIRFA, 

NAGPRA, EO 13007)

LN – LN LN LN

Sacred sites and 

Historic Properties

LN LN LN LN
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-93

Table 2.9 Lease Terms and Stipulations by Alternative

Key

CSU = Controlled Surface Use Stipulation NSO = No Surface Occupancy Stipulation

LN = Lease Notice SLT = Standard Lease Terms

NA = Not Applicable TL = Timing Limitation Stipulation

NL = No Lease 

Distances are enumerated and those equal or greater than 100 are feet and those 3 or less are miles. Time periods are month/day

Resource Alt A

(No Action Alternative) Alt B Alt C Alt D(Proposed Alternative)

Cultural Inventories LN LN LN LN

Traditional Cultural 

Properties and 

Traditional Use Areas

No similar action NSO – within 1⁄2 mile of designated 

TCPs or designated traditional use 

areas.

NSO – within 1⁄2 mile of designated TCPs 

or designated traditional use areas.

NSO – within 1⁄2 mile of designated 

TCPs or designated traditional use 

areas.

Lake Mason NWR LN - Cultural sites are located in the 

_____, Sec. __ T. ___ R. . This 

parcel is located adjacent to the Lake 

Mason National Wildlife Refuge.

In accordance with 43 CFR 3101.1-2, 

additional mitigation may be required 

in regard to exploration and 

development.

LN- Surface occupancy and use is 

subject to the following operating 

constraints:

Cultural sites are located in the _____, 

Section___ T. ___., R. ___. This parcel 

is located adjacent to the Lake Mason 

National Wildlife Refuge. 

In accordance with 43 CFR 3101.1-2, 

additional mitigation may be required in 

regard to exploration and development. 

LN - Surface occupancy and use is 

subject to the following operating 

constraints:

Cultural sites are located in the _____, 

Section___ T. ___., R. ___. This parcel 

is located adjacent to the Lake Mason 

National Wildlife Refuge. 

In accordance with 43 CFR 3101.1-2, 

additional mitigation may be required in 

regard to exploration and development. 

LN – Surface occupancy and use is 

subject to the following constraints: 

Cultural sites are located in the _____, 

Sec. __ T. ___ R. . This parcel is

located adjacent to the Lake Mason 

NWR and may contain cultural sites. 

In accordance with 43 CFT 3101.1-2 

additional mitigation may be required 

in regard to exploration and 

development.

Cemeteries No similar action NSO – Surface occupancy and use is prohibited for oil and gas exploration and development within and for a distance of 300 

feet from the boundary of a cemetery.

Paleontological

Resources

NSO – Surface occupancy and use is 

prohibited within designated 

paleontological sites.

NSO – Surface occupancy and use is prohibited within designated or recorded paleontological sites.

LN - For oil and gas leasing, exploration, and development occurring within PFYC Class 3 or higher, a lease notice would be attached. Assessment, inventory, and/or 

mitigation would be required based on PFYC class.

Vegetation, Wetlands, and Water Quality

Riparian Areas and 

Floodplains

NSO – Surface occupancy and use is 

prohibited within riparian areas, 100 

year floodplains of major rivers, and on 

water bodies and streams.

NSO – within 1⁄4 mile of riparian areas 

and wetlands, water bodies, perennial 

streams, and flood plains of perennial 

streams. 

NSO - within riparian areas and wetlands, 

water bodies, perennial streams, and 

flood plains of perennial streams.

NSO - Surface occupancy and use for 

oil and gas exploration (including 

geophysical operations) would be 

prohibited within riparian areas and 

wetlands, water bodies, perennial and 

intermittent streams, and floodplains of 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-94 Chapter 2: Resource Management Alternatives

Table 2.9 Lease Terms and Stipulations by Alternative

Key

CSU = Controlled Surface Use Stipulation NSO = No Surface Occupancy Stipulation

LN = Lease Notice SLT = Standard Lease Terms

NA = Not Applicable TL = Timing Limitation Stipulation

NL = No Lease 

Distances are enumerated and those equal or greater than 100 are feet and those 3 or less are miles. Time periods are month/day

Resource Alt A

(No Action Alternative) Alt B Alt C Alt D(Proposed Alternative)

perennial streams. 

CSU - Surface occupancy and use 

would be controlled within 300 feet of 

riparian and/or wetland areas. 

Surface-disturbing activities would 

require a plan with design features that 

demonstrate how all actions would 

maintain and/or improve the 

functionality of riparian and wetland 

areas, The plan would address: (a) 

potential impacts to riparian and 

wetland resources, (b) mitigation to 

reduce impacts to acceptable levels 

(including timing restrictions), (c) post 

project restoration, and (d) monitoring 

(the operator must conduct monitoring 

capable of detecting early signs of 

change in riparian and/or wetland 

conditions. 

State-designated 

Source Water 

Protection Areas

No similar action NSO - Surface occupancy and use is 

prohibited within State-designated 

Source Water Protection Areas

Sensitive Plant 

Species 

No similar action NSO – within 1⁄4 mile of special status 

plant species or populations. 

CSU – inventory required prior to oil and 

gas leasing, exploration and/or 

development surface disturbing activities.

CSU – inventory required prior to oil 

and gas leasing, exploration and/or 

development surface disturbing 

activities.

Sensitive Soils and 

Rock Outcrops

CSU Slopes > 30% NSO Slopes > 30% CSU Slopes > 30% CSU - all sensitive soils 

NSO - all badland and rock outcrop

areas
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-95

Table 2.9 Lease Terms and Stipulations by Alternative

Key

CSU = Controlled Surface Use Stipulation NSO = No Surface Occupancy Stipulation

LN = Lease Notice SLT = Standard Lease Terms

NA = Not Applicable TL = Timing Limitation Stipulation

NL = No Lease 

Distances are enumerated and those equal or greater than 100 are feet and those 3 or less are miles. Time periods are month/day

Resource Alt A

(No Action Alternative) Alt B Alt C Alt D(Proposed Alternative)

Invasive Species and 

Noxious Weeds

No similar action CSU - Surface occupancy or use is 

subject to the following operating 

constraints. 

The following noxious weed(s) has been 

identified within the boundaries of the 

lease parcel:

CSU - Surface occupancy or use is 

subject to the following operating 

constraints. 

The following noxious weed(s) has been 

identified within the boundaries of the 

lease parcel:

CSU – Surface occupancy and use is 

subject to the following operating 

constraints: The following invasive 

species and/or noxious weeds have 

been identified within the boundaries 

of the lease parcel: 

LN - There may be noxious weeds 

present on the lease parcel. Prior to 

any surface disturbing activities, the 

operator would be responsible for 

providing an Integrated Weed 

Management (IWP) plan. The operator 

would be responsible for the cost of the 

treatment and monitoring throughout the 

duration of the lease as long as oil and 

gas activities are occurring on the lease.

LN - There may be noxious weeds 

present on the lease parcel. Prior to any 

surface disturbing activities, the operator 

would be responsible for providing an 

Integrated Weed Management (IWP) 

plan. The operator would be responsible 

for the cost of the treatment and 

monitoring throughout the duration of the 

lease as long as oil and gas activities are 

occurring on the lease.

LN - There may be noxious weeds 

present on the lease parcel. Prior to 

any surface disturbing activities, the 

operator would be responsible for 

providing an Integrated Weed 

Management (IWP) plan. The 

operator would be responsible for the 

cost of the treatment and monitoring 

throughout the duration of the lease as 

long as oil and gas activities are 

occurring on the lease.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-96 Chapter 2: Resource Management Alternatives

Table 2.9 Lease Terms and Stipulations by Alternative

Key

CSU = Controlled Surface Use Stipulation NSO = No Surface Occupancy Stipulation

LN = Lease Notice SLT = Standard Lease Terms

NA = Not Applicable TL = Timing Limitation Stipulation

NL = No Lease 

Distances are enumerated and those equal or greater than 100 are feet and those 3 or less are miles. Time periods are month/day

Resource Alt A

(No Action Alternative) Alt B Alt C Alt D(Proposed Alternative)

Visual Resources, Caves and Karsts, Lands with Wilderness Characteristics, Recreation, and Travel Management

VRM II, III, & IV CSU – VRM Class II CSU – VRM Class II – IV CSU – VRM Class II CSU – VRM Class II – IV 

Caves & Karst No similar action NSO – within 1⁄2 mile of cave entrances CSU – Cave and Karst Areas CSU – Cave and Karst Areas

Lands with Wilderness 

Characteristics 

Manage 1,925 acres (adjacent to Pryor 

Mountain and Big Horn Tack-On 

WSAs) as lands with wilderness 

characteristics (no lease).

NL NL NL 

SRMAs

NSO – developed recreation areas 

and areas receiving high concentrated 

use.

NSO – SRMAs: 

 Sundance Lodge Recreation Area

 Four Dances Natural Area ACEC 

 Shepherd Ah-Nei Recreation Area

 Acton Recreation Area 

 Bundy Island

 South Hills TMA

 Pryor Mountain TMA 

CSU – in developed recreation areas and 

SRMAs. 

NSO – SRMAs:

 Sundance Lodge Recreation 

Area 

 Four Dances Natural Area ACEC 

 Shepherd Ah-Nei Recreation 

Area 

 Acton Recreation Area

 Yellowstone River Corridor: 1⁄2 

mile corridor 

No similar action No similar action CSU – SRMAs: 

 Asparagus Point 

 Pryor Mountain TMA 

 Horsethief TMA 

 South Hills TMA 

Travel Management CSU – Oil and gas activities would comply with all motorized vehicle use and travel plan restrictions, including seasonal restrictions and areas closed to motorized travel

Realty, Cadastral Survey, and Lands

LWCF Lands No similar action NSO – Surface occupancy and use is prohibited for oil and gas exploration and development on lands acquired with Land and 

Water Conservation Funds.

Unincorporated Towns 

and Residences 

NSO – 300 feet from human occupied 

buildings

NSO – Surface occupancy and use is prohibited for oil and gas exploration and development within and 500 feet from 

unincorporated towns or human occupied residential structures. 

Setback from Human No similar action LN –Facilities not allowed within 500 feet of human occupied residences.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-97 

Table 2.9 Lease Terms and Stipulations by Alternative

Key

CSU = Controlled Surface Use Stipulation NSO = No Surface Occupancy Stipulation

LN = Lease Notice SLT = Standard Lease Terms

NA = Not Applicable TL = Timing Limitation Stipulation

NL = No Lease 

Distances are enumerated and those equal or greater than 100 are feet and those 3 or less are miles. Time periods are month/day

Resource Alt A

(No Action Alternative) Alt B Alt C Alt D(Proposed Alternative)

Occupied Residences 

Requirement

Land Use 

Authorizations

LN – The specifically authorized acreage for land use should be avoided by oil and gas exploration and development activities. All authorized surface land uses are valid 

claims to prior existing rights unless the authorization states otherwise.

Minerals

Coal Leases NSO - Surface occupancy and 

directional drilling are prohibited within 

the boundaries of existing coal leases.

NSO - Surface occupancy and 

directional drilling are prohibited within 

the boundaries of existing coal lease

NSO - Surface occupancy and directional 

drilling are prohibited within the 

boundaries of existing coal lease

NSO – Surface occupancy and use is 

prohibited for oil and gas exploration 

and development within the 

boundaries of existing coal leases.

Special Designations

Pompeys Pillar 

National Monument

NL NL NL NL

Pompeys Pillar ACEC 

(Excluding the NM)

NSO NL NSO NSO

Bridger Fossil Area 

ACEC

NL NL NSO (no WEMS) NL

East Pryor ACEC NL NL (COAs for existing leases) NL NL

Four Dances Natural

Area ACEC

NL NL (COAs for existing leases) NL NL

Grove Creek ACEC SLT NL (COAs for existing leases) NSO (COAs for existing leases)

Meeteetse Spires 

ACEC

NL (965 acres)

Petroglyph Canyon 

ACEC

NL NSO NL

Pryor Foothills 

Research Natural Area 

(RNA) ACEC

SLT NL NSO – known plant sites. 

Inventory prior to surface disturbing 

activities (CSU).

NSO – 1⁄4 mile buffer known sensitive 

plant sites. 

CSU - Inventory prior to surface 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-98 Chapter 2: Resource Management Alternatives

Table 2.9 Lease Terms and Stipulations by Alternative

Key

CSU = Controlled Surface Use Stipulation NSO = No Surface Occupancy Stipulation

LN = Lease Notice SLT = Standard Lease Terms

NA = Not Applicable TL = Timing Limitation Stipulation

NL = No Lease 

Distances are enumerated and those equal or greater than 100 are feet and those 3 or less are miles. Time periods are month/day

Resource Alt A

(No Action Alternative) Alt B Alt C Alt D(Proposed Alternative)

disturbing activities.

(Note: All lands in this ACEC east of 

Crooked Creek Road are within an 

lands w/ wilderness characteristics unit 

and are No Lease)

Stark Site ACEC NSO NSO NSO NSO

Weatherman Draw 

ACEC

NSO (no WEMs) NL NSO (No WEMS) NL (4,986 acres).

NSO (7,291 acres) (No WEMS)

Greater Sage-Grouse 

Habitat ACEC

No ACEC Designation 

See page 2-44 (Greater Sage-Grouse

–Priority Habitat Management Areas 

(PHMAs) for lease terms and 

stipulations by alternative

NL – Closed to future oil and gas 

leasing, exploration and/or development

No ACEC Designation

See Greater Sage-Grouse – Priority 

Habitat Management Areas (PHMAs) for 

Habitat for lease terms and stipulations 

by alternative

No ACEC Designation 

See Greater Sage-Grouse –Priority 

Habitat Management Areas (PHMAs) 

for lease terms and stipulations by 

alternative

National Historic Trails No similar action NSO – within 1⁄2 mile of the L&C and NP 

NHTs.

CSU – within 1⁄2 mile of the L&C and NP 

NHTs with stipulations.

NSO – within 1⁄2 mile of the L&C and 

NP NHTs.

Wild and Scenic 

Rivers

No similar action NL – WSR-suitable segments. NSO – within 1⁄4 mile of WSR- eligible. NSO – within 1⁄2 mile of WSR-eligible 

and suitable segments. 

Pryor Mountain Wild 

Horse Range

NL

Wilderness Study 

Areas

NL

Note:

a. Refer to Recommended COAs for Existing Leases in Appendix D 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-99

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Air 

Air resource goals are to ensure authorizations and management activities comply with local, state, and federal air quality regulations and requirements, including compliance with the National 

Ambient Air Quality Standards (NAAQS) and under the Clean Air Act (amended 1990), the Montana Ambient Air Quality Standards (MAAQS), and the Wyoming Ambient Air Quality Standards 

(WAAQS). The BLM authorized activities would also be managed to reduce air quality and climate change impacts by incorporating management actions to reduce emissions of criteria pollutants 

and hazardous air pollutants. 

Air – Desired Outcomes (Goals and Objectives)

 Ensure authorizations and management activities comply with local, state, and federal air quality regulations and requirements.

 Manage BLM authorized activities to maintain compliance with the NAAQS, MAAQS, and the Montana State Implementation Plan.

 Reduce air quality and air quality related value (AQRV) impacts, including visibility and acid deposition, by including technically and economically feasible management actions to reduce 

emissions of criteria and hazardous air pollutants.

Air – Management Common to All Alternatives

The BLM authorized activities would stipulate requirements to reduce fugitive dust emissions from construction activities and sites with surface disturbance. 

The BLM authorized activities would stipulate requirements to reduce fugitive dust emissions from travel on high-traffic unpaved roads.

The BLM authorized activities would stipulate engine and stationary source emission control requirements needed to ensure compliance with NAAQS, MAAQS, WAAQS, and the 

Montana SIP.

If unacceptable air quality or AQRV degradation trends are identified and are determined to be caused by BLM authorized activities, additional emission control would be included in the 

BLM authorized activities.

The BLM would coordinate smoke management with the Montana-Idaho Airshed Management Group, the Montana Department of Environmental Quality (MDEQ), and the Yellowstone 

County Air Quality Unit in Yellowstone County. 

Management of the non-attainment area(s) within the planning area would continue to be the responsibility of the State of Montana (Map 4). 

Climate Change

The BLM goals and objectives for addressing climate change within the Billings Field Office are to reduce GHG emissions and to manage diverse, healthy landscapes to be resilient to stressors, 

including climate change, and incorporate adaptive, flexible management actions to adjust to changing climatic conditions. 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 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 decision-making process. 

Climate Change – Desired Outcomes (Goals and Objectives)

 For oil and gas activities, reduce GHG emissions on a unit-production basis.

 Evaluate the observed and anticipated ling-term dynamic of climate change and reduce GHG emissions from projects when feasible.

 Provide for diverse, healthy ecosystems that are resilient to stressors, such as climate change.

 Provide for flexible, adaptable management that allows for timely responses to changing climatic conditions.

 Maintain or improve the ability of the BLM lands to reduce (sequester) atmosphere GHGs.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-100 Chapter 2: Resource Management Alternatives

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Climate Change – Management Common to All Alternatives

Promote vegetative capture and storage of carbon, with consideration for resource objectives, by using Rangeland Standards and Montana Forestry/Rangeland BMP guidelines at the 

project planning and implementation level.

Identify opportunities for geophysical carbon sequestration on federal lands where federal mineral ownership exists as outlined in national guidance. 

The BLM authorized activities would consider the use of BMPs to reduce emissions of GHGs.

Priority would be placed on actions such as: enhanced energy efficiency, use of lower GHG-emitting technologies and/or renewable energy, planning for carbon capture and 

sequestration, and the capture or beneficial use of fugitive methane emissions. 

Adjust the timing of BLM-authorized activities as needed to accommodate long-term changes in seasonal weather patterns, while considering the impacts to other resources and resource 

uses.

Soil

The BLM goals for the management of soil resources within the Billings Field Office are to maintain or improve overall soil health and productivity. To accomplish this, the Billings Field Office 

proposes to implement a variety of management activities that review and/or restrict various land and resource uses that have the potential to inhibit soil health and watershed stability. Actions 

specific to soil resource uses are listed below, by alternative and are primarily focused on the severity of the slope where land use authorizations may occur, cross referenced by the known soil 

characteristics that occur on any given site. It is important to note that the overall goal of watershed health is directly related to the health of soils and there are many management actions under 

other resource areas that are designated to benefit soil resources (grazing management, vegetation management, forestry, etc.). Those actions listed below under the “Management Common to All 

Alternatives” form the basis for the soils management program. Those individual management actions within the various alternatives consider different levels of restrictions that may impact other 

resource uses.

Soil – Desired Outcomes (Goals and Objectives)

 Maintain or improve soil health and productivity (e.g., chemical, physical, and biotic properties) by implementing Standards for Rangeland Health and other soil protection measures.

 Minimize accelerated soil erosion and compaction and maintain surface soil water infiltration based on site specific conditions.

 Manage BLM-authorized activities to minimize soil mass movement (primarily from accelerated water/wind erosion) resulting from fire, above-ground disturbances, and accelerated stream bank 

erosion. 

 Manage soil resources to:

 Prevent or minimize accelerated soil erosion

 Prevent or minimize flood and sediment damage, as needed

 Establish desirable plant communities, maintain existing desirable vegetative ground cover composition consistent with the ecological site characteristics, and sustain other ground cover 

including biotic crusts and litter to increase or maintain surface soil stability and nutrient cycling.

 Manage BLM-authorized activities to minimize sediment delivery to creeks, streams, and standing bodies of water (lakes, ponds, reservoirs, etc.). 

Soil – Management Common to All Alternatives

BLM-authorized surface-disturbing activities would include plans for reclamation. Site-specific reclamation actions should reflect the complexity of the project, environmental concerns,

and the reclamation potential of the site, giving consideration to soils susceptible to erosion and compaction when assessing projects. 

The Standards for Rangeland Health would be used to assess compaction and erosion issues.

Respond in a timely manner to assess soil and mitigate potential soil damage after wildland or prescribed fire, in accordance with BLM Emergency Stabilization and Rehabilitation 

standards.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-101

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Identify opportunities to construct water flow, sediment control and watershed stabilization projects in partnership with local, state, and federal programs.

Soil – Management Actions by Alternative

No current management decision provided. Ground-disturbing authorizations would not be 

allowed in areas where erosion would not be 

effectively controlled or mitigated. 

Ground-disturbing authorizations would be 

allowed in areas where erosion would be 

effectively controlled or mitigated with a 

BLM-approved design plan. 

Same as C. 

Mitigate impacts of logging by prohibiting 

wheeled or tracked equipment operation on 

sustained slopes greater than 35% and reseeding of grasses and forbs on skid trails, 

landings, and roads. 

Surface disturbing activities would not be 

allowed on fragile soils with, steep slopes 

>30%, and soils with low reclamation potential 

and highly erodible characteristics.

Use Rangeland Health Standards and BMPs 

to assess and mitigate disturbance of soils 

(e.g., erosion, re-vegetation, fiber mats and 

other restoration measures, etc.).

Surface disturbing activities would not be 

allowed on soils with slopes >45% or 

fragile soils with low reclamation potential 

and highly erodible characteristics

Use Rangeland Health Standards and 

BMPs to assess and mitigate disturbance 

of soils (e.g., erosion, re-vegetation, fiber 

mats and other restoration measures, 

etc.).

Surface disturbance on slopes >25%, soils 

with low reclamation potential, and highly 

erodible characteristics would be avoided 

whenever possible. If disturbance could not 

be avoided an approved mitigation and 

reclamation plan would be required prior to 

activities taking place.

Use Rangeland Health Standards and BMPs 

to assess and mitigate disturbance of soils 

(e.g., erosion, re-vegetation, fiber mats and 

other restoration measures, etc.).

Mitigate impacts on slopes >30% for oil and 

gas leasing and development (CSU) 

No surface occupancy on slopes >30% for oil 

and gas development and leasing (NSO). 

Same as A Mitigate impacts on sensitive soils for oil and 

gas leasing and development (CSU) 

Oil and gas surface occupancy and use is 

prohibited on badlands and rock outcrop. 

(NSO)

No current management decision provided Require engineering design, geologic analysis, 

and mitigation planning when considering 

activities in areas that are prone to slumping or 

instability.

Use BMPs and Rangeland Health 

Standards at the project level to assess 

and mitigate impacts to fragile and 

unstable soils prone to slumping.

Same as Alternative C.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-102 Chapter 2: Resource Management Alternatives

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Water

The BLM goals for water resources are primarily driven by compliance with applicable federal and state water quality standards, aiming to protect water quality for municipal, residential, industrial, 

agricultural, recreational, and resource benefit while providing multiple use opportunities for public lands. The actions listed below focus on restrictions to BLM authorized activities to protect water 

quality by maintaining or restoring the chemical, physical, and biological integrity of water resources. These proposed actions accomplish this goal through promoting proper drainage and watershed 

health by maintaining riparian functionality and minimizing surface disturbance to deter excessive erosion and maintain stream channel and upland morphological conditions that can fully support 

beneficial uses. Cooperating with MT DEQ to develop and monitor TMDL plans is an essential action necessary to maintain or improve water quality, stipulated by the Clean Water Act. The 

“Management Common to All Alternatives” section is the baseline of actions used to meet the described goals, while the actions specific to each alternative offer various degrees of protection that 

may impact other resource uses. The impacts to other resources are analyzed in Chapter 4 of this document.

Water – Desired Outcomes (Goals and Objectives)

 Maintain and/or improve surface water and groundwater resources, maintain compliance with applicable federal and state water quality standards, and improve water quality where practical 

within the scope of the BLM’s authority

 Restore and/or maintain the chemical, physical, and biological integrity of water resources to protect designated beneficial uses and achieve water quality standards.

 Minimize erosion and subsequent sedimentation for improved stream and watershed health

 Maintain or improve morphological conditions to a stable state that can fully support beneficial uses

 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

 Floodplains are properly functioning allowing for aquifer recharge, wildlife habitat, and flood water retention (Map 8)

 Stream channel conditions are representative of the site capacity and dimension and moderate flows to allow floodplain aquifer recharge and safeguard floodplains

 Secure and protect water rights for beneficial uses on the BLM administered lands to ensure water availability to the BLM authorized uses and programs

Water – Management Common to All Alternatives

BLM would participate in the development, implementation, and monitoring of water quality restoration plans/TMDL plans.

Use Rangeland Health guidelines and other management strategies to meet the Standards for Rangeland Health (Standards 2, 9 &12).

Use BMPs and other practical management strategies to meet water quality standards set forth in rules/laws of federal, tribal, state, and local agencies.

Acquire in-stream water rights where appropriate, to ensure water availability for multiple-use management and proper functioning riparian and upland areas.

Cooperate with Montana State DEQ and local communities to implement Source Water Protection Programs (SWPPs) and preserve source water.

Water – Management Actions by Alternative

No current management decision provided Mitigation of surface-disturbing activities would be applied where needed to minimize impacts of human activities on riparian, water and 

floodplain resources, consistent with the stipulations identified for oil and gas development in this section. Mitigation measures would be 

applied during activity level planning if an on-site evaluation of the project area indicates the presence of these resources. Exceptions may 

be granted by the authorized officer, if an environmental review demonstrates that effects could be mitigated to an acceptable level or 

portions of the area can be occupied without affecting a particular habitat. Exceptions may also be granted where the short-term effects are 

mitigated by the long-term benefits (e.g., prescribed fire, wildlife monitoring, forest health treatments, and habitat restoration).

As defined in the Glossary, surface-disturbing and disruptive activities would not prohibit all activities or authorized uses. For example, 

emergency activities (e.g., fire suppression, search and rescue), rangeland monitoring, routine maintenance associated with an approved 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-103

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

authorization, dispersed recreational activities (e.g., hunting, hiking), and livestock grazing are not considered surface-disturbing or 

disruptive activities.

No similar action Oil and gas surface occupancy and use is prohibited within State-designated Source Water Protection Areas (NSO)

Stabilize watershed conditions where grazing 

management or range condition is 

contributing to excessive erosion. 

Use Rangeland Health Standards and 

Guidelines and BMPs to assess and mitigate 

impacts in areas where grazing or range 

condition is contributing to excessive erosion.

Restrict or limit BLM-authorized activities that 

contribute to deteriorating watershed 

conditions and/or excessive erosion. 

Same as Alternative A Restrict or limit BLM-authorized activities that 

contribute to deteriorating watershed 

conditions and/or excessive erosion. 

Use Rangeland Health Standards and 

Guidelines and BMPs to mitigate impacts 

from activities that are contributing to 

excessive erosion.

No current management decision provided. Close and reclaim roads where runoff 

contributes to accelerated decline in water 

quality and/or habitat. 

Seasonally close roads where runoff 

contributes to accelerated decline in water 

quality and/or habitat.

Monitor route conditions and 

temporarily/permanently close roads and/or 

apply mitigation measures where runoff 

contributes to accelerated decline in water 

quality and/or habitat, and/or reclaim.

Any allowed discharge of oil and gasproduced water from point sources from 

public lands would be in compliance with 

Montana DEQ requirements.

Prohibit disposal of new surface discharge of 

oil and gas produced water into streams or 

other flow-connected surface features on BLMadministered land.

Avoid the discharge of oil and gasproduced water from point sources to 

public lands, including stream channels 

and uplands, as a means of disposal. Any 

allowed discharge would be in compliance 

with Montana DEQ requirements. 

Same as Alternative C

Oil and gas leasing and development would 

only be allowed with an NSO stipulation on 

riparian areas, wetlands, water bodies, and 

100-year flood plains of major rivers. 

Surface occupancy and use for oil and gas 

exploration (including geophysical operations) 

would be prohibited within 1⁄4 mile of riparian 

areas and wetlands, water bodies, perennial 

streams, and flood plains of perennial streams. 

Surface occupancy and use for oil and 

gas exploration (including geophysical 

operations) would be prohibited within 

riparian areas and wetlands, water bodies, 

perennial streams, and flood plains of 

perennial streams. 

Surface occupancy and use for oil and gas 

exploration (including geophysical 

operations) would be prohibited within 

riparian areas and wetlands, water bodies, 

perennial and intermittent streams, and 

floodplains of perennial streams. (NSO)

Surface occupancy and use would be 

controlled within 300 feet of riparian and/or 

wetland areas. Surface-disturbing activities 

would require a plan with design features that 

demonstrate how all actions would maintain 

and/or improve the functionality of riparian 

and wetland areas, The plan would address: 

(a) potential impacts to riparian and wetland 

resources, (b) mitigation to reduce impacts to 

acceptable levels (including timing 
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Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

restrictions), (c) post project restoration, and 

(d) monitoring (the operator must conduct 

monitoring capable of detecting early signs of 

change in riparian and/or wetland conditions. 

(CSU)

Vegetation: Forests and Woodlands

The BLM would manage the public forests and woodlands to maintain and enhance the health, productivity, and biological diversity of these ecosystems. A balance of natural resource benefits 

would be provided to present and future generations. The management of forest and woodland resources would be consistent with the principles of multiple use and sustained yield. The Federal 

Land Policy and Management Act of 1976 (FLPMA) directs the BLM to prepare interdisciplinary land use plans based on the principles of multiple-use and sustained yield. The ecosystem 

management concept is at the core of FLPMA and the basis for all forestry activities in the BLM. All forest management actions would meet or exceed the Montana Streamside Management Zone 

(SMZ) law and Water Quality Best Management Practices for Montana Forests (BMPs) to ensure the protection of soil, water, riparian, and fisheries resources. The BLM’s forestry program 

promotes forest and woodland communities that are healthy, resilient, and vigorous. Forestland mosaics are managed for a diversity of stand structures and species components that complement 

other resource values, including but not limited to recreation, wildlife, rangelands, fisheries, and wood fiber production. 

Vegetation: Forests and Woodlands – Desired Outcomes (Goals and Objectives)

 Restore and/or maintain the health and productivity of public forests and woodlands to provide a balance of forest and woodland resource benefits to current and future generations.

 Manage forests and woodlands, considering factors such as species, density, canopy cover, age class, and stand health and understory components, to restore vitality, health, and diversity.

 Promote forest vegetation recovery on forested lands after wildfire events.

 Use fire and fuels treatments as an integrated approach to meet forest health objectives.

 Return forests toward a more natural forest condition class and fire regime by implementing treatments that move forest conditions toward Fire Regime Condition Class I (FRCC1).

 Natural disturbance regimes would be maintained or mimicked so that plant communities are resilient to climate change and periodic outbreaks of insects, disease, and wildfire.

 Manage quaking aspen stands to promote vigor and resilience and to promote expansion of its current range.

 Manage coniferous and deciduous forests to promote vigor and resilience. 

 Manage forests and woodlands to meet or exceed the standards identified in BLM’s Standards for Rangeland Health (Standards 1 and 5)

Vegetation: Forests and Woodlands – Management Common to All Alternatives

An inventory and health assessment of forested stands within the planning area would be completed during the life of the plan, as budget and other priorities allow.

Monitor forest health indicators, including populations of insects, and apply forest management methods which promote the appropriate level of stocking and function based on the forest 

type.

Manage vegetation structure, density, species composition, patch size, pattern, and distribution in a manner which reduces the occurrence of unnaturally large and severe wildfires and 

forest insect/disease outbreaks. The amount of vegetation to be treated may vary and would be based on inventory and monitoring to meet desired objectives.

Treat stands at risk of catastrophic wildfire and epidemic levels of forest insects and/or disease as a high priority.

Conduct forest and woodland health management activities using a prescription based on the best available science. At a minimum, prescriptions would require a description of current 

stand conditions and desired future conditions. 

Forest management would emphasize forest structures with large trees appropriate to the forest type, snag recruitment, and large diameter trees for cavity nesters where appropriate.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-105

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Use adaptive management strategies that address climate change in order to maintain or enhance forest and woodland ecosystems

Vegetation: Forests and Woodlands – Management Actions by Alternative

No similar management decision Remove conifers encroaching into sagebrush 

habitats. Prioritize treatments closest to 

occupied sage-grouse habitats and near 

occupied leks, and where juniper 

encroachment is phase 1 or phase 2. Use of 

site-specific analysis and principles like those 

included in the FIAT report (Chambers et. al., 

2014) and other ongoing modeling efforts to 

address conifer encroachment would help 

refine the location for specific priority areas to 

be treated. 

Mechanical harvest (e.g. soil disturbing 

activities) limited to slopes < 35%, but line or 

helicopter operations allowed on slopes > 

35%. 

Would allow operations on approx. 68% of

forested acres not restricted by WSAs or 

ACECs. 

Wheeled and tracked vehicle operation would 

not be allowed on sustained slopes greater 

than 30%.

Would allow operations on approx. 60% of 

forested acres not restricted by WSAs or 

ACECs. 

Mechanical harvest (e.g. soil disturbing 

activities) limited on slopes > 30%, but line or 

helicopter operations allowed.

Wheeled and tracked vehicle operation 

would not be allowed on sustained slopes 

greater than 45%.

Would allow operations on approx. 79% of 

forested acres not restricted by WSAs or 

ACECs. 

Mechanical harvest (e.g. soil disturbing 

activities) limited on slopes > 45%, but line 

or helicopter operations allowed.

Wheeled and tracked vehicle operation would 

be avoided on sustained slopes greater than 

25% whenever possible. If operations could 

not be avoided, an approved mitigation and 

reclamation plan would be required prior to 

activities taking place.

Would allow operations on approx. 60% of 

forested acres not restricted by WSAs or 

ACECs.

Mechanical harvest (e.g. soil disturbing 

activities) limited on slopes > 25% without an 

approved mitigation and reclamation plan in 

place, but line or helicopter operations 

allowed. 

No current management decision provided. Emphasis would be placed on retention and 

acquisition of forested lands. 

Disposal, retention, or acquisition of forested 

lands would consider the values of the forest 

type, habitat diversity, and potential for carbon 

sequestration.

Dispose of isolated forested lands where 

appropriate land/resource values are 

considered. 

Same as Alternative B. 

9,500 acres of forested land would be 

protected from cutting, except where needed 

for other resource values. Protective areas 

include Pryor Mountain WSA, Bighorn TackOn WSA, Burnt Timber WSA, Bad Canyon, 

Same as Alternative A. Cutting for density management, forest 

health, and fuels management would be 

allowed unless otherwise restricted (e.g., 

WSAs, ACECs, etc.). Removal of large 

trees would be allowed on forested lands 

Cutting for density management, forest 

health, and fuels management would be 

allowed unless otherwise restricted (e.g., 

WSAs, ACECs, etc.). Large trees would be 

retained in numbers and species as 
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Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Young’s Point, Asparagus Point, Shepherd 

Ah-Nei and Acton.

consistent with wildlife requirements and 

other resources values.

appropriate for the forest type and 

successional stage, consistent with wildlife 

requirements and other resource values. 

Vegetation: Rangelands

The goal of the vegetation management program is to manage vegetative resources that maintain a diversity of ecological conditions while providing for a variety of multiple uses that are based on 

sound biological principles and the best available science. The BLM partners with other natural resource management agencies to provide sound ecological management of rangeland resources, 

implementing a variety of management actions that regulate resource uses or activities that have the potential to degrade or enhance rangeland habitats. The actions specific to vegetation resource 

management are listed below, by alternative. These actions primarily focus on varying degrees of ground disturbance in sagebrush dominated communities and crested wheatgrass monocultures. 

These actions would guide the authorization of BLM activities, ensuring the maintenance or enhancement of rangelands resources. Actions under “Management Common to All Alternatives”, sets 

the basis for vegetation management, while those actions in various alternatives provides a range of levels of manipulation that may impact other resource uses. Some actions associated with other 

resources (soils, water, wildlife, vegetative communities, etc.) benefit rangeland resources by concentrating on rangeland health. “Rangeland Health” is the minimum ecological standard, 

independent of the rangeland's use and how it is managed. If rangeland health is protected, a variety of uses could be appropriate for any particular rangeland. For more information on rangeland 

health standards, see Appendix I.

Vegetation: Rangelands – Desired Outcomes (Goals and Objectives)

 Manage vegetative resources to maintain a diversity of ecological conditions on rangelands while providing for a variety of multiple uses that are economically feasible, and based on sound 

biological principles and the best available science. 

 Manage vegetative communities to restore, maintain or enhance vegetation community health, habitat, composition and diversity to provide a mix of successional stages that incorporate 

diverse structure and composition in the desired vegetation types. 

 Maintain, improve, enhance, or restore habitat to facilitate the conservation, recovery, and maintenance of populations of native and desirable nonnative plant and animal species. 

 Promote recovery and restoration of sagebrush communities after wildfire events. 

Vegetation: Rangelands – Management Common to All Alternatives

Manage rangelands to meet health standards consistent with the Standards for Rangeland Health (Standards 1 and 5) and Guidelines for Livestock Grazing Management and apply 

appropriate guidelines where not meeting the standards.

Identify and maintain areas containing high quality native vegetation for use as seed collection sites.

Identify priority treatment areas for conifer encroachment, including big game winter range, WUIs, current and historic sagebrush habitat, forest meadows and bighorn sheep habitat. 

To manage cheatgrass and annual bromes, use the best available vegetation treatments, including but not limited to early spring grazing, prescribed fire, interim farming practices, and 

herbicide use.

Native seed would be used for all restoration and rehabilitation efforts unless site specific objectives dictate otherwise.

Vegetation: Rangelands – Management Actions by Alternative

No similar action Within Greater Sage-Grouse Priority Habitat 

Areas, only treatments that conserve, 

enhance, or restore Greater Sage-Grouse 

habitat would be allowed. Treatment 

methods, including prescribed burning and 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-107

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

mechanical treatments would be used to 

eliminate conifer encroachment and stimulate 

vegetative re-growth in grassland/shrub land 

habitats; and to reduce fuels, thin understories, recycle nutrients, and create small 

openings in forested vegetation types.

No similar action In Priority Habitat Management Areas, the 

desired condition is to maintain a minimum of 

70% of lands capable of producing 

sagebrush with 10 to 30% sagebrush canopy 

cover. The attributes necessary to sustain 

these habitats are described in Interpreting 

Indicators of Rangeland Health (BLM Tech 

Ref 1734-6).*

Prescribed fire/treatment on 6,418 acres of 

sagebrush for forage enhancement.

Prescribed fire would not be allowed in 

sagebrush communities. Wildfires would be 

suppressed in sagebrush communities.

A variety of treatment methods, including 

mechanical, chemical, biological and

prescribed fire (including wildfire), would 

be used if the treatment would achieve a 

diversity of habitat components within 

sagebrush communities.

Same as C.

Crested wheatgrass (160 acres) would be 

hayed or mechanically treated to increase 

forage production, improve range conditions, 

and reduce erosion.

A target of fifteen percent of crested 

wheatgrass acres (approximately 4,459 acres) 

would be converted to native sagebrush/ 

grassland over the life of the plan.

Preferred treatment areas would be areas that 

are not currently being used in a grazing 

system to provide early spring grazing and 

reduce grazing pressure from other areas 

within a grazing allotment. 

Priority treatment areas would be in Greater 

Sage-Grouse PHMAs, RAs and GHMAs.

A target of five percent of crested 

wheatgrass acres (approximately 1,486 

acres) in high density Greater SageGrouse population areas would be 

converted to native sagebrush/grassland 

over the life of the plan.

Preferred treatment areas would be areas 

that are not currently being used in a 

grazing system to provide early spring 

grazing and reduce grazing pressure from 

other areas within a grazing allotment.

Priority treatment areas would be in 

Greater Sage-Grouse PHMAs, RAs, and 

GHMAs.

A target of eight percent of crested 

wheatgrass acres (approximately 2,378 

acres) would be converted to native 

sagebrush/grassland over the life of the plan.

Preferred treatment areas would be areas 

that are not currently being used in a grazing 

system to provide early spring grazing and 

reduce grazing pressure from other areas 

within a grazing allotment.

Priority treatment areas would be in Greater 

Sage-Grouse PHMAs, RAs, and GHMAs.

* Footnote: 70% of the lands capable of producing that level will be
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Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Vegetation: Riparian and Wetlands 

The BLM goals for the management of riparian areas within the Billings Field Office decision area center on promoting healthy wetland ecosystems, supporting physical processes and natural 

combinations of vegetation that work together to create stable stream banks, functional floodplains, complex fish and wildlife habitat and high water quality within site potential. Management actions 

ensure consistency with achieving or maintaining the Standards for Rangeland Health and Guidelines for Livestock Grazing Management for Montana, North Dakota, and South Dakota (BLM 

1997a) and as a minimum, all riparian areas and wetlands are in Proper Functioning Condition (PFC) or where PFC is not obtainable to be at their capability. The PFC is a method for assessing the 

condition of riparian wetland areas through a consistent approach, considering hydrology, vegetation, and erosion/deposition attributes and processes. The term PFC refers to how well the physical 

processes of the riparian area are functioning. In addition, Desired Future Conditions (DFCs) would be developed in some alternatives to help enhance riparian conditions beyond PFC. The DFCs 

can include, but are not limited to, riparian characteristics such as native species diversity and abundance, important in enhancing fish and wildlife habitat as well as riparian functionality.

Vegetation: Riparian and Wetlands – Desired Outcomes (Goals and Objectives)

 Riparian and wetland areas would be managed to promote healthy wetland ecosystems, supporting physical processes and natural combinations of vegetation that work together to create 

stable stream banks, functional floodplains, complex fish and wildlife habitat and high water quality within site potential.

 Riparian vegetation would be managed to achieve or sustain desired future conditions (DFCs). The DFCs would be developed by an interdisciplinary team, giving consideration to restoring 

and/or promoting natural communities and complex riparian conditions valuable to water quality and wildlife habitat.

 Invasive species management would focus on restoring native and desired non-native communities to riparian areas to attain DFCs.

Vegetation: Riparian and Wetlands – Management Common to All Alternatives

Forest treatments would comply with the Montana Streamside Management Zone law to protect riparian resources. 

Manage riparian communities to meet Standards for Rangeland Health (Standard 2) to ensure riparian areas and wetlands are in Proper Functioning Condition (PFC).

Vegetation: Riparian and Wetlands – Management Actions by Alternative

No current management decision provided. Mitigation of surface-disturbing activities would be applied where needed to minimize impacts of human activities on riparian, water and 

floodplain resources, consistent with the stipulations identified for oil and gas development in this section. Mitigation measures would be 

applied during activity level planning if an on-site evaluation of the project area indicates the presence of these resources. Exceptions may 

be granted by the authorized officer, if an environmental review demonstrates that effects could be mitigated to an acceptable level or 

portions of the area can be occupied without affecting a particular habitat. Exceptions may also be granted where the short-term effects are 

mitigated by the long-term benefits (e.g., prescribed fire, wildlife monitoring, forest health treatments, and habitat restoration).

As defined in the Glossary, surface-disturbing and disruptive activities would not prohibit all activities or authorized uses. For example, 

emergency activities (e.g., fire suppression, search and rescue), rangeland monitoring, routine maintenance associated with an approved 

authorization, dispersed recreational activities (e.g., hunting, hiking), and livestock grazing are not considered surface-disturbing or 

disruptive activities.

No current management decision provided Riparian areas would be monitored on a 

prioritized basis. High priority areas would 

include:

 Riparian areas adjacent to fish bearing 

waters.

 Riparian areas with existing cottonwood 

galleries or potential cottonwood gallery 

Riparian areas would be monitored with a 

scheduled rotation or when needed for 

grazing permit renewals.

Same as B.
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-109

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

habitat

 Riparian areas within Greater SageGrouse Priority Habitat

No current management decision provided Riparian areas would be managed towards 

Desired Future Conditions. Desired Future 

Conditions would be established based on 

individual resources, as identified.

Riparian areas would be managed to meet 

rangeland health standards (properly 

functioning condition).

High priority riparian areas would be 

managed towards Desired Future Conditions. 

Other riparian areas would be managed to 

meet rangeland health standards (properly 

functioning condition), unless other Desired 

Future Conditions are appropriate.

Oil and gas leasing and development would 

only be allowed with an NSO stipulation on 

riparian areas or wetlands. NSO within 100 

year flood plains of major rivers and on 

water bodies and streams.

Surface occupancy and use for oil and gas 

exploration (including geophysical operations) 

would be prohibited within 1⁄4 mile of riparian 

areas and wetlands, water bodies, perennial 

streams, and flood plains of perennial streams. 

Surface occupancy and use for oil and gas 

exploration (including geophysical 

operations) would be prohibited within 

riparian areas and wetlands, water bodies, 

perennial streams, and flood plains of 

perennial streams. 

Surface occupancy and use for oil and gas 

exploration (including geophysical 

operations) would be prohibited within 

riparian areas and wetlands, water bodies, 

perennial and intermittent streams, and 

floodplains of perennial streams. (NSO)

Surface occupancy and use would be 

controlled within 300 feet of riparian and/or 

wetland areas. Surface-disturbing activities 

would require a plan with design features that 

demonstrate how all actions would maintain 

and/or improve the functionality of riparian 

and wetland areas, The plan would address: 

(a) potential impacts to riparian and wetland 

resources, (b) mitigation to reduce impacts to 

acceptable levels (including timing 

restrictions), (c) post project restoration, and 

(d) monitoring (the operator must conduct 

monitoring capable of detecting early signs of 

change in riparian and/or wetland conditions. 

(CSU)

NSO for oil and gas leasing and 

development and geophysical exploration 

within 1⁄4 mile of designated reservoirs with 

fisheries. 

Surface occupancy and use for oil and gas 

exploration (including geophysical operations) 

would be prohibited within 1⁄2 mile of 

designated reservoirs with fisheries. 

Same as A Same as A

No current management decision provided Surface occupancy and use for oil and gas 

exploration (including geophysical operations) 

would be prohibited within 1⁄2 mile of Blue and 

Red Ribbon streams, and YCT populations 

Surface occupancy and use for oil and gas 

exploration (including geophysical 

operations) would be prohibited within 1⁄4 

mile of Blue Ribbon streams, and YCT 

Surface occupancy and use for oil and gas 

exploration (including geophysical 

operations) would be prohibited within 1⁄2 mile 

of Blue Ribbon streams, and YCT 
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2-110 Chapter 2: Resource Management Alternatives

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

and YCT suitable habitat (NSO) (Maps 26-28). populations (NSO) (Maps 26, 27). populations (NSO) (Maps 26, 27).

No current management decision provided Priority riparian habitats would include riparian 

areas associated with perennial streams, fish 

bearing streams, cottonwood galleries, and 

riparian areas within Greater Sage-Grouse 

Priority Habitat Management Areas (PHMAs)

Priority riparian habitats would include 

riparian areas associated with YCT 

populations and suitable recovery habitat. 

Blue and Red Ribbon streams and 

cottonwood galleries.

Priority riparian habitats would include 

riparian areas associated with perennial 

streams and cottonwood galleries. 

Vegetation: Invasive Species and Noxious Weeds

The BLM goals for the management of invasive species and noxious weeds within the Billings Field Office are to manage for healthy native plant communities by reducing, preventing expansion of, 

or eliminating the occurrence of undesirable invasive, nonnative species, or noxious weeds (predatory plant pests or disease) by implementing management actions consistent with national 

guidance, state and local weed management plans and best available science. Integrated Pest Management would be implemented to move toward a healthy plant community, while meeting 

multiple land use objectives. 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 principles of Integrated Pest 

Management (IPM) and creating weed management areas (WMAs). The actions specific to the management of invasive and noxious weeds are listed below, by alternative. These “Action 

Alternatives” would primarily protect people, water, fish, wildlife, special status species and their habitats, prevent the introduction and spread of invasive and noxious weeds. Some actions 

associated with other resources (soils, water, fish and wildlife etc.) benefit the management of invasive and noxious weed program by limiting activities that would reduce soil and vegetation 

disturbance and reduce the spread and introduction of invasive and noxious weeds. 

Vegetation: Invasive Species and Noxious Weeds – Desired Outcomes (Goals and Objectives)

 Manage for healthy native plant communities and desirable nonnative plant communities by reducing, preventing expansion of, or eliminating the occurrence of undesirable invasive species, 

undesirable nonnative, or noxious weeds (predatory plant pests or disease) by implementing management actions consistent with national guidance, state and local weed management plans. 

 Use Integrated Pest Management to make progress towards a healthy plant community, while meeting multiple land use objectives and meeting Standards for Rangeland Health (Standards 1, 

2, and 5).

 Maintain baseline data to evaluate effectiveness of management actions and assess progress toward meeting invasive species management goals/objectives. 

 Create buffer zones to protect and/or restore fish and wildlife habitat and neighboring agricultural fields.

 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 principles of Integrated Pest Management (IPM) and creating weed 

management areas (WMAs).

Vegetation: Invasive Species and Noxious Weeds – Management Common to All Alternatives

Reclamation/stabilization and maintenance materials used would be from weed free seed source.

Invasive species, including aquatic invasives, would be managed in cooperation with other agencies, organizations, and landowners in accordance with EO 13112 (1999).

Biological control would be applied where appropriate and approved by APHIS. The BLM would consider adapting new or updated biological control techniques, as supported by 

research.

Domestic sheep and goats used for weed control would only be authorized where mechanisms are in place to achieve effective separation from wild sheep.

Weed control using domestic sheep and/or goats in potential grizzly bear and wolf habitat would only be authorized after consultation with U.S. Fish Wildlife Services. 
Billings and Pompeys Pillar National Monument 

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Chapter 2: Resource Management Alternatives 2-111

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Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Visitor protection during herbicide treatments at developed recreation areas would include posting signs to prevent public entry. To the extent practical, herbicide treatments would occur 

only during low recreation use.

Require the use of certified weed free seed forage and feeds to prevent establishment of new weed species. Forage subject to this rule would include hay, grains, cubes, pelletized 

feeds, straw and mulch.

Require the use of weed free seed and mulch for BLM-authorized activities and projects.

Noxious/Invasive species treatments would be approved by the appropriate BLM specialist prior to treatment occurring

Stipulations would be attached to all surface disturbing projects for noxious/invasive species prevention, identification, and treatments, as well as monitoring during and after project.

Vegetation: Invasive Species and Noxious Weeds – Management Common to Action Alternatives

No current management decision provided Oil and gas leases would be inventoried for noxious and/or invasive weeds, monitoring would occur throughout the duration of the project 

to prevent the spread and introduction of noxious and/or invasive weeds, and project activities must be designed to minimize soil 

disturbance. (LN)

No current management decision provided Oil and gas leases would be subject to constraints should noxious and/or invasive weeds be identified within the boundaries of the lease 

parcel (CSU).

No current management decision provided When possible, hand spray herbicides in areas of special status species (plants and animals)

No current management decision provided Noxious and invasive weed control would not occur within 1⁄2 mile of nesting and brood rearing areas for special status species during the 

nesting and brood rearing season

No current management decision provided Treatment priorities would be established consistent with State of Montana Noxious Weed guidance. 

High Treatment Priority: eradication of new species; new infestations, areas of special concerns, riparian corridors or special status plant 

populations where there is a high threat to species of concern (such as Russian olive and salt cedar treatments); areas where

partnership/cooperative agreements are in place; treatment and prevention in special designations and weed management areas.

Moderate/Low Treatment Priority: areas that contain existing large infestations with a focus on boundaries of infestations, travel routes, 

trails, trailheads, and access points leading to areas of concern, control existing large infestations and suppression of existing large 

infestations when eradication/control or containment is likely not to be successful. 

Vegetation: Invasive Species and Noxious Weeds – Management Actions by Alternative

No current management decision provided Remove invasive species from cottonwood 

galleries and take actions to maintain the 

appropriate stand composition, structure and 

understory diversity to promote the expansion 

of galleries.

Natural processes would be allowed to 

determine structure and composition of 

cottonwood galleries (no proactive 

management).

Same as B

Aerial application of non-aquatic label 

herbicides would not be allowed within 100 

feet of wetlands, riparian areas, and aquatic 

Aerial application of non-aquatic label 

herbicides would not be allowed within 1⁄4 mile 

of wetlands, riparian areas, and aquatic 

Specific buffer strip widths indicated on 

pesticide labels or by state regulations 

would be followed. This also applies to 

Aerial application of non-aquatic label 

herbicides would not be allowed within 500 

feet of wetlands, riparian areas, and aquatic 
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Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

habitats. 

Specific buffer strip widths indicated on 

pesticide labels or by state regulations must 

be followed. This also applies to cropland 

and ornamentals

Exceptions would be applied when 

managing riparian noxious/invasive species 

and following aquatic approved herbicide 

labels.

habitats. 

Specific buffer strip widths indicated on 

pesticide labels or by state regulations must be 

followed. This also applies to cropland and 

ornamentals

Exceptions would be applied when managing 

riparian noxious/invasive species and following 

aquatic approved herbicide labels.

cropland and ornamentals.

Exceptions would be applied when 

managing riparian noxious/invasive 

species and following aquatic approved 

herbicide labels.

habitats. 

Specific buffer strip widths indicated on 

pesticide labels or by state regulations must 

be followed. This also applies to cropland 

and ornamentals

Exceptions would be applied when managing 

riparian noxious/invasive species and 

following aquatic approved herbicide labels.

Minimize treatments near fish-bearing and 

salmonid-bearing water bodies during 

periods when fish are in life stages most 

sensitive to the herbicide(s) used. Use only 

spot treatment methods. 

Land base application methods would not be 

allowed within 1⁄4 mile of fish-bearing water 

bodies during periods when fish are in life 

stages most sensitive to the herbicide(s) used. 

Minimize treatments near fish-bearing and 

salmonid-bearing water bodies during 

periods when fish are in life stages most 

sensitive to the herbicide(s) used. Use 

only spot treatment methods.

Exceptions would be applied when 

managing riparian noxious/invasive 

species and following aquatic approved 

herbicide labels.

Land base application methods would not be 

allowed within 25 feet (by vehicle) or 10 feet 

(by hand) of fish-bearing water bodies during 

periods when fish are in life stages most 

sensitive to the herbicide(s) used.

Exceptions would be applied when managing 

riparian noxious/invasive species and 

following aquatic approved herbicide labels.

Vehicle and hand application of herbicides 

would not be allowed within 25 feet (by 

vehicle) or 10 feet (by hand) of wetlands, 

riparian areas, aquatic habitats, dwellings 

and cropland.

Exceptions would be applied when 

managing riparian noxious/invasive species 

and following aquatic approved herbicide 

labels.

Vehicle and hand application of herbicides 

would not be allowed within 50 feet of 

wetlands, riparian areas, aquatic habitats, 

dwellings and cropland.

Exceptions would be applied when managing 

riparian noxious/invasive species and following 

aquatic approved herbicide labels.

Same as A Same as A

Mix herbicides with non-aquatic label at a 

minimum of 500 feet away from riparian 

areas, water sources, floodplains, and 

known special status plant species 

populations. 

Mix herbicides with non-aquatic label at a 

minimum of 1⁄4 mile away from riparian areas, 

water sources, floodplains and known special 

status plant species populations.

Same as A Same as A
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Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Vehicle and hand application of herbicides 

near special 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 would not be 

allowed within 1mile of special status plant 

species.

Vehicle and hand application of herbicides 

would not be allowed within 1⁄4 mile of special 

status plant species.

Aerial application of herbicides would not 

be allowed within 1⁄2 mile of special status 

plant species.

Vehicle and hand application of herbicides 

near special status plant species would be 

allowed only when the treatment would 

benefit special status plant species (to be 

determined during site-specific analysis).

Same as C

Use native seed mixtures unless modified 

through NEPA.

Only native species appropriate to the site 

would be used to restore vegetation on 

disturbed ground.

Native or low impact, non-invasive seed 

mixtures would be used to restore 

vegetation on disturbed ground.

Native plant species common to the site’s 

natural plant community would be used to 

restore disturbed ground. 

Desirable non-native species would be 

considered based on site-specific analysis 

where difficult site stabilization or wildlife 

concerns prevail. 

In the past 10 years a combination of 

treatment methods (herbicide, manual, 

mechanical, sheep/goats, biological and fire) 

were used to treat 366 acres to 5,548 acres 

per year.

A target range of a minimum of 200 acres and 

at least a maximum of 800 acres of invasive 

and noxious weeds would be treated annually 

by BLM and cooperators through a variation of 

methods (herbicide, manual, mechanical, 

sheep/goats, biological and fire).

A target range of a minimum of 1,500 

acres and at least a maximum of 3,000 

acres of invasive and noxious weeds 

would be treated annually by BLM and 

cooperators through a variation of 

methods (herbicide, manual, mechanical, 

sheep/goats, biological and fire).

A target range of a minimum of 400 acres 

and at least a maximum of 2,000 acres of 

invasive and noxious weeds would be treated 

annually by BLM and cooperators through a 

variation of methods (herbicide, manual, 

mechanical, sheep/goats, biological and fire).

Vegetation: Special Status Plants

The Bureau of Land Management goals for the management of Special Status Plants within the Billings Field Office are to conserve and recover Special Status Plant species and the ecosystems 

that they depend to prevent the need for listing as threatened or endangered. This includes protecting or enhancing areas of ecological importance for Special Status Plant species and managing 

for no net loss of habitat. The following Management Actions describe, by alternative, implementation strategies, restoration opportunities, and use restrictions to meet the goals. Management for 

specific environmental hazards, risks, and impacts that are compatible with Special Status Plant species are also identified by alternative.

Vegetation: Special Status Plants – Desired Outcomes (Goals and Objectives)

 Conserve and recover special status plant species and the ecosystems on which they depend to prevent the need to list any of these species as threatened or endangered.

 Protect or enhance areas of ecological importance for special status plant species. Manage for no net loss of habitat for any special status plant species.

 Conserve and recover special status plant species by determining and implementing strategies, restoration opportunities, use restrictions, and management actions.

 Manage specific environmental hazards, risks, and impacts in a manner compatible with special status plant species health.

Vegetation: Special Status Plants – Management Common to All Alternatives

BLM-authorized activities should maintain or improve habitat for Federally listed threatened, endangered, and special status plants.

Conduct inventory and monitoring to determine extent and trend of special status plant populations.
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Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Habitats of special status plants would be managed to meet or exceed the Montana Standard for Rangeland Health (Standard 5). 

Increase public awareness of special status plants through outreach, tours, and brochures.

Consider the high public value of special status plants and their habitat in land exchanges, purchases or disposals in which public ownership of such habitat would be affected.

Vegetation: Special Status Plants – Management Actions by Alternative

On-site examination is required prior to 

surface disturbing activities. Evaluate all 

BLM actions for potential effects on special 

status plants and conduct on-site inventory 

for species of concern prior to treatment.

Evaluate all BLM-authorized activities for 

potential effects on special status plants.

Conduct on-site inventory for special status

plants prior to any surface disturbance. 

Evaluate all BLM-authorized activities on 

known special status plant sites for 

potential effects on special status plants.

Same as B, except only conduct on-site 

inventory if potential special status plant 

habitat is known to be present.

No current management decision provided No surface occupancy for oil and gas leasing, 

exploration and/or development within 1⁄4 mile 

of special status plant species or populations

(NSO). 

On-site examination would be required 

prior to oil and gas leasing, exploration 

and/or development surface disturbing 

activities (CSU).

Same as C

Mineral Materials - No current management 

decision provided

No permitting of mineral materials would be 

authorized in special status plants sites.

Mineral material sales would be allowed 

through permit only with appropriate 

mitigation. 

Mineral material sales would be allowed on a 

case-by-case basis by permit only. Mitigation 

may be required as appropriate. 

No current management decision provided No supplement or salt placement within 1⁄2 mile 

of known special status plant sites.

No supplement or salt placement within 1⁄4 

mile of known special status plant sites.

No supplement or salt placement within 1⁄4 

mile of known special status plant sites, 

unless livestock is otherwise excluded (fence 

or barrier).

Additional management actions, by alternative, related to Special Status Plants can be found under Special Designations - Areas of Critical Environmental Concern (ACECs) section 

under the East Pryor ACEC, Grove Creek ACEC, Meeteetse Spires ACEC, and Pryor Foothills Research Natural Area (RNA) ACEC.
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Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Wildlife Habitat and Special Status Species (Wildlife)

The BLM, Billings Field Office’s goals for wildlife are to manage terrestrial habitat to provide native and desirable non-native species diversity and viability, while considering multiple uses of public 

lands. The necessary habitat would be present to maintain, enhance, or restore T & E, priority, and special status species populations and habitat with “no net loss of habitat” as the goal. BLM 

would manage environmental risks and associated impacts in a manner compatible with sustaining plant, fish, wildlife, and special status species populations through restoration and building 

resilience to disturbance. Environmental risks include, but are not limited to, parasites, diseases, insect outbreaks, catastrophic fires, contamination, pesticides, rodenticides, herbicides, climate, and 

other hazards.

Sagebrush, native grasslands, seasonal or crucial wildlife ranges, special status species habitat, fisheries, cottonwood galleries, and riparian/wetlands would be priority habitats. All wildlife habitats 

would be managed to meet Rangeland Health Standards (Standards 1 and 5). BLM is responsible for managing habitats, whereas state and federal wildlife management agencies (e.g., MT FWP, 

USFWS) oversee management of wildlife species. BLM would coordinate with and support the conservation plans of those agencies on BLM administered lands. Priority wildlife species for 

management are described in Chapter 3.

Those actions listed under the “Management Common to All Alternatives” form the basis for the wildlife management program. The “Management Actions by Alternative” consider different levels of 

restrictions that may impact other resource uses. The management activities proposed by BLM to accomplish the wildlife goals are described in the management actions by alternative. For analysis 

purposes, the alternatives describe how wildlife habitat would be managed when affected by resource uses of public lands. 

Special status species include federally listed, proposed, or candidate species; state protected species; and BLM sensitive species. The BLM must follow the requirements of the Endangered 

Species Act of 1973, as amended, and BLM policy to conserve federally listed threatened and endangered species and the habitat on which they depend. BLM policy also states, “...ensure that 

actions requiring authorization or approval by the Bureau of Land Management (BLM or Bureau) are consistent with the conservation needs of special status species and do not contribute to the 

need to list any special status species, either under provisions of the ESA or other provisions of this policy.” The Billings Field Office would manage special status species following the direction and 

guidance identified in BLM Manual 6840; recovery plans; biological opinions; conservation agreements, plans, and strategies; habitat conservation plans; and the recommendations from 

interagency recovery implementation teams. Special status and T & E species designations and lists are dynamic and subject to change based on population changes, habitat improvements and 

protections, and new data.

Please refer to the Appendices for definitions, descriptions of laws, regulations, policies, and guidance, Best Management Practices (BMPs), Oil and Gas leasing notices, stipulations, and CSU 

guidelines, Wildlife Monitoring and Protection Plan, and T&E and Special Status Species lists. The appendices are intended to clarify the content of the RMP.

The “Wildlife Monitoring and Protection Plan” (WMPP) (Appendix H), was prepared to acquire baseline wildlife information, monitor populations, and assess stipulations for effectiveness. Wildlife 

stipulations attached to leases offer protective measures: 1) for certain species, 2) during a particular time period, or 3) within a specific area. These stipulations may not address other concerns 

related to special status species or water/habitat related issues caused by direct and indirect impacts from development activities. 

Inventory and monitoring data would be used in adaptive management for improving wildlife management techniques and processes. Therefore, the WMPP would facilitate our ability to pinpoint 

problems (including the evaluation of other contributing factors), design project plans which include conservation for declining species, monitor the effectiveness of decisions, and make 

recommendations to adjust management to address specific situations. 

In 2010, the U.S. Fish and Wildlife Service determined that the Greater Sage-Grouse is a Candidate species and Warranted, but precluded, by other priorities, for listing under the Endangered 

Species Act. In 2009, the MT/DAKs BLM delineated three types of Greater Sage-Grouse habitat areas as part of the planning process (Map 23):

 Greater Sage-Grouse Habitat - Priority Habitat Management Areas (PHMAs), 

 Greater Sage-Grouse Habitat - Restoration areas (RAs), and 

 Greater Sage-Grouse Habitat – General Habitat Management Areas (GHMA)

Each area would have varying degrees of management in order to achieve the goals or objectives for each Greater Sage-Grouse habitat area. The Greater Sage-Grouse habitat delineations may 

be modified as needed as local site conditions change or as new information becomes available. Refer to the Glossary for definitions of the three Greater Sage-Grouse habitat areas, Appendix AA 

(section F) for mitigation measures and conservation actions for Greater Sage-Grouse habitat, and Appendix AA (section A) for monitoring of Greater Sage-Grouse and Sagebrush Habitats.
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Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Wildlife Habitat) – Desired Outcomes (Goals and Objectives)

 Manage terrestrial habitat to provide native species diversity and viability, and to sustain ecological, economic, and social values while providing for multiple uses of public lands.

 Manage for no net loss and connectivity of priority habitats on BLM-administered lands. The necessary habitat would be present to maintain, enhance, or restore T & E, special status, and

priority native species populations. Sagebrush, native grasslands, seasonal or crucial wildlife ranges, special status species habitat, fisheries, cottonwood galleries, and riparian/wetlands 

would be priorities.

 Manage all BLM actions or authorized activities to sustain wildlife populations and their habitats and to avoid contributing to the listing of or jeopardizing the continued existence or recovery of 

special status species and their habitats.

 Manage or restore habitat on BLM-administered lands within the planning area to facilitate the conservation, recovery, and maintenance of populations of native, desirable non-native, and 

special status species consistent with appropriate local, state, and federal management plans.

 Manage habitats to support MT FWP in the attainment of objectives and well-distributed, healthy populations of wildlife species consistent with the MT FWP’s Strategic Habitat Plan, Montana’s 

Comprehensive Fish and Wildlife Conservation Strategy, and strategic population plans, and to achieve the stated purpose of designated State of Montana Wildlife Management Areas.

 Minimize fragmentation of large intact blocks of wildlife habitat to maintain connectivity, population migrations and functional blocks of security habitat for big game species.

 Manage environmental risks and associated impacts in a manner compatible with sustaining plant, fish, wildlife, and special status species populations. Environmental risks include, but are not 

limited to, parasites, diseases, insect outbreaks, catastrophic fires, contamination, pesticides, rodenticides, herbicides, climate, and other hazards.

 Provide for the long-term conservation, enhancement, and restoration of the sagebrush steppe/mixed-grass prairie complex in a manner that supports sustainable Greater Sage-Grouse

populations and a healthy diversity and abundance of wildlife species.

 Coordinate with other agencies to prevent or control diseases, pests and species that threaten the health of humans, wildlife, livestock, and vegetation.

Wildlife Habitat – Management Common to All Alternatives

Implement conservation actions identified in Executive Order 13186 – “Responsibilities of Federal Agencies To Protect Migratory Birds.”

Implement the North American Bird Conservation initiative to restore, enhance, and maintain habitats for migratory birds. Include USFWS Birds of Conservation Concern for Bird 

Conservation Regions 10 and/or 17 where appropriate through project level NEPA analysis. Emphasize maintenance and restoration of habitats that sustain special status species with 

minimum disturbance during the breeding season. Enhance or restore habitat composition and structure beyond PFC in riparian habitats, where and when appropriate, for migratory bird 

habitat.

Retaining important blocks of hiding, security, and thermal cover for big game would be considered during project planning. The BLM would emphasize habitat improvements in areas 

where there is limited or fragmented security habitat through vegetation treatments and route limitations (including seasonal closures).

Assist in the restoration, reintroduction, augmentation, or re-establishment of T & E, special status, and priority species and other populations and (or) habitats in coordination with other 

agencies.

Fences identified as barriers to wildlife movement on BLM-administered lands would be modified or removed to accommodate wildlife passage, unless the fences were built specifically 

to keep native ungulates out of an area. Fences would also be placed and marked, or modified, to reduce wildlife collisions or entanglements.

Conditions of Approval (COAs) would be applied to all Applications for Permit to Drill (APDs) for Special Status Species.

Utilize appropriate offsite compensatory mitigation to reduce impacts to wildlife habitat. This would be necessary if (1) all onsite mitigation has been accomplished and adverse effects 

have not been mitigated; or (2) if onsite mitigation is not feasible. Off –site mitigation would be applied as close to the affected area as possible and for the same or similar impacted 

species or habitats.

Manage siting of facilities to minimize impacts on wildlife habitat function and quality, to minimize impacts on vegetation resources for all uses, and to minimize wildlife mortality during 
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Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

the life of the facility.

Where wildlife conflicts exist, overhead powerlines and tall structures would follow the recommendations in the APLIC guidelines. When possible, perch, collision, and electrocution 

preventions would be used.

Functional wildlife escape ramps would be installed on all water tanks on BLM-administered public lands with preference given to built-in bird ramps in new troughs/ tanks. 

Management techniques, including but not limited to prescribed and managed wildfire, prescriptive livestock grazing, planting, exclusion to intense disturbance, timber harvest and other 

mechanical methods would be used to restore, maintain or improve the desired ecological conditions of vegetation communities for the purpose of improving forage, nesting, breeding, 

and security habitat, hiding cover and travel corridors for a wide diversity of terrestrial and aquatic species.

Management actions would emphasize providing habitat of sufficient quantity and quality, including connectivity and wildlife movement corridors, habitat complexity, forest openings, 

edges, and ecotones, to enhance biological diversity and provide quality, sustainable habitat for native wildlife species.

Caves and abandoned mines would be inventoried for bat habitation. The BLM would determine the need for closures or seasonal closures for activities affecting caves and abandoned 

mines. Hibernacula and maternity cave closure dates would be determined when the inventory is completed. 

Bat gates or other suitable measures would be used to protect bat habitat. Public health and safety could take precedence over protection of bat habitat if hazardous mine openings 

cannot be remediated.

Clearing of vegetation, would not be allowed within 250 feet of the entrance of caves and abandoned mines with populations of bats except for public safety and vegetation would only be 

removed for installing bat gates, noxious weed control, or when it becomes an obstruction to bat movement.

Areas that would be targeted for conversion from crested wheatgrass to native sagebrush/grasslands would be areas that have high wildlife habitat potential, particularly for Greater 

Sage-Grouse, big game, and other sagebrush obligate species, and are currently monocultures with little vegetation diversity. 

Predator control would be permitted subject to the stipulations outlined in the annual Animal Damage Control (ADC) Memorandum of Understanding between BLM and USDA-Animal 

Plant Health Inspection Service. Predator control in non-USDA ADC areas would be subject to the same stipulations as applied to those counties where predators are managed by 

USDA-APHIS.

The BLM could seasonally limit/close rock climbing activities in areas with active raptor nests and would educate the public about the importance of avoiding such locations.

Unoccupied raptor nests would be protected from removal or destruction for 7 years.

Surface disturbing and disruptive activities that impact special status species, particularly during critical life cycles, would be avoided or minimized.

Water developments, where deemed effective, would be managed to reduce the spread of West Nile virus

When wildlife or their habitat could be affected, the BLM would require, as appropriate, a current year wildlife survey of the project area from the project proponent.

Oil and gas timing stipulations would not apply to operation and maintenance of production facilities. If environmental analysis determines that the operations and maintenance of oil and 

gas production facilities results in surface disturbing and disruptive activities or impacts, mitigation of these types of oil and gas activities would be applied where needed through 

Conditions of Approval (COAs) to minimize impact of human activities on important seasonal wildlife habitat.

Designated Crucial Winter Ranges would be used in lieu of CAPS data when the data is available. Any references to CAPS data would be updated when Crucial Winter Ranges are 

designated.
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Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Wildlife Habitat – Management Common to Action Alternatives

No current management decision provided. Mitigation of surface-disturbing or disrupting activities (including operations and maintenance associated with fluid mineral development) 

would be applied where needed to minimize impacts of human activities on important seasonal wildlife habitats, consistent with the wildlife 

stipulations outlined in the Wildlife / Special Status Species and Fluid Minerals sections of Chapter 2. Mitigation measures would be 

applied during activity level planning if an on-site evaluation of the project area indicates the presence of important wildlife species. 

Exceptions may be granted by the authorized officer, if an environmental review demonstrates that effects could be mitigated to an 

acceptable level, habitat for the species is not present in the area, or portions of the area can be occupied without affecting a particular 

species. Exceptions may also be granted where the short-term effects are mitigated by the long-term benefits (e.g., prescribed fire, wildlife 

monitoring, or forest health treatments).

As defined in the Glossary, surface-disturbing and disruptive activities would not prohibit all activities or authorized uses. For example, 

emergency activities (e.g., fire suppression, search and rescue), rangeland monitoring, routine maintenance associated with an approved 

authorization, dispersed recreational activities (e.g., hunting, hiking), and livestock grazing are not considered surface-disturbing or 

disruptive activities.

No current management decision provided Where environmental analysis and monitoring demonstrate a continued need for mitigation or insufficient mitigation measures are present 

for impacts to wildlife, restrictions could be applied to the operation and maintenance of production facilities or other projects. 

Comply with Rangeland Health Standard 5 Monitor areas with wildlife habitat conflicts on an annual basis. Identify all/any activities leading to causal factors for not achieving Standard 

5. Where Standard 5 is not being met, guidelines would be applied within 1 year to make progress toward meeting the standard.

No current management decision provided 

for Colonial Nesting Waterbird Colonies

Surface occupancy and use is prohibited within 1⁄4 mile of Colonial nesting waterbird colonies. (NSO)

Surface use is prohibited within 1⁄2 mile of Colonial nesting waterbird colonies from April 1 through July 15. (TL)

Colonial nesting waterbirds include the following: Clark’s Grebe, American White Pelican, Great Blue Heron, Black-crowned Night Heron, White-faced Ibis, 

Franklin’s Gull, Caspian Tern, Forster’s Tern, Common Tern, Black Tern, and Double-crested Cormorant.

No current management decision provided 

for Sprague’s pipit

Surface-disturbing and disruptive activities would be avoided from April 15 through July 15 in Sprague’s pipit habitat. (TL)

Surface use for oil and gas exploration, (including geophysical exploration) is prohibited from April 15 through July 15 in Sprague’s pipit 

habitat. (TL)

No current management decision provided 

for Migratory Birds

The oil and gas operator is responsible for compliance with provisions of the Migratory Bird Treaty Act (LN)

Wildlife Habitat – Management Actions by Alternative

Where resource conflicts exist, Low voltage 

powerlines would be buried if feasible.

Where resource conflicts exist, BLM would not 

authorize above-ground powerlines (<69kV), 

unless burying the powerline is not feasible.

Where resource conflicts exist, powerlines 

(<69kV) would be authorized in a manner 

that ensures habitat is maintained (e.g. 

burying or line location).

Where resource conflicts exist, BLM would 

not authorize above-ground powerlines 

(<69kV), unless burying the powerline is 

unfeasible. If burying powerlines is 

unfeasible, then powerlines would be 

authorized in a manner that ensures habitat 

is maintained (e.g. line location).
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Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources 

Alternative A Alternative D Record# Alternative B Alternative C (No Action Alternative) (Proposed Alternative) 

No similar action Where federal mineral estate exists, designate Oil and gas leasing, development and Oil and gas leasing, development and 

all State Wildlife Management Areas, Fishing exploration would be allowed, if habitat exploration would be allowed with NSO in 

Access Sites, and State Parks as No Lease suitability within designated State Wildlife designated State Wildlife Management 

areas (NL). Management Areas, Fishing Access Sites, Areas, Fishing Access Sites, and State Parks 

and State Parks is maintained (CSU). (NSO). 

Elk Calving 

Oil and gas exploration and development Surface use for oil and gas exploration Surface occupancy and use for oil and Prior to surface occupancy and use a plan 

and geophysical exploration would be (including geophysical exploration) would be gas exploration leasing and development would be prepared by the proponent as a 

prohibited from April 1 to June 15 (TL) within prohibited from April 1 to July 1 within and (including geophysical exploration) component of the APD, Sundry Notice, etc., 

established spring calving range for elk. established big game parturition habitat (TL). within big game parturition habitat would and approved by the authorized officer in 

be allowed with CSU stipulations. coordination with MTFWP. The operator 

would not initiate surface disturbing activities 

unless the authorized officer has approved 

the plan, The plan must demonstrate to the 

authorized officer’s satisfaction that the 

function and suitability of the habitat would 

not be impaired.(CSU) _________________________________________________________________________________________________________________________________________________________________

Crucial Winter Range (antelope, elk, moose, bighorn sheep, mule deer, whitetail deer, and greater sage-grouse)

No similar action Surface occupancy and use is prohibited (NSO). 

Big Game Winter Range (antelope, elk, moose, bighorn sheep, mule deer, and whitetail deer)

Surface use is prohibited to avoid Surface occupancy and use for oil and gas Surface use is prohibited to avoid Prior to surface occupancy and use a plan 

disturbance of white-tailed deer, mule deer, exploration (including geophysical exploration) disturbance of white-tailed deer, mule would be prepared by the proponent as a 

elk, pronghorn antelope, moose, and and geothermal operations is prohibited to deer, elk, pronghorn antelope, moose, component of the APD, Sundry Notice, etc. 

bighorn sheep during the winter use season, avoid disturbance of white-tailed deer, mule and bighorn sheep during the winter use and approved by the Authorized Officer in 

December 1 - March 31 (TL). deer, elk, pronghorn antelope, moose, and season, December 1 - March 31 (TL). coordination with the state wildlife 

bighorn sheep during the winter use season, management agency. The operator would 

December 1 - March 31, big game winter not initiate surface-disturbing activities unless 

range habitat (Maps 15-20). the Authorized Officer has approved the plan. 

The following special operating constraints The plan must demonstrate to the Authorized 

apply in big game winter habitat (Maps 15-20): Officer’s satisfaction the function and 

suitability of the habitat would not be  Surface occupancy and surface impaired. (CSU) disturbance density and / or mitigation

plan (CSU).

No similar action. No new permanent roads would be allowed in There would be no net increase in There would be no net increase in permanent 

areas where open road densities are 1⁄2 mile/ permanent roads built in areas where roads built in areas where open road 

square mile (mi/mi2) or less in big game winter open road densities are 1 1⁄2 mi/mi2 or densities are 1 mi/mi2 or ,less in big game 

range habitat (Maps 15-20), and parturition less in big game winter and parturition winter range habitat (Maps 15-20) and 
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Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

ranges unless not possible due to conflicts with 

valid existing rights. All practicable measures 

would be taken to assure that important 

habitats with low road densities remain in that 

condition.

BLM would manage to reduce open road 

densities in big game winter range (Maps 15-

20) and calving ranges where they exceed 1⁄2 

mi/mi2. 

Roads would be gated during crucial seasons, 

closed and/ or reclaimed. 

ranges unless not possible due to conflicts 

with valid existing rights. All practicable 

measures would be taken to assure that 

important habitats with low road densities 

remain in that condition.

BLM would manage to reduce open road 

densities in big game winter and calving

ranges where they exceed 1 1⁄2 mi/mi2. 

Roads would be gated during crucial 

seasons, closed and/ or reclaimed. 

parturition ranges, unless not possible due to 

conflicts with valid existing rights. All 

practicable measures would be taken to 

assure that important habitats with low road 

densities remain in that condition.

BLM would manage to reduce open road 

densities in big game winter range (Maps 15-

20) and calving ranges where they exceed 1 

mi/mi2. 

Roads would be gated during crucial 

seasons, closed and/ or reclaimed. 

No current management decision provided Over the snow vehicles would be prohibited in 

big game winter range.

Over the snow vehicles would be allowed 

in big game winter range.

Same as B

Bighorn Sheep Range and Bighorn Sheep Lambing Areas

Oil and gas leasing and development would 

be allowed with an NSO stipulation within the 

designated bighorn sheep range (Map 17). 

Surface occupancy and use for oil and gas 

exploration (including geophysical 

exploration) and development would be 

prohibited within designated bighorn sheep 

range (NSO). 

Oil and gas exploration and development 

and geophysical exploration would require 

a mitigation plan to maintain habitat and 

avoid habitat loss (CSU). 

Surface occupancy and use is prohibited 

within bighorn sheep lambing areas. (NSO). 

Prior to surface occupancy and use a plan 

would be prepared by the proponent as a 

component of the APD, sundry notice, etc., 

and approved by the authorized officer in 

coordination with the state wildlife 

management agency. The operator would 

not initiate surface-disturbing activities unless 

the authorized officer has approved the plan. 

The plan must demonstrate to the authorized 

officer’s satisfaction that the function and 

suitability of the habitat would not be 

impaired. (CSU)

Sheep or goats would not be permitted within

9 miles from known bighorn sheep habitat

(Map 17). This distance would be greater if 

deemed necessary through site specific 

analysis.

Conversions from cattle to domestic sheep or 

goats would be prohibited in allotments within

occupied wild sheep habitat (Map 17).

New sheep and goat allotments or 

conversions from cattle to sheep or goats 

would not be permitted within 14.3 miles from 

known bighorn sheep habitat. This distance 

would be greater if deemed necessary 

through site specific analysis.

Conversions from cattle to domestic 

sheep or goats would be prohibited in 

allotments within occupied wild sheep 

habitat (Map 17).

New sheep and goat allotments or 

conversions from cattle to sheep or goats 

would not be permitted within 12.4 miles 

from known bighorn sheep habitat. This 

distance would be greater if deemed 

Domestic sheep/goat permits – No new 

grazing permits authorizing sheep or goats 

would be allowed within 14.3 air miles or 23 

Kilometers in bighorn sheep range (Map 17) 

or as determined through consultation with 

MTFWP. 

Sheep and goat grazing allotments in areas 

with risk of contact between bighorn sheep 

and domestic sheep and/or goats in the 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-121

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources 

Record# Alternative A 

(No Action Alternative) Alternative B Alternative C Alternative D (Proposed Alternative) 

necessary through site specific analysis. planning area would be reviewed and 

managed, or reclassified if necessary, to 

achieve effective separation (both temporal 

and/or spatial at 23 kilometers (14.3 miles) 

or as determined through consultation with 

MTFWP. Contact risk would be based on 

habitat, distance between bighorn sheep 

range (current and anticipated), sheep and 

goat allotments, movement potential, and 

current science and guidelines. Domestic 

sheep/goats would not be allowed within 

bighorn sheep range unless mechanisms are 

in place to achieve effective separation from 

wild sheep. 

Raptor Nests (Applies to Special Status Species including ferruginous hawk, burrowing owl, great grey owl, Swainson’s hawk, northern goshawk, and osprey (Bald Eagles and peregrine falcons are 

addressed separately) (note: Special Status Species designations can change)

Oil and gas exploration and development 

surface use would be prohibited from March 

1 to August 1 (TL) within 0.5 mile of raptor 

nest sites which have been active within the 

past 2 years. 

Geophysical exploration would be 

prohibited. 

Surface occupancy and use for oil and gas 

exploration and development activities 

(including geophysical exploration) would be 

prohibited within 1⁄2 mile of raptor nest sites 

which have been active within the past 7 years 

(NSO). 

Oil and gas exploration and development 

and geophysical exploration activities 

would be prohibited within 1⁄4 mile of raptor 

nest sites which have been active within 

the past 7 years (NSO). 

Surface occupancy and use would be 

prohibited within 1⁄4 mile of raptor nest sites 

active within the preceding 7 years. (NSO). 

Surface occupancy and use would be 

prohibited within 1⁄2 mile of active raptor nest 

sites from March 1 through July 31. (TL) 

Sharp-tailed Grouse Leks and Nesting Habitat 

Surface occupancy within 1⁄4 mile of leks is 

prohibited. 

Surface occupancy and use for oil and gas 

exploration and development (including 

geophysical exploration) would be prohibited 

within 2 miles of sharp-tailed grouse leks 

(NSO). 

Oil and gas exploration and development 

and geophysical exploration within 1⁄4 mile 

of sharp-tailed grouse lek sites and 

nesting habitats would be subject to the 

following constraints: (1) noise from oil, 

gas and geothermal production facilities 

would not exceed 49 decibels (10dBa 

above background noise at the lek site); 

and (2) operational constraints would 

include off-site production facilities and 

gated access to minimize disturbance to 

sharp-tailed grouse lek sites and nesting 

habitats (CSU). 

Surface occupancy and use is prohibited on 

and within 1⁄2 mile of the perimeter of leks. 

(NSO) 

__________________________________________________________________________________________________________________________________________________________________
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Proposed Resource Management Plan and Final Environmental Impact Statement 

2-122 Chapter 2: Resource Management Alternatives

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources 

Record# Alternative A 

(No Action Alternative) Alternative B Alternative C Alternative D (Proposed Alternative) 

Oil and gas exploration and development 

(including geophysical exploration) would be 

prohibited from March 1 to June 15 (TL) in 

sharp-tailed grouse nesting habitat within 2 

miles of a lek. 

Surface occupancy and use for oil and gas 

exploration and development (including 

geophysical exploration) would be prohibited 

within 2 miles of sharp-tailed grouse leks 

(NSO). 

Surface use for oil and gas exploration 

and development (including geophysical 

exploration) would be prohibited between 

March 1 to June 15 in sharp-tailed grouse 

nesting habitat within 1⁄2 mile of a lek (TL). 

Surface use is prohibited within 2 miles of the 

perimeter of sharp-tailed grouse and/or 

greater prairie chicken leks from April 1 

through July 15. (TL) 

Special Status Species (Wildlife) – Management Actions Common to All Alternatives 

All federally listed and BLM sensitive species and their habitats would be considered priority species and habitats.

Identify distribution, key habitat areas, and special management needs for development of management plans and conservation measures, consistent with restoration, conservation and 

recovery plans for threatened, endangered, and other special status species. Priority habitats are riparian/ wetland areas, native grasslands, sagebrush steppe, conifer forests, and 

seasonal ranges supporting life cycle requirements for wildlife (i.e., winter, breeding, parturition, etc.). 

Timing restrictions would be used in special status species habitat. Surface disturbing and disruptive activities that impact special status species habitats during their seasons of use, 

particularly during critical life cycles would be avoided or minimized. 

Assist in the restoration, reintroduction, augmentation, or re-establishment of threatened, endangered, and other priority or special status species populations and (or) habitats in 

coordination with MTFWP and USFWS. 

Water developments, and discharge water from energy development, where deemed effective, would be managed with BMPs to reduce the spread of West Nile virus 

The BLM would require, as appropriate, a current year wildlife survey of the project area from the project proponent. 

Oil and gas surface occupancy and use is subject to the following operating constraints: 

The lease area may now or hereafter contain plants, animals, or their habitats determined to be threatened, endangered, or other special status species. BLM may recommend 

modifications to exploration and development proposals to further its conservation and management objective to avoid BLM approved activity that would contribute to a need to list such 

a species or their habitat. BLM may require modifications to or disapprove proposed activity that is likely to result in jeopardy to the continued existence of a proposed or listed 

threatened or endangered species or result in the destruction or adverse modification of a designated or proposed critical habitat. BLM would not approve any ground-disturbing activity 

that may affect any such species or critical habitat until it completes its obligations under applicable requirements of the Endangered Species Act as amended, 16 U.S.C. § 1531 et seq., 

including completion of any required procedure for conference or consultation. (LN) 

Special Status Species (Wildlife) – Management Actions By Alternative 

Potential Black-Footed Ferret Habitat 

Black-footed ferret habitat is defined as prairie dog colonies within 1.5 km of each other and comprising of 1,500 acres. 

Surface occupancy or use is subject to the 

following operating constraints: 

Prior to surface disturbance, a surface use 

plan of operations (SUPO) for oil and gas 

activities must be approved for black-footed 

ferret reintroduction areas by the authorized 

officer in consultation with the U.S. Fish and 

Prior to surface disturbance, prairie dog 

colonies and complexes 80 acres or more in 

size would be examined to determine the 

presence or absence of black-footed ferrets. 

The findings of this examination may result 

in some restrictions to the operator’s plans 

or may even preclude use and occupancy 

Same as B Surface occupancy and use for oil and gas 

leasing, development, and exploration and 

geophysical operations would be prohibited 

within 1⁄4 mile of black-footed ferret habitat 

(NSO). 

__________________________________________________________________________________________________________________________________________________________________

__________________________________________________________________________________________________________________________________________________________________

__________________________________________________________________________________________________________________________________________________________________
Billings and Pompeys Pillar National Monument 

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Chapter 2: Resource Management Alternatives 2-123

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Wildlife Service (USFWS). (CSU) that would be in violation of the ESA. The 

lessee or operator may, at their own option, 

conduct an examination on the leased lands 

in order to determine the presence or 

absence of black-footed ferrets, if the activity 

would have an adverse effect, or if the area 

can be cleared. This examination must be 

done by or under the supervision of a 

qualified resource specialist approved by the 

surface managing agency. An acceptable 

report must be provided to the surface 

management agency documenting the 

presence or absence of black-footed ferrets 

and identifying the anticipated effects of the 

proposed action on the black-footed ferret 

and its habitat. This stipulation does not 

apply to the operation and maintenance of 

production facilities. (CSU)

Black-tailed and White-tailed Prairie Dogs

Management of prairie dog colonies on public lands would be subject to the Conservation Plan for Black-tailed and White-tailed Prairie Dogs in Montana. White-tailed prairie dogs would 

be considered a priority for management due to limited and declining populations in Montana. 

Prior to surface-disturbing activities, prairie 

dog colonies and complexes 80 acres or 

more in size and containing 5 burrows per 

acre would be examined to determine the 

presence or absence of black-footed ferrets 

(CSU)

Oil and gas leasing, development, and 

exploration, and geophysical operations would 

be prohibited within 1⁄2 mile of black-tailed or 

white-tailed prairie dog colonies, active within 

the past 10 years (NSO).

Oil and gas leasing, development and 

exploration, and geophysical operations 

would be allowed with within black-tailed 

or white-tailed prairie dog colonies with a 

mitigation plan (CSU).

Refer to Guidelines for Wildlife CSUs –

Appendix H.

Oil and gas surface occupancy and use is 

prohibited within 1⁄4 mile of prairie dog 

colonies active within the past 10 years.

(NSO). 

Prairie Dog Habitat

Management of prairie dog colonies on 

public lands would be subject to the 

statewide prairie dog conservation plan 

(2002). Prairie dog towns that occur on 

public lands would be managed for wildlife 

and recreational values.

Prairie dog colonies would be managed to 

ensure their populations are maintained at the 

current levels. If populations decline, measures 

would be implemented to develop and 

enhance habitat for colony expansions.**

Prairie dog colonies would be managed 

for maintenance of populations where the 

public has access. 

Control measures would be considered 

with the following criteria**: 

Prairie dog colonies would be managed for 

maintenance of populations where the public 

has access. 

Control measures would be considered with 

the following criteria**:

No similar criteria

**Prairie dog towns would be allowed to expand as long as they are not adversely impacting adjacent private or state land, other 

resources, or affecting Standards for Rangeland Health (Appendix I). Prairie dog towns would be adversely impacting other resources, and 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-124 Chapter 2: Resource Management Alternatives

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

controls could be considered, if the towns are: 

 The source of or an exacerbation of invasive or noxious plants;

 Substantially limiting forage and/or important habitat for wildlife species in the immediate area;

 Substantially limiting forage for livestock in the immediate area;

 Overriding the effectiveness of other management measures; or 

 Posing a substantial economic hardship or risk for other landowners, resulting from the need to control populations on private or state

land because of prairie dogs on adjacent BLM land.

Controls would not occur where mountain plover or burrowing owls have been documented using established habitat. Prairie dogs could be 

reestablished on historic towns that have been eradicated or that have died out due to sylvatic plague. Specific actions to address adverse 

impacts to or from prairie dogs would be addressed through a site-specific environmental assessment.

Mountain Plover

Surface use is prohibited within 1⁄4 mile of 

active mountain plover nest sites. 

Disturbance to prairie dog towns would be 

avoided where possible. Any active prairie 

dog town occupied by mountain plovers 

would have No Surface Use between April 1 

and July 31. (NSO)

Surface occupancy and use for oil and gas 

exploration and development (including 

geophysical exploration) would be prohibited

within 1⁄2 mile of mountain plover habitat 

(NSO). 

Oil and gas leasing and development and 

geophysical exploration would not be 

allowed within 1⁄4 mile of mountain plover 

habitat, subject to the following special 

operating constraints: (1) operational 

constraints could include off-site 

production facilities, audio restrictions, 

and gated access to minimize disturbance 

to key mountain plover habitats (CSU). 

NSO - Oil and gas surface occupancy and 

use is prohibited within mountain plover 

habitat 

TL Surface use is prohibited within 1⁄4 mile of 

mountain plover habitat from April 1 through 

July 15.

Interior Least Tern

Surface occupancy and use is prohibited within 1⁄4 mile of wetlands identified as Interior Least Tern habitat. (NSO)

Peregrine Falcon

Oil and gas leasing and development would 

be allowed with an NSO stipulation within 1 

mile of peregrine falcon nesting sites. 

Geophysical exploration would not be 

allowed. 

Surface occupancy and use for oil and gas 

exploration and development (including 

geophysical exploration) would be prohibited 

within 1 mile of peregrine falcon nesting sites 

(NSO).

Surface occupancy and use for oil and

gas exploration (including geophysical 

exploration) would be prohibited within 1⁄4 

mile of active peregrine falcon nesting 

sites (NSO). 

Surface occupancy and use for oil and gas 

exploration and development (including 

geophysical exploration) would be prohibited 

within 1 mile of peregrine falcon nest sites

active within the preceding 7 years. (NSO).

Bald Eagle and Golden Eagle Nests and Habitat

BGEPA (Bald and Golden Eagle Protection Act): BLM would coordinate with USFWS on activities that may affect bald or golden eagles for compliance with BGEPA. The BLM would not 

issue a notice to proceed for any project that is likely to result in take of bald eagles and/or golden eagles until the applicant completes its obligation under applicable requirements of 

BGEPA, including completion of any required procedure for coordination with the FWS or any required permit. The applicant may be required to conduct further analysis and mitigation 

following assessment of operational impacts.

Bald eagle and golden eagle nesting habitats would be actively protected from loss due to fire, insect, or disease by reducing vegetation competition and encroachment in these habitats, 

unless visual barriers are compromised.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-125

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Bald Eagle Nests

Activities and habitat alterations including surface disturbing or disruptive activities that disturb bald eagles would be restricted within suitable habitats or avoided within 1⁄2 mile of bald 

eagle nest sites active within the preceding 5 breeding seasons. Activities in bald eagle habitat would be conducted according to Montana Bald Eagle Management guidelines (Montana 

Bald Eagle Working Group, 2009, Montana Bald Eagle Management Guidelines: An Addendum to Montana Bald Eagle Management Plan, 1994). 

Oil and gas leasing and development would 

be prohibited within an NSO stipulation 

within 1⁄2 mile of eagle nest sites which have 

been active within the past 7 years and 

within eagle nesting habitat in riparian areas 

(NSO).

Geophysical exploration would not be 

allowed. 

Surface occupancy and use for oil and gas 

exploration (including geophysical operations) 

would be prohibited within 1 mile of eagle nest 

sites which have been active in the past 7 

years and within eagle nesting habitat in 

riparian areas (NSO). 

Surface occupancy and use for oil and 

gas exploration (including geophysical 

operations) would be prohibited within 1⁄4 

mile of active eagle nest sites (NSO). 

Surface occupancy and use for oil and gas 

exploration would be prohibited within 1⁄2 mile 

of eagle nest sites active within the preceding 

5 years unless the activity complies with the 

USFWS National Bald Eagle Management 

Guidelines (2007). (NSO)

Greater Sage-Grouse 

Refer to crested wheatgrass conversion alternative in the Vegetation- Rangelands section of this table. Acreages and priorities for conversion or treatments are discussed. Greater SageGrouse habitat is a priority for crested wheatgrass conversions or treatments.

No current management decision In all sage-grouse habitat, in undertaking 

BLM management actions, and consistent 

with valid existing rights and applicable law, 

in authorizing third-party actions that result in 

habitat loss and degradation, the BLM would

require and ensure mitigation that provides a 

net conservation gain to the species 

including accounting for any uncertainty 

associated with the effectiveness of such 

mitigation. This would be achieved by 

avoiding, minimizing, and compensating for 

impacts by applying beneficial mitigation 

actions.

No current management decision Vegetation objectives have been identified 

for sage-grouse breeding (leks, pre-laying, 

nesting and early brood-rearing) habitat on 

public land. The desired conditions for sagegrouse habitat presented are based on 

recommendations in current literature 

(Stiver, et al. 2014, Doherty, et al. 2014, 

Doherty, et al. 2011, Connelly, et al. 2000b, 

and Hagen, et al. 2007) and have been 

modified to more accurately reflect local 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-126 Chapter 2: Resource Management Alternatives

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

conditions based on the vegetative potentials 

identified for ecological sites in the Billings 

Field Office. Table 2.3 Billings Field Office 

Greater Sage-Grouse Habitat Objectives, is 

to be used as a minimum to meet the 

applicable Land Health Standard in sagegrouse habitats. 

No similar action These habitat objectives in Table 2.3

summarize the characteristics that research 

has found represent the seasonal habitat 

needs for Greater Sage-Grouse. The 

specific seasonal components identified in 

the Table were adjusted based on local 

science and monitoring data to define the 

range of characteristics used in this 

subregion. Thus, the habitat objectives 

provide the broad vegetative conditions we 

strive to obtain across the landscape that 

indicate the seasonal habitats used by sagegrouse. These habitat indicators are 

consistent with the rangeland health 

indicators used by the BLM.

The habitat objectives would be part of the 

sage-grouse habitat assessment to be used 

during land health evaluations (Monitoring 

Framework, Appendix AA, section B). These 

habitat objectives are not obtainable on 

every acre within the designated GRSG 

habitat management areas. Therefore, the 

determination on whether the objectives 

have been met would be based on the 

specific site's ecological ability to meet the 

desired condition identified in the table. 

All BLM use authorizations would contain 

terms and conditions regarding the actions 

needed to meet or progress toward meeting 

the habitat objectives. If monitoring data 

show the habitat objectives have not been 

met nor progress being made towards 

meeting them, there would be an evaluation 

and a determination made as to the cause. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-127

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

If it is determined that the authorized use is a 

cause, the use would be adjusted by the 

response specified in the instrument that 

authorized the use. 

Surface use is prohibited from December 1 

to March 31 within crucial winter range for 

sage-grouse. Stipulation does not apply to 

the operation and maintenance of 

production facilities.

Note: Crucial winter range was not 

designated for Greater Sage-Grouse.

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 Greater 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. 

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 2 miles of a Greater SageGrouse lek (TL). 

Surface occupancy and use is prohibited 

within Greater sage-grouse crucial winter 

range (NSO).

No similar action Manage priority sage‐grouse habitats so that 

discrete anthropogenic disturbances cover less 

than 3% of the total sage‐grouse habitat 

regardless of ownership to protect priority 

sage‐grouse habitats from anthropogenic 

disturbances that would reduce distribution or 

abundance of sage‐grouse. 

The BLM would apply appropriate 

mitigation measures and conservation 

actions to BLM authorized activities to 

avoid, minimize, rectify, reduce, or 

compensate for impacts if an evaluation of 

the project area indicates the presence of 

important wildlife species, seasonal wildlife 

habitat, or other resource concern. 

If the 3% anthropogenic disturbance cap is 

exceeded on lands (regardless of land 

ownership) within GRSG Priority Habitat 

Management Areas in any given Biologically 

Significant Unit, then no further discrete 

anthropogenic disturbances (subject to 

applicable laws and regulations, such as the 

1872 hard rock mining law, valid existing 

rights, etc.) would be permitted by BLM 

within GRSG Priority Habitat Management 

Areas in any given Biologically Significant 

Unit until the disturbance has been reduced 

to less than the cap.

If the BLM determines that the State of 

Montana has adopted a GRSG Habitat 

Conservation Program that contains 

comparable components to those found in 

the State of Wyoming’s Core Area Strategy 

including an all lands approach for 

calculating anthropogenic disturbances, a 

clear methodology for measuring the density 

of operations, and a fully operational Density 

Disturbance Calculation Tool, the 3% 

disturbance cap would be converted to a 5% 

cap for all sources of habitat alteration within 

a project analysis area
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-128 Chapter 2: Resource Management Alternatives

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources 

Record# Alternative A 

(No Action Alternative) Alternative B Alternative C Alternative D (Proposed Alternative) 

If the 3% disturbance cap is exceeded on all 

lands (regardless of land ownership) within a 

proposed project analysis area in a Priority 

Habitat Management Areas, then no further 

anthropogenic disturbance would be 

permitted by BLM until disturbance in the 

proposed project analysis area has been 

reduced to maintain the area under the cap 

(subject to applicable laws and regulations, 

such as the 1872 hard rock mining law, valid 

existing rights, etc.). 

Priority Habitat Management Areas (PHMAs) for Greater Sage-Grouse habitat: to maintain or improve Greater Sage-Grouse populations by maintaining Greater Sage-Grouse 

habitat in good condition.

No similar action - Greater Sage-Grouse 

habitat is managed uniformly throughout the 

planning area. 

Establish Greater Sage-Grouse PHMAs (158,926 acres of BLM-administered lands and 60,569 acres of federal minerals). These PHMAs 

are generally consistent with MTFWP Greater Sage-Grouse core area designations, with the exception of one small area in southern 

Carbon County near Elk Basin Oil field (Map 23). 

No similar action In all Priority Habitat Management Areas, the 

desired condition is to maintain a minimum 

of 70% of lands capable of producing 

sagebrush with 10 to 30% sagebrush canopy 

cover. The attributes necessary to sustain 

these habitats are described in Interpreting 

Indicators of Rangeland Health (BLM Tech 

Ref 1734-6).* 

No similar action In undertaking BLM management actions, 

and consistent with valid and existing rights 

and applicable law in authorizing third-party 

actions, the BLM would apply the lek bufferdistances identified in the USGS Report 

Conservation Buffer Distance Estimates for 

Greater Sage-Grouse – A Review (Open File 

Report 2014-1239) in accordance with 

Appendix AA (section G). 

No similar action No waivers or modifications to a fluid mineral 

lease no-surface-occupancy stipulation 

would be granted. The Authorized Officer 

may grant an exception to a fluid mineral 

lease no-surface-occupancy stipulation only 

where the proposed action: 

* Footnote: 70% of the lands capable of producing that level will be
Billings and Pompeys Pillar National Monument 

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Chapter 2: Resource Management Alternatives 2-129

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

i. Would not have direct, indirect, or 

cumulative effects on GRSG or its habitat; 

or,

ii. Is proposed to be undertaken as an

alternative to a similar action occurring on a 

nearby parcel, and would provide a clear 

conservation gain to GRSG. 

Exceptions based on conservation gain (ii) 

may only be considered in (a) PHMAs of 

mixed ownership where federal minerals 

underlie less than fifty percent of the total 

surface, or (b) areas of the public lands 

where the proposed exception is an 

alternative to an action occurring on a 

nearby parcel subject to a valid Federal fluid 

mineral lease existing as of the date of this 

RMP [revision or amendment]. Exceptions 

based on conservation gain must also 

include measures, such as enforceable 

institutional controls and buffers, sufficient to 

allow the BLM to conclude that such benefits 

would endure for the duration of the 

proposed action’s impacts. 

Any exceptions to this lease stipulation may 

be approved by the Authorized Officer only 

with the concurrence of the State Director. 

The Authorized Officer may not grant an 

exception unless the applicable state wildlife 

agency, the USFWS, and the BLM 

unanimously find that the proposed action 

satisfies (i) or (ii). Such finding shall initially 

be made by a team of one field biologist or 

other GRSG expert from each respective 

agency. In the event the initial finding is not 

unanimous, the finding may be elevated to 

the appropriate BLM State Director, USFWS 

State Ecological Services Director, and state 

wildlife agency head for final resolution. In 

the event their finding is not unanimous, the 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-130 Chapter 2: Resource Management Alternatives

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

exception would not be granted. Approved 

exceptions would be made publically 

available at least quarterly."

No similar action Create Greater Sage-Grouse ACEC on the 

158,926 acres of BLM managed surface of 

Greater Sage-Grouse PHMAs.

No ACEC established

Open to oil and gas leasing and geophysical 

operations, subject to the following lease 

stipulations:

Surface occupancy and use would be 

prohibited within 0.25 miles of Greater SageGrouse leks (NSO).

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. 

Open to oil and gas leasing and 

development (including geophysical 

exploration). 

Surface occupancy and use would be 

prohibited within 0.6 miles of Greater 

Sage-Grouse leks (NSO).

Surface occupancy and use would be 

subject to the following special operating 

constraints: surface occupancy and 

surface disturbance density and mitigation 

plan (CSU).

Open to oil and gas leasing and development 

(including geophysical exploration).

To protect Greater Sage-grouse, a priority 

species for management, surface occupancy 

and use would be prohibited within Greater 

Sage-Grouse Priority Habitat Management 

Areas (NSO). 

Open to commercial renewable energy. Exclusion area for renewable and solar energy 

exploration and facility development.

Avoidance area for renewable and solar 

energy exploration and facility 

development with approved mitigation.

Same as B

Open for ROWs. Exclusion area for major and minor ROWs, 

except for valid existing rights. 

Avoidance area for major and minor 

ROWs. 

However ROWs would only be allowed in 

GRSG PHMAs where habitat functionality 

would be maintained.

Same as C

Greater Sage-Grouse Restoration Areas (RAs): In these areas, BLM would manage habitat so that Greater Sage-Grouse populations can be restored over the long-term. BLM would 

strive to restore historical Greater Sage-Grouse habitat functionality, or at a minimum, have no net loss of Greater Sage-Grouse habitat, to support Greater Sage-Grouse populations.

No similar action - Greater Sage-Grouse

habitat is managed uniformly throughout the 

planning area.

Establish RAs (78,927 acres of BLM-administered lands and 22,951 acres of federal mineral estate). These areas would include one small 

polygon of core habitat in Carbon County near Elk Basin Oil Field, as well as other areas (Map 23).

Open to oil and gas leasing and geophysical 

operations, subject to the following lease 

stipulations:

 Surface occupancy and use would be

prohibited within 1⁄4 miles of Greater 

Sage-Grouse leks (NSO).

 Surface occupancy and use would be

Surface occupancy and use for oil and gas 

exploration and development would be 

prohibited within 0.6 miles of Greater SageGrouse leks (NSO). 

Surface use for oil and gas exploration and 

development would be prohibited from March 1 

to June 15 in Greater Sage-Grouse nesting 

Surface occupancy and use for oil and 

gas exploration and development would 

be prohibited within 1⁄4 miles of Greater 

Sage-Grouse leks (NSO). 

Surface use for oil and gas exploration 

and development would be prohibited 

from March 1 to June 15 in sage- grouse 

Surface occupancy and use for oil and gas 

exploration and development would be 

prohibited within 0.6 miles of Greater SageGrouse leks (NSO). 

Surface use for oil and gas exploration and 

development would be prohibited from March 

1 to June 15 in Greater Sage-Grouse nesting 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-131

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

prohibited from March 1 to June 15 in 

sage- grouse nesting habitat within 2 

miles of a lek (TL). 

habitat within 4 miles of a lek (TL). 

Surface occupancy and use for oil and gas 

exploration and development would be subject 

to the following special operating constraints 

that would maintain Greater Sage-Grouse

habitat (CSU –surface occupancy and surface 

disturbance density and mitigation plan). 

nesting habitat within 2 miles of a lek (TL). habitat within 3 miles of a lek (TL). 

Surface occupancy and use for oil and gas 

exploration and development would be 

subject to the following special operating 

constraints that would maintain Greater 

Sage-Grouse habitat: surface disturbance 

density and mitigation plan (CSU).

Open to geophysical exploration, subject to 

the following: 

 Surface occupancy and use would be

prohibited within 1⁄4 miles of Greater 

Sage-Grouse leks. (NSO) 

 Surface use is prohibited from March 1

to June 15 in grouse nesting habitat

within 2 miles of a lek (TL).

Geophysical exploration would be allowed on 

existing roads and trails with surface use 

prohibited from March 1 to June 15 within 4 

miles of a lek (TL). 

Geophysical exploration would be allowed 

if the applicant demonstrates that Greater 

Sage-Grouse habitat suitability would be 

maintained.

Same as B

Open to commercial renewable energy. GRSG Restoration Areas outside of Elk Basin 

would be exclusion areas for renewable and 

solar energy exploration and facility 

development. 

GRSG Restoration Areas outside of Elk 

Basin would be avoidance areas for 

renewable and solar energy exploration, 

development and facilities with approved 

mitigation.

Same as C

Open to commercial renewable energy. The Elk Basin GRSG Restoration Area would 

be an exclusion area for renewable and solar 

energy exploration and facility development. 

The Elk Basin GRSG Restoration Area 

would be an avoidance area for 

renewable and solar energy exploration, 

development and facilities with approved 

mitigation.

Same as B

Open for ROWs Avoidance area for major and minor ROWs. Avoidance area for major and minor 

ROWs. 

However ROWs would only be allowed in 

GRSG RAs where habitat functionality 

would be maintained.

Same as C

Greater Sage-Grouse Habitat: General Habitat Management Areas (GHMAs): BLM would maintain habitat for viable Greater Sage-Grouse populations to promote movement and 

genetic diversity. Maintain, restore or enhance Greater Sage-Grouse habitat and connectivity between sagebrush habitats, with emphasis on those habitats occupied by Greater SageGrouse.

Greater Sage-Grouse habitat is managed 

uniformly throughout the planning area.

Establish General Habitat Management Areas (113,816 acres of BLM-administered lands and 57,420 acres of federal mineral estate). 

These areas include a 3 mile buffer around Greater Sage-Grouse leks, outside of the PHMA and RA areas (Map 23).

No similar action In undertaking BLM management actions, 

and consistent with valid and existing rights 
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2-132 Chapter 2: Resource Management Alternatives

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

and applicable law in authorizing third-party 

actions, the BLM would apply the lek bufferdistances identified in the USGS Report 

Conservation Buffer Distance Estimates for 

Greater Sage-Grouse – A Review (Open File 

Report 2014-1239) in accordance with 

Appendix AA (section G).

Oil and gas leasing and development would 

not be allowed within 1⁄4 mile of Greater 

Sage-Grouse leks (NSO).

Oil and gas surface occupancy and use 

would be prohibited from March 1 to June 15 

in Greater Sage-Grouse nesting habitat 

within 2 miles of a lek (TL). 

Surface occupancy and use for oil and gas 

exploration and development would be 

prohibited within 0.6 miles of the perimeter of 

Greater Sage-Grouse leks (NSO). 

To protect nesting Greater Sage-grouse, 

surface occupancy and use within 2 miles of a 

lek may be restricted or prohibited. Prior to 

such activities, a plan to mitigate impacts to 

nesting Greater Sage-grouse and Greater 

Sage-grouse nesting habitat would be 

prepared by the proponent and implemented 

upon approval by the authorized officer (CSU).

Oil and gas leasing and development 

would be prohibited within 1⁄4 miles of 

Greater Sage-Grouse leks (NSO). 

Surface use for oil and gas exploration 

and development would be prohibited 

from March 1 to June 15 in Greater SageGrouse nesting habitat within 2 miles of a 

lek (TL). 

Same as B

Open to geophysical exploration, subject to 

the following: 

 Surface occupancy and use would be

prohibited within 1⁄4 mile of Greater 

Sage-Grouse leks. (NSO) 

 Surface use is prohibited from March 1

to June 15 in grouse nesting habitat

within 2 miles of a lek (TL).

Geophysical exploration would be allowed on 

existing roads and trails with surface use 

prohibited from March 1 to June 15 within 3 

miles of a lek (TL). 

Geophysical exploration would be allowed 

with mitigation to maintain Greater SageGrouse habitat suitability. 

Same as B

Open to commercial renewable energy. Exclusion area for renewable and solar energy 

exploration and facility development. 

Avoidance area for renewable and solar 

energy exploration, development and 

facilities with approved mitigation.

Same as C

Open for ROWs GRSG GHMAs would be avoidance areas for 

major and minor ROWs.

ROWs would be allowed.

Utilities and similar facilities would be 

located adjacent to other facilities where 

practical and only when habitat can be 

maintained.

GRSG GHMAs would be avoidance areas for 

major ROWs. 

GRSG GHMAs would be open to minor 

ROWs.

Utilities and similar facilities would be located 

adjacent to other facilities where practical and 
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Chapter 2: Resource Management Alternatives 2-133

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

only when habitat can be maintained.

Fisheries Habitat and Special Status Species (Fisheries)

The BLM goals for the management of fisheries resources within the Billings Field Office decision area are to manage aquatic and riparian habitats to provide native and desirable non-native 

aquatic species diversity and viability, sustaining ecological, economic and social values while providing for multiple uses of public lands. The BLM partners with Montana Fish, Wildlife and Parks 

(MTFWP) and other natural resource management agencies in plans to provide sound ecological management of aquatic resources, implementing a variety of management actions that regulate 

resource uses or activities that have the potential to degrade or enhance riparian and aquatic habitats. The actions specific to fisheries and aquatic resource management are listed below, by 

alternative. These actions primarily focus on reducing ground disturbance in or near riparian areas adjacent to fisheries and water resources, which can lead to degraded riparian function, 

increasing erosion, sedimentation, and water temperatures, and direct habitat alteration (increased width to depth ratios, removal of security cover and loss of coarse woody debris recruitment).

These actions would guide the authorization of BLM activities, ensuring the maintenance or enhancement of riparian and aquatic habitats to protect water quality, fisheries and other aquatic species 

from harmful impacts associated with those activities. The BLM identifies opportunities to protect these resources in partnership with private land owners adjacent to public lands, generally 

expanding quality fisheries and habitat management where feasible. Actions under “Management Common to All Alternatives”, sets the basis for fisheries habitat management, while those actions 

in various alternatives provides a range of levels of protection that may impact other resource uses. Some actions associated with other resources (soils, water, wildlife, vegetative communities, 

etc.) benefit fisheries resources by concentrating on watershed health, promoting proper drainage of the surrounding uplands.

The Billings Field Office decision area contains populations of Yellowstone Cutthroat Trout (YCT) and associated habitat. YCT are a BLM special status fish species, warranting specific actions to 

protect and enhance existing populations and habitat conditions. Many actions listed below have been developed through cooperative efforts to ensure viable populations persist in existing habitats, 

as well as opportunistically restoring habitats and populations in streams that currently do not have populations.

Fisheries – Desired Outcomes (Goals and Objectives)

 Manage aquatic habitat to provide native and desirable non-native species diversity and viability, and sustain ecological, economic, and social values while providing for multiple uses of public

lands.

 Manage aquatic ecosystems to provide sustainable recreational and educational benefits to the public.

 Manage fisheries habitat to support Montana Fish, Wildlife and Park’s Strategic Habitat Plan and the Montana Comprehensive Fish and Wildlife Conservation Strategy.

 Management activities would emphasize restoration and/or maintenance of riparian structure, composition, and processes, including physical integrity of riparian ecosystems, amount and

distribution of woody debris to sustain physical and biological complexity, adequate summer and winter thermal regulation, water quality and hydrologic processes, distribution and diversity of

riparian vegetative communities and source habitats for riparian dependent species.

 Use cooperative efforts to minimize negative impacts to, or enhance aquatic ecosystems on adjacent private lands.

 Coordinate with other agencies to prevent or control diseases, pests and species that threaten the health of humans, wildlife, livestock, and vegetation.

 Manage or restore habitat on BLM-administered lands within the planning area to facilitate the conservation, recovery and maintenance of populations of native and special status species

(BLM special status species, Candidate species, USFWS listed, proposed, or petitioned species) consistent with appropriate local, state, and federal management plans.

 Yellowstone Cutthroat Trout bearing waters and associated riparian habitat would be managed to protect all ecological values necessary to maintain or enhance YCT populations (using

guidelines outlined in the Conservation Strategy for Yellowstone Cutthroat Trout in the States of ID, MT, UT, NV, and WY).

Fisheries – Management Common to All Alternatives

Manage riparian areas and wetlands supporting fisheries toward PFC, as required through Standards and Guidelines.

Roads would be located, designed and maintained, to the extent practical, to reduce sedimentation, identify and remove unnatural barriers, eliminate fish passage barriers (when 

desired), and restore or maintain riparian vegetation.

Manage siting of facilities to minimize impacts on fish habitat function and quality, to minimize impacts on vegetation resources for all uses, and to minimize fish mortality during the life of 
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Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

the facility.

If natural barriers cannot be used, in-channel barriers (including selective barriers) would be constructed downstream of the native fish populations at risk from invasion.

Impacts beyond the riparian zone would be considered as part of YCT habitat management. Project-level activities would mitigate impacts on water quality, in-stream habitat, channel 

morphology, and riparian areas to benefit YCT populations.

Habitat-improvement techniques would be used where appropriate to provide missing habitat components or improve existing habitats. 

The BLM would continue to partner with MT FWP in the establishment of fishing access sites.

Land and water management decisions likely to affect YCT populations would include both pre- and post-project evaluation and monitoring to ensure that the habitat elements for YCT 

are protected. 

Use restoration to enhance YCT habitat and riparian function where habitat conditions are determined to be degraded. 

Opportunistically enhance or restore habitat for populations of YCT.

Establish high priority YCT habitat zones and increase monitoring on YCT bearing streams to ensure no significant degradation to water quality and fish habitat. 

Develop and maintain a prairie fish and fish habitat inventory and identify potential or suitable habitat.

Fisheries – Management Actions by Alternative

No current management decision provided Mitigation of surface-disturbing activities would be applied where needed to minimize impacts of human activities on important fisheries, 

riparian and water resources, consistent with the stipulations identified for oil and gas development in this section. Mitigation measures 

would be applied during activity level planning if an on-site evaluation of the project area indicates the presence of important fisheries, 

water or riparian resources. Exceptions may be granted by the authorized officer, if an environmental review demonstrates that effects 

could be mitigated to an acceptable level, habitat for the species is not present in the area, or portions of the area can be occupied without 

affecting a particular species or habitat. Exceptions may also be granted where the short-term effects are mitigated by the long-term 

benefits (e.g., prescribed fire, wildlife monitoring, forest health treatments, and habitat restoration).

As defined in this chapter and in the Glossary, surface-disturbing and disruptive activities would not prohibit all activities or authorized 

uses. For example, emergency activities (e.g., fire suppression, search and rescue), rangeland monitoring, routine maintenance associated 

with an approved authorization, dispersed recreational activities (e.g., hunting, hiking), and livestock grazing are not considered surfacedisturbing or disruptive activities.

Oil and gas leasing and development would 

only be allowed with an NSO stipulation on 

riparian areas or wetlands. NSO within 100 

year flood plains of major rivers and on 

water bodies and streams.

Surface occupancy and use for oil and gas 

exploration (including geophysical operations) 

would be prohibited within 1⁄4 mile of riparian 

areas and wetlands, water bodies, perennial 

streams, and flood plains of perennial streams. 

Surface occupancy and use for oil and 

gas exploration (including geophysical 

operations) would be prohibited within 

riparian areas and wetlands, water bodies, 

perennial streams, and flood plains of 

perennial streams. 

Surface occupancy and use for oil and gas 

exploration (including geophysical 

operations) would be prohibited within 

riparian areas and wetlands, water bodies, 

perennial and intermittent streams, and 

floodplains of perennial streams. (NSO)

Surface occupancy and use would be 

controlled within 300 feet of riparian and/or 
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Chapter 2: Resource Management Alternatives 2-135

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

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Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

wetland areas. Surface-disturbing activities 

would require a plan with design features that 

demonstrate how all actions would maintain 

and/or improve the functionality of riparian 

and wetland areas, The plan would address: 

(a) potential impacts to riparian and wetland 

resources, (b) mitigation to reduce impacts to 

acceptable levels (including timing 

restrictions), (c) post project restoration, and 

(d) monitoring (the operator must conduct 

monitoring capable of detecting early signs of 

change in riparian and/or wetland conditions. 

(CSU)

No current management decision provided. Surface occupancy and use for oil and gas 

exploration (including geophysical operations) 

would be prohibited within 1⁄2 mile of Blue and 

Red Ribbon streams, YCT populations and 

YCT suitable habitat (Maps 26-28). 

Surface occupancy and use for oil and 

gas exploration (including geophysical 

operations) would be prohibited within 1⁄4 

mile of Class I (Blue Ribbon) streams, and 

YCT populations (Maps 26, 27). 

Surface occupancy and use for oil and gas 

exploration (including geophysical 

operations) would be prohibited within 1⁄2 mile 

of Class I (Blue Ribbon) streams, and YCT 

populations (Maps 26, 27).

NSO for oil and gas leasing and 

development and geophysical exploration 

within 1⁄4 mile of designated reservoirs with 

fisheries. 

Surface occupancy and use for oil and gas 

exploration (including geophysical operations) 

would be prohibited within 1⁄2 mile of 

designated reservoirs with fisheries.

Same as A Same as A

Spring developments would be considered 

on a case-by-case basis.

New spring developments would not be

authorized in riparian areas or wetlands. 

New spring developments would be 

authorized and fenced if the development 

would maintain the integrity and 

functionality of the associated riparian 

area/wetland. 

Same as C

Approximately 10 miles of streams with 

active fisheries would be surveyed per year 

to collect species occurrence and habitat 

condition data.

Habitat conditions would be monitored on fishbearing streams (approx. 10 miles) on a 3 year 

rotation.

Fish-bearing stream habitat would not be 

surveyed or monitored. Other source-data 

(e.g., FWP) would be used to assist in 

management decisions as needed.

Habitat conditions would be monitored on 

fish-bearing streams (approx. 7 miles) with 

existing or potential threats, where grazing or 

human-caused impacts are likely. 

No current management decision provided Livestock grazing would be excluded from fish 

bearing streams and associated riparian 

habitat. 

Fencing around the riparian zone, or at least 

50’ from the water’s edge or using drift fence 

or other methods to exclude livestock from the 

riparian zone.

Livestock grazing would be allowed on 

YCT- bearing or other sensitive habitats 

as long as rangeland health standards are 

being met. If standards cannot be met 

through grazing management, grazing 

would be excluded. 

Fencing around the riparian zone, or at 

Same as C
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Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

least 50’ from the water’s edge or using 

drift fence or other methods to exclude 

livestock from the riparian zone.

Survey three reservoirs per year to 

determine suitability for sport fishery.

Reservoir fishery development would not be 

promoted by the BLM.

Existing and potential reservoirs would be 

developed to promote recreational 

fisheries and riparian/aquatic habitat 

enhancement. 

Development of existing or potential 

reservoirs would be considered to promote 

recreational fisheries and riparian/aquatic 

habitat enhancement.

Wild Horses 

Protection, management, and control of wild horses to ensure a thriving natural ecological balance and preserving multiple use relationships are the primary management drivers for wild horses 

maintained on BLM administered lands. Wild horses are principally managed under authorities from the Wild Free-Roaming Horse and Burro Act of 1971, as amended. Numerous other public land 

laws (e.g. Federal Land Policy and Management Act, Public Range Improvement Act, Taylor Grazing Act, Antiquities Act, Wilderness Act) other Federal Agencies (e.g. United States Forest Service, 

National Park Service) and Secretarial Orders also dictate management activities that can occur on the land and resources that wild horses use. Due to this myriad of public land law, the primary 

management tool for wild horses is maintenance of numbers or appropriate management level (AML) through removal of excess animals or fertility control (e.g. birth control or sterilization). 

Management of the wild horses on the range is designed to manage both the population and individual animals while making progress towards standards for rangeland health, in balance with other 

multiple uses. 

Wild Horses– Desired Outcomes (Goals and Objectives)

 Maintain, protect, manage, and control a healthy wild horse herd inside the herd management area within the appropriate management level to ensure a thriving natural ecological balance,

while preserving multiple use relationships with other uses and resources, and making progress towards Standards for Rangeland Health (Standards 1 and 5).

 Maintain a wild horse herd that exhibits a diverse age structure, genetic diversity, and any characteristics unique to the Pryor horses.

 Manage wild horses within a balanced program which considers all values without impairment to the productivity of the land.

Wild Horses– Management Common to All Alternatives

Initially, the wild horse population would be managed within a population range between 90 to 120 wild horses. 

Maintain a wild horse herd that exhibits a diverse age structure, genetic diversity, and any characteristics unique to the Pryor horses.

Unless otherwise specified, implementation level planning through a Herd Management Area Plan (HMAP) or other activity level plans would identify and set objectives for, but not limited 

to, the following: herd composition, animal characteristics, genetics, and habitat development needs; soil, vegetation, and watershed characteristics; and establishment and adjustment to 

appropriate management level (AML).

Appropriate management levels would be adjusted as needed to ensure a thriving natural ecological balance through monitoring and data collection including but not limited to: forage 

utilization, trend, ecological condition, precipitation data, rangeland health assessments, population inventory, climate or habitat changes, and range availability.

Wild Horses– Management Actions by Alternative

Herd Management Area Establishment

Manage wild horses on approximately 

24,595 acres of BLM-administered lands 

(37,494 acres all ownerships) (Map 31). 

Manage wild horses only within the boundaries 

of the original Secretarial Orders from 1968 

and 1969 (23,204 acres BLM-administered 

Manage wild horses on approximately 

28,622 acres of BLM-administered lands 

(44,855 acres all ownerships) (Map 33). 

Manage wild horses on approximately 27,094 

acres of BLM-administered lands (39,994 

acres all ownerships) (Map 34). 
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Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Keep the administrative pastures closed as 

well as areas adjacent to private lands to 

reduce public/private conflicts.

lands and 31,153 acres all ownerships) (Map 

32). 

The rest of the Herd Area would be closed to 

wild horse use in order to maximize protection 

of plant species of concern, sub-alpine 

meadows and to protect wild horses from 

commercial uses.

Designate the entire Herd Area as the 

Herd Management Area.

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.

Herd Characteristics

Within an HMAP, herd structure would be 

managed for all representations in the herd, 

not allowing specific colors or bloodlines to 

dominate from management manipulation.

Within an HMAP, herd structure would be 

managed through natural selection with no 

promotion of any characteristics or 

preservation of colors or bloodlines.

Within an HMAP, herd structure would be 

managed for and to promote the public 

perception of the quintessential Pryor 

horse that is Dun or Grulla with striping 

and line back markings.

Same as A

Appropriate Management Levels

Appropriate management level (AML) 

determination would be made within the 

context of having the maximum amount of 

wild horses the range can sustain while 

preventing deterioration.

Appropriate management level (AML)

determination would be made within the 

context of having a minimum amount of wild 

horses in order to improve ecological 

conditions, protecting other resources and 

individual animals.

Same as A Same as A

Wild Horse Habitat

Range improvements would be authorized 

through site-specific analysis. Vegetation 

conversion treatments would not be allowed.

Range improvements and/or vegetation 

treatments would not be authorized in wild 

horse habitat; only natural processes would be 

allowed to occur.

Maximize the amount of acres available 

for vegetation treatments and/or water 

developments that potentially increase 

forage availability for wild horses that is 

compliant with other multiple-use 

decisions and restrictions.

Same as C

Cultural and Heritage Resources

Management of cultural resources is directed primarily, but not exclusively, by two laws: the National Historic Preservation Act of 1966, as amended, and the Archaeological Resources Protection 

Act of 1979. The National Historic Preservation Act requires management and enhancement of significant historic properties and the Archaeological Resources Protection Act requires protection of 

archaeological resources (sites and objects of 100 years or more in age). The Federal Land Policy and Management Act directs the Bureau of Land Management to manage public lands on the 

basis of multiple use and to “protect the quality of historical resources and archaeological values.” This act provides for the periodic inventory of public lands and resources. 

Following Washington Office Instruction Bulletin 2002-101, the BLM would allocate all cultural resources in the Billings Field Office, whether already recorded or projected to occur on the basis of 

existing data synthesis (including cultural landscapes), or not projected to occur but later identified through inventory, to the following uses according to their nature and relative preservation value. 

These use allocations pertain to cultural resources, not to areas of land. Each resource would be assigned to a primary use category, but that assignment would not preclude management from 

other use categories. The six types of use allocations are: Scientific Use, Conservation for Future Use, Traditional Use, Public Use, Experimental Use, and Discharged from Management. See the 
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Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

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Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Cultural category in the glossary for cultural use allocation definitions and Appendix F for management direction of site types.

Cultural and Heritage Resources – Desired Outcomes (Goals and Objectives)

 Identify, preserve, and protect significant cultural resources and ensure that they are available for appropriate uses by present and future generations (FLPMA, Section 103 (c), 201(a) and (c);

National Historic Preservation Act, Section 110(a); Archaeological Resources Protection Act, Section 14(a)).

 Seek to reduce imminent threats and resolve potential conflicts from natural or human-caused deterioration, or potential conflict with other resource uses (FLPMA Section 203(c), NHPA 106,

110(a) (2)) by ensuring that all authorizations for land use and resource use would comply with the NHPA Section 106.

 Cultural resources on BLM-administered land would be protected and maintained in stable condition. Appropriate management actions would be determined after evaluation and allocation of

cultural resource use categories through cultural resource project plans.

 Maintain viewsheds of important cultural resources whose settings contribute significantly to their scientific, public, traditional, or conservation values.

 Provide and promote research opportunities that would contribute to our understanding of the ways humans have used and influenced the landscape.

 Manage historic trails to realize their educational, recreational, and scientific values.

 Enhance public understanding of, and appreciation for, cultural resources through educational outreach and heritage tourism opportunities.

Cultural and Heritage Resources – Management Common to All Alternatives

Evaluate cultural resources according to National Register criteria (36 CFR Part 60.4) and assign cultural resources to appropriate use categories as the basis for management decisions 

(see Appendix F)

All sites determined eligible to the National Register of Historic Places would be allocated and managed for Scientific, Public, Traditional, Experimental, and/or Conservation for Future 

Use. However, if another use becomes evident or proposed after use allocation has occurred, the use allocation may be changed without a plan amendment.

All sites determined not eligible to the National Register of Historic Places and not containing antiquities or archaeological resources would be allocated and managed as Discharged 

from Management Use

Cremains scattering would not be permitted on prehistoric or historic archaeological sites, buildings, or structures, Native American burials, sacred sites, or traditional cultural use areas.

Design and maintain facilities to preserve the visual integrity of cultural resources, settings, and cultural landscapes consistent with VRM objectives established in the RMP

Where feasible, acquire properties adjacent to public lands through donation, exchange, or purchase that contain significant cultural resources including, but not limited to, those 

properties eligible for inclusion on the NRHP

A lease notice (consistent with the Montana guidance for cultural resource protection related to oil and gas) would continue to be issued to ensure that leased lands are examined to 

determine if cultural resources are present and to specify mitigation measures.

A lease notice stipulation would be attached to oil and gas leases around the Lake Mason National Wildlife Refuge to protect cultural resources.

A lease notice for NHPA, AIRFA, NAGPRA and E.O. 13007 would be attached to all oil and gas leases. 

Cultural and Heritage Resources – Management Common to Action Alternatives

Allowed A Lease Notice for sacred sites and Historic Properties would be attached to oil and gas leases.

Allowed No Surface Occupancy (NSO) stipulation would be attached to leases for cemeteries or individual gravesites located on private 
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Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

surface/federal mineral estate (known cemeteries include: Annherer Spring Grave, Sunrise Cemetery, Castle Butte Cemetery, and Cabin 

Creek Cemetery)

Allowed NSO within 1⁄2 mile of cultural properties of particular importance to Native Americans (TCPs, traditional use areas, burials, plant gathering 

locations, etc.) 

Cultural and Heritage Resources – Management Actions by Alternative

The following sites include a small buffer 

zone for protection from oil and gas actions 

(NSO):

 Steamboat Butte

 Bruder-Janich Site

 Paul Duke Site

 Demi-John Flat NR District

 Young’s Point

 Bighorn Mouth North Cliffs Rock Art

Site

 Gyp Springs Site

 Hoskins Basin Archaeological District

The following sites, districts, or areas would not 

be available for oil and gas leasing, 

exploration, and/or development (NL): 

 Steamboat Butte

 Bruder-Janich Site

 Paul Duke Site

 Demi-John Flat NR District

 Bighorn Mouth North Cliffs Rock Art Site

 Gyp Springs Site

 Hoskins Basin Archaeological District

NSO for oil and gas leasing, development 

and/or exploration on the following sites, 

districts, or areas:

 Steamboat Butte

 Bruder-Janich Site

 Paul Duke Site

 Demi-John Flat NR District

 Bighorn Mouth North Cliffs Rock Art

 Gyp Springs Site

 Hoskins Basin Archaeological

District

 Bandit Site (48BH0460)

Same as C

NSO within sites or areas designated for 

conservation use, public use or sociocultural use.

NSO within sites or areas designated for 

conservation use, public use, scientific use, or 

traditional use.

NSO within eligible sites or areas 

designated for conservation use, public 

use, scientific use, or traditional use, 

including those areas determined to be 

traditional cultural properties and/or 

designated for traditional use.

Same as C

No current management decision provided NSO within 1⁄2 mile for oil and gas leasing, 

exploration and/or development on the 

following historic trails:

 Bridger Cut-Off Trail

 Meeteetse Trail

Oil and gas leasing, exploration and

development would be allowed within 1⁄4 

mile of the following historic trails with 

stipulations (CSU):

 Bridger Cut-Off Trail

 Meeteetse Trail

Same as C

Parameter – Cultural Resource Use Allocation – Rock Art Sites

The following sites would be allocated to 

conservation or socio-cultural use:

 Steamboat Butte

 Paul Duke Site

 Petroglyph Canyon ACEC

 Castle Butte ACEC

 Young’s Point

Allocate and manage all National Register 

eligible rock art sites for Conservation, 

Traditional, and/or Scientific Use. 

No interpretative sites would be developed

Allocate and manage all National Register 

eligible rock art sites for Conservation, 

Traditional, and/or Public Use.

Up to four sites would be developed for 

interpretative use.

Allocate and manage all National Register 

eligible sites for Conservation, Scientific, 

Traditional, and /or Public Use. 

Interpretative sites would be developed as 

appropriate.
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Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

 Weatherman Draw ACEC

 Bighorn Mouth North Cliffs Rock Art

Site

Parameter – Cultural Resource Use Allocation – Rockshelter/Cave Sites

The following sites would be allocated to 

conservation or socio-cultural use:

 Steamboat Butte

 Petroglyph Canyon NR Site

 Stark Bison Kill Site

 Young’s Point

 Dryhead Overlook site

 Weatherman Draw

 Sykes Spring Site

Allocate and manage all National Register 

eligible sites for Conservation and/or 

Traditional Use. No interpretative sites would 

be developed

Allocate and manage all National Register 

eligible sites to Conservation, Scientific, 

and/or Public Use. Up to five sites would 

be developed for interpretative use.

Allocate and manage all National Register 

eligible sites for Conservation, Scientific, 

Traditional, and /or Public Use. Interpretative 

sites would be developed as appropriate.

Parameter – Cultural Resource Use Allocation – Aboriginal Occupation Sites and Structures (prehistoric & protohistoric)

The following sites would be allocated to 

conservation or socio-cultural use:

 Steamboat Butte

 Paul Duke Site

 Petroglyph Canyon NR Site

 Demi-John Flat NR District

 Castle Butte

 Stark Bison Kill Site

 Young’s Point

 Gyp Springs Site

 Dryhead Overlook site

 Weatherman Draw

 Sykes Spring Site

 Bruder-Janich Site

Allocate and manage all National Register 

eligible sites to Scientific, Traditional, and/or 

Conservation Use. No interpretative sites 

would be developed

Allocate and manage all National Register 

eligible sites to Scientific Public and/or 

Conservation Use. Up to four 

interpretative sites would be developed.

Allocate and manage all National Register 

eligible sites to Scientific, Public, Traditional, 

and/or Conservation Use.

Interpretative sites would be developed as 

appropriate.

Parameter – Cultural Resource Use Allocation – Lithic Scatters/Workshops

Manage for future Cultural Resource Use 

Allocations

Allocate and manage all National Register 

eligible sites to Conservation Use.

Allocate and manage all National Register 

eligible sites to Conservation and or 

Scientific Use.

Same as C
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-141

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Parameter – Cultural Resource Use Allocation – Communal Kill Sites

The following sites would be allocated to 

conservation or socio-cultural use:

 Steamboat Butte

 Castle Butte

 Stark Bison Kill Site

 Young’s Point

 Sykes Spring Site

Allocate and manage all National Register 

eligible sites to Conservation and/or Scientific 

Use. No interpretative sites would be 

developed

Allocate and manage all National Register 

eligible sites to Scientific, Public, and/or 

Experimental Use. Up to five 

interpretative sites would be developed.

Allocate and manage all National Register 

eligible sites to Conservation, Scientific, 

and/or Public Use. Interpretative sites would 

be developed as appropriate.

Parameter – Cultural Resource Use Allocation – Aboriginal trails

Manage for future Cultural Resource Use 

Allocations. Allocate and manage DemiJohn Flat NR District.

Allocate and manage all National Register 

eligible sites to Conservation and/or Traditional 

Use. No interpretative sites would be 

developed

Allocate and manage all National Register 

eligible sites to Conservation and/or 

Public Use. Up to three interpretative 

sites would be developed.

Allocate and manage all National Register 

eligible sites to Conservation, Traditional, 

and/or Public Use.

Interpretative sites would be developed as 

appropriate

Parameter – Cultural Resource Use Allocation – Lithic Procurement Sites/Quarries (bedrock and surface)

Manage for future Cultural Resource Use 

Allocations

Allocate and manage all National Register 

eligible lithic procurement sites/quarries to 

Conservation and/or Traditional Use 

Allocate and manage all National Register 

eligible lithic procurement sites/quarries to 

Conservation, Traditional, and/or 

Scientific Use.

Same as C

Parameter – Cultural Resource Use Allocation – Vision Quest Sites/Sacred Sites/TCPs/Ethnohistoric Sites

Manage for future Cultural Resource Use 

Allocations

Allocate and manage all National Register 

eligible sites to Conservation and/or Traditional 

Use

Same as B Same as B

Parameter – Cultural Resource Use Allocation – Historic Features

Manage for future Cultural Resource Use 

Allocations

Allocate and manage all National Register 

eligible sites to Conservation and/or Scientific 

Use

Allocate and Mange all National Register 

eligible sites to Conservation and/or 

Public Use.

Same as B

Parameter – Cultural Resource Use Allocation – Historic Roads/Trails

Manage for future Cultural Resource Use 

Allocations

Allocate and manage all National Register 

eligible resources for Scientific, Conservation, 

and/or Public Use. No interpretative sites would 

be developed.

Allocate and manage all National Register 

eligible resources for Scientific, 

Conservation, and/or Public Use. 

Interpretative sites would be developed at 

all sites allocated and managed for Public 

Use.

Allocate and manage all National Register 

eligible resources for Scientific, Conservation, 

and/or Public Use. 

Interpretative sites would be developed as 

appropriate.

Parameter – Cultural Resource Use Allocation – Historic Structures and/or Homesteads
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-142 Chapter 2: Resource Management Alternatives

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Manage for future Cultural Resource Use 

Allocations

Allocate and manage all National Register 

eligible sites to Scientific and/or Conservation 

Use. No interpretative sites would be 

developed

Allocate and manage all National Register 

eligible sites with standing structures to 

Public Use. Allocate and manage all 

National Register eligible sites to 

Scientific, Conservation, and/or Public 

Use. Up to three interpretative sites would 

be developed.

Allocate and manage all National Register 

eligible sites to Scientific, Conservation, 

and/or Public Use.

Interpretative sites would be developed as 

appropriate.

Parameter – Cultural Resource Use Allocation – Historic Industrial/Development (mines, oil/gas, etc.)

Manage for future Cultural Resource Use 

Allocations

Allocate and manage all National Register 

eligible sites to Conservation Use.

Allocate and manage all National Register 

eligible sites to Conservation and/or 

Scientific Use. 

Same as C

Parameter – Cultural Resource Use Allocation – Historic Structures and/or Homesteads

Manage for future Cultural Resource Use 

Allocations

Allocate and manage all National Register 

eligible sites to Scientific and/or Conservation 

Use. No interpretative sites would be 

developed

Allocate and manage all National Register 

eligible sites with standing structures to 

Public Use. Allocate and manage all 

National Register eligible sites to 

Scientific, Conservation, and/or Public 

Use. Up to three interpretative sites would 

be developed.

Allocate and manage all National Register 

eligible sites to Scientific, Conservation, 

and/or Public Use.

Interpretative sites would be developed as 

appropriate.

Parameter – Cultural Resource Use Allocation – “Other” Sites

Manage for future Cultural Resource Use 

Allocations

All National Register eligible sites would be 

allocated and managed for Scientific and/or 

Conservation Use. 

All National Register eligible sites would 

be allocated and managed for Scientific 

and/or Conservation Use with public use 

being monitored. 

Same as C

Paleontological Resources

The BLM has authority to manage and protect paleontological resources under the Paleontological Resources Preservation Act (PRPA) 2009 (P.L. 111-011 Title VI Subtitle D). PRPA directs the 

BLM to manage, protect, and preserve paleontological resources using scientific principles and expertise as well as provide for public education and awareness, scientific research, curation, and 

other proactive efforts. 

Paleontological Resources – Desired Outcomes (Goals and Objectives)

 Identify, manage, and monitor at-risk paleontological resources (scientific values); preserve and protect vertebrate fossils through best science methods; and promote public and scientific use

of invertebrate and paleo-botanical fossils.

 Manage fossil locales with high scientific value in a stable condition, while allowing appropriate scientific and public use.

 Locate, evaluate, and manage paleontological resources and protect them where appropriate

 Facilitate suitable scientific, educational, and recreational uses of fossils
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-143

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

 Ensure that significant fossils are not inadvertently damaged, destroyed, or removed from public ownership as a result of surface disturbance or land tenure adjustments

Paleontological Resources – Management Common to All Alternatives

The Potential Fossil Yield Classification (PFYC) system would be used to assess possible resource impacts and mitigation needs for Federal actions involving surface disturbance, land 

tenure adjustments, and land-use planning

Recreational collectors may collect and retain reasonable amounts of common invertebrate and plant fossils for personal, non-commercial use. Surface disturbance must be negligible 

and mechanized tools cannot be used

Vertebrate fossils can be collected only under a permit issued to qualified individuals. Vertebrate fossils include bones, teeth, eggs, and other body parts of animals with backbones, such 

as dinosaurs, fish, turtles, and mammals. Vertebrate fossils also include trace fossils such as footprints, burrows, gastroliths, and coprolites.

Fossils collected under a permit remain the property of the federal government and must be placed in a suitable repository which would be identified at the time of permit issuance

Lands identified for disposal or exchange would be evaluated to determine whether such actions would remove significant fossils from federal ownership

Where feasible, acquire properties adjacent to public lands through donation, exchange, or purchase that contain significant paleontological resources 

Surface occupancy and use is prohibited within designated or recorded paleontological sites (NSO)

Paleontological Resources – Management Actions by Alternative

The combination of Lease Stipulations and 

Lease Terms would mitigate impacts to 

paleontological resources on a case by case 

basis. 

For oil and gas leasing, exploration, and development occurring within PFYC Class 3 or higher, a lease notice would be attached. 

Assessment, inventory, and/or mitigation would be required based on PFYC class (Map 35).

No current management decision provided For all surface disturbing activities occurring within PFYC Class 3 or higher units, a stipulation or condition of approval would be included 

on the permitting document. Assessment, inventory, and/or mitigation would be required based on PFYC class (Map 35).

Written information about fossils and hobby 

fossil collecting would be provided

Written and web-based information would be 

provided about fossils, hobby collecting, and 

local interpretative sites

Same as A Written and web-based information would be 

developed, maintained, and provided about 

fossils and to promote visitor education

Paleontological Resource Use permits for 

scientific study would be issued

Paleontological Resource Use permits would 

be issued for scientific study, promoting or 

supporting investigations in poorly documented 

areas

Same as A Paleontological Resource Use permits would 

be issued for scientific study.

BLM would support investigations in lesser 

known areas and in areas where surface 

disturbance is occurring or anticipated.

Collection of common invertebrate and plant 

fossils for personal, non-commercial use 

would be allowed

Collection of common invertebrate and plant 

fossils would be allowed for personal, noncommercial use. 

Collection of common invertebrate and 

plant fossils for personal, non-commercial 

use would be allowed. 

Areas for hobby collection would be 

identified and monitored.

Collection of common invertebrate and plant 

fossils would be allowed for personal, noncommercial use. 

Areas with vertebrate fossils would be closed 

to common invertebrate and plant fossil 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-144 Chapter 2: Resource Management Alternatives

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

hobby collecting unless collection activity is 

authorized by the BLM.

Visual Resources

Visual resources are the visible physical features in a landscape defined by landforms, water, vegetation, animals, structures, and other natural or manmade features. The purpose of visual 

resource management (VRM) program is to manage the visual environment and any potential visual impediments while maintaining the viability of resource programs in the BiFO planning area. 

Lands are first inventoried using the visual resource inventory (VRI) process in BLM Manual 8410-1, and then assigned visual resource management classes (VRM) which have different 

management objectives, found in BLM Manual 8431-1. 

The Billings Field Office goal is to manage public lands for their scenic values while providing for the overall multiple-use and quality of experience to visitors of public lands. Through the VRI 

process, the Billings Field Office would establish visual management objectives to minimize adverse impacts to the visual resources on the landscape.

Visual Resources – Desired Outcomes (Goals and Objectives)

 Manage public lands for their scenic values while providing for the overall multiple-use and quality of experience to visitors of public lands.

 Establish visual management objectives to minimize adverse impacts to the visual resources on the landscape.

 Maintain the overall integrity of VRM classes, while allowing for modifications to landscapes in those classes, consistent with the established management objectives.

Visual Resources – Management Common to All Alternatives

Manage visual resources according to established guidelines for VRM classes. 

Use the visual resource contrast rating system during project level planning to determine whether or not proposed activities would meet VRM objectives. Identify appropriate mitigation 

measures to reduce visual contrasts.

Following BLM Handbook 8410-1 and BLM IM 2000-96, the Billings Field office would manage WSAs under VRM Class I objectives to maintain an undeveloped landscape and preserve 

their natural values.

Prepare rehabilitation plans to address landscape modifications on a case-by-case basis.

Visual Resources – Management Actions by Alternative

Manage BLM public lands according to the 

following Visual Resource Inventory (VRI) 

classifications (the existing 1984 RMP did 

not assign visual resource management 

(VRM) classifications) (Map 38):

 VRI Class A 28,717 acres

 VRI Class B 13,507 acres

 VRI Class B/C 391,113 acres

 VRI Class C 816 acres

Manage BLM public lands according to the 

following VRM class designations (Map 39):

 VRM Class I 56,700 acres

 VRM Class II 14,377 acres

 VRM Class III 362,905 acres

 VRM Class IV 0 acres

Manage BLM public lands according to 

the following VRM class designations 

(Map 40):

 VRM Class I 29,714 acres

 VRM Class II 26,569 acres

 VRM Class III 378,751 acres

 VRM Class IV 0 acres

Manage BLM public lands according to the 

following VRM class designations (Map 41):

 VRM Class I 29,714 acres

 VRM Class II 55,883 acres

 VRM Class III 349,441 acres

 VRM Class IV 0 acres

Oil and gas activities would be allowed in 

VRM Class II areas if the contrasting visual 

elements from the actions can be minimized 

Surface occupancy or use, surface disturbing 

activities, and construction of semi-permanent 

and permanent facilities in VRM Class II – IV 

areas would require special design including 

Same as A Same as B
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-145

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

or eliminated (CSU).

location, painting, and camouflage to blend 

with the natural surroundings and meet the 

visual quality objectives for each respective 

class (CSU).

Fire Ecology and Management

The BLM goals and objectives are to manage fire and fuels to protect life and property and to protect or enhance resource values and to enhance public awareness and knowledge of hazards 

associated with fuel accumulation and fire, as well as practical preventive measures especially in the wildland urban interface. The BLM works with the public to ensure a greater understanding 

about the natural role of fire in the ecosystem and the use of prescribed fire to protect property, reduce fuels, and maintain healthy plant and animal communities. The BLM provides guidance to 

develop management of wildfires with an emphasis on firefighter and public safety and works to use fire to protect, maintain, and enhance resources; and to function in its ecological role where 

appropriate. Management actions within the fire program are directed at integrating fire and fuels management across landscape, agency, and ownership boundaries and coordination with fire 

adapted communities and other government agencies to identify wildfire hazards and create mitigation strategies, as well as providing public education on fire ecology and ecosystem restoration.

Fire Ecology and Management – Desired Outcomes (Goals and Objectives)

 Manage wildfire and fuels for the protection of public health, safety, property, and resource values.

 Manage hazardous fuels in areas of urban and industrial interface to reduce potential loss due to fire.

 Maintain desired mix of seral stages within vegetation communities, including desert shrublands, forest and woodlands, grasslands, mountain shrublands, sagebrush (all sub-species),

riparian/wetlands and aspen.

 Manage vegetation communities through cooperative efforts by restoring natural fire regimes and frequency to the landscape, where appropriate.

 Maintain partnerships with the public and interagency cooperators to strengthen coordination of all fire management activities and encourage the creation of fire-safe communities.

 Utilize an integrated management technique unless otherwise restricted (defined as prescribed fire, mechanical, chemical, or biological, followed by desired reseeding) to reduce fuels to

protect high priority areas or resource values.

Fire Ecology and Management – Management Common to All Alternatives

In the course of fire suppression, a resource advisor would be consulted or assigned to wildfires that involve or threaten public lands.

The use of fire suppression chemicals would be limited around areas with rock art and standing structures and other areas with significant cultural resources (including ACECs). 

Use of wildfire suppression chemicals within 300 feet of waterways would be prohibited. 

Fuels treatments would be designed to protect or improve resource values. 

Emergency stabilization and rehabilitation of burned areas would be conducted according to current policy to protect and sustain ecosystems, public health and safety. 

Prevent the movement of wildfires from the wildlands into the Wildland Urban Interface area (Interagency Strategy for the Implementation of Federal Wildland Fire Management, pg. 28)

Within the following areas work to restore or maintain approximately 14,000 acres available for restoring natural Fire Regime Condition Classes in Musselshell, Stillwater, Carbon, and 

Sweet Grass Counties, should resource management constraints and considerations (i.e. Greater Sage-Grouse habitat, other identified T&E issues and culturally sensitive areas) 

allow. 

Fire Ecology and Management – Management Common to Action Alternatives
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-146 Chapter 2: Resource Management Alternatives

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

No similar management decision If prescribed fire is used in Greater SageGrouse habitat, the NEPA analysis for the 

Burn Plan would address:

 why alternative techniques were not

selected as a viable options;

 how Greater Sage-Grouse goals and

objectives would be met by its use;

 how the COT Report objectives would

be addressed and met;

 A risk assessment to address how 

potential threats to Greater SageGrouse habitat would be minimized.

a) Prescribed fire as a vegetation or fuels

treatment shall only be considered after 

the NEPA analysis for the Burn Plan

has addressed the four bullets outlined

above. Prescribed fire could be used to

meet specific fuels objectives that

would protect Greater Sage-Grouse

habitat in PHMAs (e.g., creation of fuel

breaks that would disrupt the fuel

continuity across the landscape in

stands where annual invasive grasses

are a minor component in the

understory, burning slash piles from

conifer reduction treatments, used as a

component with other treatment

methods to combat annual grasses and

restore native plant communities).

b) Prescribed fire in known winter range

shall only be considered after the

NEPA analysis for the Burn Plan has

addressed the four bullets outlined

above. Any prescribed fire in winter 

habitat would need to be designed to

strategically reduce wildfire risk around

and/or in the winter range and

designed to protect winter range

habitat quality.”

No similar management decision Remove conifers encroaching into 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-147

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

sagebrush habitats. Prioritize treatments 

closest to occupied sage-grouse habitats 

and near occupied leks, and where juniper 

encroachment is phase 1 or phase 2. Use of 

site-specific analysis and principles like 

those included in the FIAT report (Chambers 

et. al., 2014) and other ongoing modeling 

efforts to address conifer encroachment 

would help refine the location for specific 

priority areas to be treated. 

Fire Ecology and Management – Management Actions by Alternative

Use appropriate management response to 

implement protection objectives in 

accordance with management objectives 

based on current conditions and fire 

location. 

The full range of fire management activities 

would be used to help achieve ecosystem 

sustainability, including interrelated ecological, 

economical, and social components. Fire 

suppression strategies and tactics would be 

used in the following areas:

 Wildland urban interface

 Wildland industrial interface

 Developed recreation sites

 Developed electronics sites of all types

In all other areas, fire management strategies 

and tactics would be determined by (but not 

limited to) the following:

 Firefighter and public safety

 Resource values at risk

 Proximity to private land

 Firefighting resource availability

Fire suppression strategies would be used 

across the entire planning area.

Fire management strategies and tactics 

would be determined by (but not limited to) 

the following:

 Firefighter and public safety

 Resource values at risk

 Proximity to private land

 Firefighting resource availability

Response to wildfires would be based on 

ecological, social, economic and legal 

consequences of the wildfire.

Fire management strategies and tactics 

would be determined by (but not limited to) 

the following:

 Firefighter and public safety

 Resource values at risk

o In PHMA suppression

would be prioritized to

conserve habitat

o In GMHA, suppression

would be prioritized where

wildlfires threaten PHMA

 Proximity to private land

 Firefighting resource availability

Heavy equipment would not be used to 

construct fire lines in areas containing 

cultural resources. 

Cultural resource specialists or area 

resource advisors would be consulted for 

locations of identified areas before use of or 

anticipated use of heavy equipment. 

Exceptions may be permitted for protection 

of human life and/or property.

Heavy equipment generally would not be 

Tactical constraints would follow: 

 No heavy equipment would be used

within the following areas, except when

human safety is at risk:

 Areas of cultural resource sensitivity

 Riparian/wetland habitats

 Big game crucial winter range habitat

 Greater Sage-Grouse nesting habitat

within proximity of lek sites

 Areas of highly erosive soils

Tactical constraints would follow: 

 Heavy equipment use would be

allowed in all areas, unless otherwise

restricted (e.g., ACECs, WSAs, etc.).

 Heavy equipment would not be

restricted to roads and trails, except

where prohibited (ex: known special

status plant sites).

Heavy equipment would not be used to 

construct fire lines in crucial winter range, 

habitat of candidate or special status 

species, riparian/wetlands or in areas of 

cultural resource sensitivity or other 

designated areas (e.g., ACECs, WSAs). 

Exceptions would be permitted for protection 

of human life, property and/or to protect

resource values from further loss due to 

unwanted/unplanned natural or human 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-148 Chapter 2: Resource Management Alternatives

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

used to construct fire lines in critical winter 

range. Agency wildlife biologist(s) would be 

consulted when fires threaten critical winter 

range. If heavy equipment is used, 

rehabilitation work on lines would begin 

immediately after containment.

In areas not identified as full suppression, 

heavy equipment usage would be limited to 

existing roads and trails or immediately 

adjacent to them.

Full Suppression acreage

caused wildland fires. 

Cultural Resource Specialists, Wildlife 

Biologists, or Resource Advisors would be 

consulted for locations of identified areas 

before use of or anticipated use of heavy 

equipment.

If heavy equipment is used, rehabilitation 

work on lines would begin immediately after 

containment.

Heavy equipment could be used in a WSA 

only if the exceptions in the non-impairment 

standards are met.

In areas where a prescribed fire is planned, 

appropriate fire management would be used 

if a wildfire is meeting the stated resource 

management objectives of the prescribed 

fire project. 

Management plans would emphasize 

containment within the Project 

Area/Allowable area as developed in 

prescribed fire plans.

Wildfires (natural ignitions) that occur within or 

adjacent to an area identified for vegetation or 

fuels treatment could be managed to meet the 

desired management objectives.

Same as Alternative B. Same as Alternative B.

Fire management is categorized into six (6) 

Fire Management Units (FMUs). 

There are five (5) Category B FMUs. These 

areas are where unplanned wildfire is not 

desired because of current conditions and 

where an unplanned ignition would have 

negative effects unless/until some form of 

mitigation takes place.

There is one Category C FMU. This area is 

where wildfire is desired, but there are 

significant constraints that must be 

considered for its use. 

Wildfire management (natural ignitions) for 

resource benefit would be considered for the 

following areas:

 East Pryor ACEC 

 Grove Creek ACEC

 Meeteetse Spires ACEC

 Pryor Foothills RNA ACEC 

 Weatherman Draw ACEC

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

Wildfire management (natural ignitions) for 

resource benefit would not be authorized. 

Wildfire management (natural ignitions) for 

resource benefit would be considered for the 

following areas:

 East Pryor ACEC 

 Grove Creek ACEC

 Meeteetse Spires ACEC

 Pryor Foothills RNA ACEC 

 Weatherman Draw ACEC

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

Prescribed burning would be implemented to 

manipulate vegetation on areas identified for 

treatment in the range, forestry, and wildlife 

programs. 

Prescribed fire would be allowed on up to 5 

percent of BLM administered acres within the 

planning area to achieve measurable 

landscape level objectives from (1) other 

resources, including, but not limited to, 

Prescribed fire would be allowed on up to 5 

percent of the percent of BLM administered 

acres within the planning area to achieve 

measurable landscape level objectives 

from (1) other resources, including, but not 

Same as Alternative C.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-149

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

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Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

forestry, wildlife, range, vegetation, and 

watershed; (2) the reduction of hazardous 

fuels; and (3) the introduction of fire into fireadapted ecosystems.

Prescribed fire would not be allowed in the 

Greater Sage-Grouse Habitat ACEC, Greater

Sage-Grouse PHMAs, or RAs.

limited to, forestry, wildlife, range, 

vegetation, and watershed; (2) the 

reduction of hazardous fuels; and (3) the 

introduction of fire into fire-adapted 

ecosystems.

Within Greater Sage-Grouse PHMAs and 

RAs, only treatments that conserve, 

enhance, or restore Greater Sage-Grouse 

habitat would be allowed. 

Treatment methods, including prescribed 

burning and mechanical treatments would 

be used to eliminate conifer encroachment 

and stimulate vegetative re-growth in 

grassland/shrub land habitats; and to 

reduce fuels, thin under-stories, recycle 

nutrients, and create small openings in 

forested vegetation types. 

A fire risk assessment would be completed 

for implementation of prescribed fire in 

relation to GRSG goals and objectives.

When prescribed fire is used for vegetation 

treatments, the burn plan would clearly 

indicate how COT objectives would be 

addressed and met by use of prescribed 

fire and why alternative techniques for 

vegetation treatment were not selected.

Lands with Wilderness Characteristics

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 6310

and incorporates the findings in the RMP through its Manual 6320. These manuals incorporate principles from BLM guidance (ex: Organic Act directives) and legal rules developed as part of BLM’s 

original wilderness inventories.

Lands with Wilderness Characteristics – Desired Outcomes (Goals and Objectives)

 Protect, preserve, and maintain wilderness characteristics in areas inventoried and found to possess them.

 Lands with wilderness characteristics would be managed to maintain:

o A high degree of naturalness (where lands and resources are affected primarily by the forces of nature and where the imprint of human activity is substantially unnoticeable);

o Outstanding opportunities for solitude (when the sights, sounds, and evidence of other people are rare or infrequent and where visitors can be isolated, alone or secluded from 

others), and

o Outstanding opportunities for primitive and unconfined recreation, where the use of the area would be through non-motorized, non-mechanical means, and where no or minimal

developed recreation facilities are encountered.
Billings and Pompeys Pillar National Monument 

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2-150 Chapter 2: Resource Management Alternatives

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

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Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Lands with Wilderness Characteristics – Management Common to All Alternatives

Conduct active restoration activities to remove unnatural features and rehabilitate unauthorized human disturbances. Remove unauthorized facilities consistent with regulations.

Monitor for development and disturbances, as well as visitor use, to identify and address potential impacts to wilderness character.

Lands with Wilderness Characteristics – Management Actions by Alternative

Manage 1,925 acres outside of the Bighorn

Tack-On and Pryor Mountain WSAs for their 

wilderness characteristics (Map 42).

Manage for wilderness characteristics all 

areas/acres found to contain wilderness 

character (27,507 acres) (Map 43):

 Pryor Mountain Unit Tract 1 – 2,873 acres

 Pryor Mountain Unit Tract 2- 497 acres

 Pryor Mountain Unit Tract 3 - 143 acres

 Pryor Mountain Unit Tract 5 – 512 acres

 Pryor Mountain Unit Tract 6 – 1,074 acres

 Pryor Mountain Unit Tract 7 – 327 acres

 Burnt Timber Unit Tract 1 – 703 acres

 Burnt Timber Unit Tract 2 – 5,375 acres

 Weatherman Draw Unit – 6,033 acres

 Meeteetse Unit Tract 10 – 2,149 acres

 Yellowstone River islands – 126 acres

 Bad Canyon Unit – 2,036 acres

 Bear Canyon Unit – 5,659 acres

Manage for wilderness characteristics the 

following select areas/acres (3,379 acres)

(Map 44):

 Pryor Mountain Unit Tract 2- 497

acres

 Pryor Mountain Unit Tract 3 - 143

acres

 Burnt Timber Unit Tract 1 – 703

acres

 Bad Canyon Unit – 2,036 acres

Do not manage for wilderness 

characteristics the following areas/acres 

(24,128 acres):

 Pryor Mountain Unit Tract 1 – 2,873

acres

 Pryor Mountain Unit Tract 5 – 512

acres

 Pryor Mountain Unit Tract 6 – 1,074

acres

 Pryor Mountain Unit Tract 7 – 327

acres

 Burnt Timber Unit Tract 2 – 5,375

acres

 Meeteetse Unit Tract 10 – 2,149

acre

 Weatherman Draw – 6,033 acres

 Yellowstone River islands – 126

acres

 Bear Canyon Unit – 5,659 acres

Manage for wilderness characteristics the 

following areas/acres immediately adjacent to

WSA (13,653 acres) (Map 45):

 Pryor Mountain Unit Tract 1 – 2,873

acres

 Pryor Mountain Unit Tract 2- 497 acres

 Pryor Mountain Unit Tract 3 - 143 acres

 Pryor Mountain Unit Tract 5 – 512 acres

 Pryor Mountain Unit Tract 6 – 1,074

acres

 Pryor Mountain Unit Tract 7 – 327 acres

 Meeteetse Unit Tract 10 – 2,149 acre

 Burnt Timber Unit Tract 1 – 703 acres

 Burnt Timber Unit Tract 2 – 5,375 acres

Do not manage for wilderness characteristics 

the following areas/acres (13,854 acres):

 Weatherman Draw – 6,033 acres

 Bad Canyon Unit – 2,036 acres

 Yellowstone River islands – 126 acres

 Bear Canyon Unit – 5,659 acres
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-151

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Currently the BiFO has the following 

management prescriptions in place: 

 VRM Class II

 Closed to motorized OHV use

 Closed to oil and gas leasing, exploration

and development (NL)

 Closed to solid mineral leasing

 Closed to disposal of mineral materials

 Closed and recommend for withdrawal

from mineral entry

 Exclusion area for new ROWs

 Closed to permitted commercial and

personal use wood cutting and seed

collection

 Vegetation and fuel treatments using

prescribed fire would be allowed

Lands with wilderness characteristics would be 

managed as follows: 

 VRM Class I

 Closed to motorized OHV use

 Closed to oil and gas leasing, exploration

and development (NL)

 Closed to solid mineral leasing

 Closed to disposal of mineral materials

 Closed and recommend for withdrawal

from mineral entry

 Exclusion area for new ROWs

 Closed to permitted commercial and

personal use wood cutting and seed

collection

 Vegetation and fuel treatments using

prescribed fire would be allowed

 Surface disturbing and disruptive

activities would be allowed only if the

activity does not impair the resource

values and/or wilderness characteristics,

with the exception of emergency

operations and the exercise of valid

existing rights.

 Closed to new structures unrelated to

preserving the wilderness characteristics

 Vegetation treatments to control

expansion of invasive exotic species

would be allowed

Lands with wilderness characteristics would be managed as follows: 

 VRM Class II

 Closed to motorized OHV use, with the exception of the Meeteetse Spires Unit,

which would be limited to authorized motorized OHV use only.

 Closed to oil and gas leasing, exploration and development (NL)

 Closed to solid mineral leasing

 Closed to disposal of mineral materials

 Closed and recommend for withdrawal from mineral entry

 Exclusion area for new ROWs

 Closed to permitted commercial and personal use wood cutting and seed collection

 Vegetation and fuel treatments using prescribed fire would be allowed

 Surface disturbing and disruptive activities would be allowed only if the activity does

not impair the resource values and/or wilderness characteristics, with the exception

of emergency operations and the exercise of valid existing rights.

 Closed to new structures unrelated to preserving the wilderness characteristics

 Vegetation treatments to control expansion of invasive exotic species would be

allowed

Note for Lands with Wilderness Characteristics: 

BiFO interprets the statement from the BiFO 1984 ROD (“managed as WSA”) as the intent for BiFO to administratively apply similar management prescriptions (avoid surface disturbing 

activities and permanent facilities, close the lands to motorized uses, permit grandfathered and prior-existing uses, and in general to continue those land uses which maintain the land suitability 

for potential Wilderness designation by Congress. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-152 Chapter 2: Resource Management Alternatives

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Cave and Karsts Resources

Cave and karsts resources are managed under 43 CFR, part 37, cave management, BLM MOU WO-250-2007-01 , 

The latest policy guidance on Cave Safety Standards and the Federal Cave Resources Protection Act of 1988 in order to protect and maintain their biologic, geologic, mineralogic, paleontological, 

hydrologic, cultural, educational, scientific, and recreational values.

Cave and Karsts Resources – Desired Outcomes (Goals and Objectives)

 Manage all cave resources as mandated by the Federal Cave Resources Protection Act of 1988, the National Environmental Policy Act, and the Endangered Species Act and other applicable

laws and regulations to protect unique, nonrenewable, and fragile biological, geological, hydrological, cultural, paleontological, scientific and recreational values for present and future users.

 Cave and karst resources would be managed to provide opportunities for scientific research, educational study, and recreational experiences which are compatible and consistent with

protection of all biologic and non-biologic resources associated with caves and karst landforms.

Cave and Karsts Resources – Management Common to All Alternatives

Secure, protect, and preserve natural cave features and conditions. 

Geocaching would not be allowed in caves or at cave entrances.

Scientific and research use of caves requires a written proposal explaining the purpose of the research, who would be conducting it, how long it is expected to take, if it would require any 

collection of specimens, and what kind of reporting would be done.

Manage all cave and karst formations in compliance with the National Plan for assisting state, federal agencies, and tribes in managing White-Nose Syndrome in Bats (US Fish and 

Wildlife Service, May 2011). 

Evaluate all known caves in the region to determine if they satisfy the six criteria of significance. The Code of Federal Regulations at 43CFR, Part 37.11 (c) lists the six criteria that are 

used to evaluate cave significance.

Manage recreational use of all known caves under a cave management plan and address: protecting and maintaining cave resources, including wildlife species and habitat in and around 

caves, by interpreting, restricting, and/or prohibiting nonconforming uses; enhancing user experiences and opportunities by managing use at levels compatible with resource carrying 

capacity and protection. Management actions proposed to be implemented also could include installation of cave gates, implementation of a visitor use permit system, the development of 

new visitor public education materials; systematic inventories of cave resources; restoration of damaged habitat; and monitoring of cave conditions and the quality of visitor recreational 

experiences.

Mystery Cave, already designated as a significant cave, located near the Big Horn Tack-On WSA, is recommended for withdrawal from mineral entry and No Lease for oil and gas 

leasing, exploration, and/or development. 

Caves found to be significant would be recommended for withdrawal from mineral entry and managed as No Lease for oil and gas leasing, exploration, and development.

Cave and Karsts Resources – Management Actions by Alternative

No current management decision provided. No surface disturbing or disruptive activities 

within 1⁄2 mile of cave entrances. 

No surface use restrictions. Surface disturbing or disruptive activities 

within 1⁄4 mile of cave entrances may be 

allowed if the activity benefits the desired 

outcome of this resource. 

No current management decision provided Oil and gas leasing, exploration and/or 

development within 1⁄2 mile of cave entrances 

would not be allowed (NSO).

Cave and karst areas would be 

inventoried prior to oil and gas leasing, 

exploration and/or development. An 

approved mitigation plan would be 

Same as C
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-153

Table 2.10 Detailed Table of Alternatives: Physical, Biological, and Cultural / Heritage Resources

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

required to avoid impacts to cave 

resources (CSU).

No current management decision provided Cave and karst resources would be closed to 

locatable minerals and recommended for 

withdrawal from mineral entry; closed to solid 

leasable development and mineral material 

sales.

Inventory of cave and karst areas would 

be required prior to surface-disturbing 

activities. Cave and karst resources would 

be open to mineral development with an 

approved mitigation plan that protects 

resource values. 

Same as C 

No current management decision provided Cave and karst areas would be managed as a 

ROW exclusion area. 

Cave and karst areas would be managed 

as ROW avoidance areas. 

Same as C
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-154 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Energy and Mineral Resources: Solid Leasables (including Coal)

The BLM goals and objectives for coal resources are to make federal solid mineral resources available for exploration and acquisition consistent with other resource goals. In accordance with 

existing laws and regulations, BLM-administered public lands open to solid mineral leasing would be identified. The management actions listed below are the various restrictions and constraints to 

the development of mineral resources. 

Energy and Mineral Resources: Coal – Desired Outcomes (Goals and Objectives)

 Make federal solid mineral resources available for exploration and acquisition consistent with other resource goals.

 Identify the public lands open to solid minerals leasing in accordance with existing laws and regulations (43 CFR 3400 and 3500).

Energy and Mineral Resources: Coal – Management Common to All Alternatives

BLM would consider proposals for developing leasable minerals (coal, phosphate, sodium, potash, sulfur, oil shale, native asphalt, and solid and semi-solid bituminous rock) under the 

administration of the federal government on a case-by-case basis. Site specific environmental analysis would be required to lease these minerals.

BLM would allow exploration and development of solid minerals as authorized under the 1920 and 1947 Mineral Leasing Acts.

Prospecting permits would be available for all land not closed to mineral leasing in conformance with 43 CFR 3500.

Terms and conditions would be applied to mining activities to meet land health standards for uplands, riparian areas and wetlands, water quality, air quality, and native plant and 

animal species (see BMPs in Appendix B and Greater Sage-Grouse Appendix AA).

Surface occupancy and directional drilling are prohibited within the boundaries of existing coal leases. (NSO) Surface occupancy and use is prohibited 

for oil and gas exploration and 

development within the boundaries of 

existing coal leases. (NSO)

No similar action At the time an application for a new coal 

lease or lease modification is submitted to 

the BLM, the BLM would determine 

whether the lease application area is 

"unsuitable" for all or certain coal mining 

methods pursuant to 43 CFR 3461.5. 

PHMA is essential habitat for maintaining 

GRSG for purposes of the suitability 

criteria set forth at 43 CFR 3461.5(o)(1).

Energy and Mineral Resources: Coal – Management Actions by Alternative

The following areas are closed to solid 

leasable mineral development (26,131

acres):

 Pompeys Pillar NM

 Four Dances ACEC 

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

The following areas would be closed to solid 

leasable mineral leasing and development 

(290,048 acres):

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

 Lands with wilderness characteristics

 Bridger Fossil Area ACEC 

The following areas would be closed to 

solid mineral leasing and development 

(264,450 acres):

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA. (If Twin Coulee

WSA is released from further 

consideration, the area may be open for 

solid mineral leasing and development.)

The following areas would be closed to 

solid mineral leasing and development 

(225,655 acres):

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA. (If Twin Coulee

WSA is released from further 

consideration, the area may be open for 

solid mineral leasing and development.)
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-155

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

 Lands with wilderness

characteristics

 Process lease by application (LBAs) 

for new coal leases by applying the

coal screening process to the

application. The coal screening

process results would determine

which lands may be available for 

further consideration for coal

leasing and development.

Appropriate NEPA analysis would

be required prior to leasing. The

existing RMP (BLM 1984) coalscreening management decisions

are current and relevant to the

application area.

 East Pryor ACEC 

 Four Dances ACEC 

 Grove Creek ACEC

 Meeteetse Spires ACEC

 Petroglyph Canyon ACEC 

 Pompeys Pillar NM and ACEC

 Pryor Foothills RNA/ACEC 

 Stark Site ACEC

 Weatherman Draw ACEC

 Nez Perce NHT

 Lewis and Clark NHT

 Cave and karst areas

 Lands with wilderness characteristics

 Lands with wilderness

characteristics

 Bridger Fossil Area ACEC 

 Four Dances ACEC 

 Pompeys Pillar NM and ACEC

 Stark Site ACEC

 Nez Perce NHT

 Lewis and Clark NHT

 Lands with wilderness

characteristics

 Lands with wilderness characteristics

 Bridger Fossil Area ACEC 

 East Pryor ACEC 

 Four Dances ACEC 

 Grove Creek ACEC

 Meeteetse Spires ACEC

 Petroglyph Canyon ACEC 

 Pompeys Pillar NM and ACEC

 Pryor Foothills RNA/ACEC 

 Weatherman Draw ACEC

 Nez Perce NHT

 Lewis and Clark NHT

 Lands with wilderness characteristics

No current management decision 

provided

Within Greater Sage-Grouse PHMAs (including the Alternative B Greater Sage-Grouse Habitat ACEC) and RAs solid mineral leasing

(coal) would only be allowed with the following lease stipulations: 

 Mining may only occur via sub-surface methods

 All mine related appurtenant facilities would be placed outside of the Priority Habitat Areas

No current management decision 

provided

 Remainder of Planning Area: Process lease by application (LBAs) for new coal leases by applying the coal screening process to the

application. The coal screening process results would determine which lands may be available for further consideration for coal

leasing and development. Appropriate NEPA analysis would be required prior to leasing. The existing RMP (BLM 1984) coalscreening management decisions are current and relevant to the application area. (See Appendix M)

Energy and Mineral Resources – Fluid Minerals

The BLM goal for management of oil and gas resources within the Billings Field Office is to provide opportunities for exploration and development of fluid mineral resources on available public 

lands. This includes providing opportunities for exploring, leasing, and developing conventional oil and gas, coal bed natural gas, and geothermal resources while applying the appropriate lease 

stipulations, to varying degrees by alternative as indicated below, and conditions of approval and the project level stage, to mitigate environmental impacts from development and providing 

opportunities for geophysical (e.g. seismic) exploration for oil and gas subject to the appropriate mitigating measures. The BLM identifies opportunities for leasing and development by alternative. 

Actions under “Management Common to All Alternatives” as well as Appendix D sets the framework for the fluid minerals program. 

Energy and Mineral Resources – Fluid Minerals – Desired Outcomes (Goals and Objectives)

 Provide opportunities for exploration and development of fluid mineral resources on available public lands.

 Provide opportunities for exploring, leasing, and developing conventional oil and gas, coal bed natural gas, and geothermal resources while applying the appropriate lease stipulations and

conditions of approval to mitigate environmental impacts from development.

 Provide opportunities for geophysical (e.g. seismic) exploration for oil and gas subject to the appropriate mitigating measures.

Energy and Mineral Resources – Fluid Minerals – Management Common to All Alternatives

Federal oil and gas leasing authority for public lands is found in the Mineral Leasing Act of 1920, as amended; and for acquired lands in the Acquired Lands Leasing Act of 1947, as 

amended. Leasing of federal oil and gas is affected by other acts such as the National Environmental Policy Act of 1969, the National Historic Preservation Act of 1966, FLPMA 

(1976), the Wilderness Act of 1964, the Endangered Species Act of 1973, as amended, and the Federal Onshore Oil and Gas Leasing Reform Act of 1987. Regulations and other 

guidance governing federal oil and gas leasing and lease operations are contained in 43 CFR Group 3100, Onshore Operating Orders, Notices to Lessees, and BLM handbooks 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-156 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

manuals and instruction memorandums. Regulations governing geophysical exploration are found at 43 CFR 3150.

All public lands available for oil and gas leasing would be offered first by competitive bid at an oral auction.

Appropriate stipulations would be applied at the time of leasing. 

Areas where oil and gas development would coexist with other resource uses would be open to leasing under standard lease terms or with added stipulations. Stipulations are a part 

of the lease only when environmental and planning records show the need for them. Three types of stipulations describe how lease rights are modified: no surface occupancy, timing 

limitation (seasonal restriction), and controlled surface use. (For descriptions, see Leasing Process in the Oil and Gas section of Appendix D – Fluid Minerals) Stipulations may be 

changed by application of waivers, exceptions, or modifications. The decision whether to grant waivers, exceptions, or modifications generally occurs during the Application for Permit 

to Drill approval process. If the authorized officer determines the change to be substantial, the preferred alternative would be subject to a 30-day public review period. Waivers are a 

permanent exemption from a lease stipulation. This occurs when the resource does not require the protection of stipulation. Exceptions are granted on a case-by-case basis. Each 

time the lessee applies for an exception, the resource objective of the stipulation must be met. Modifications are fundamental changes to the provisions of a lease stipulation either 

temporarily or for the term of the lease.

An oil and gas lease grants the lessee the right to explore for, extract, remove, and dispose of oil and gas deposits that may be found on the leased lands. The lessee may exercise 

the rights conveyed by the lease, subject to lease terms and any lease stipulations (modifications of the lease), and permit approval requirements.

The terms of existing oil and gas leases cannot be changed by the decisions in this document. When the lease expires, the area would be managed for oil and gas according to the 

decisions reached in this document.

For federal oil and gas where the surface is managed by another federal agency, the BLM would consult with that agency before issuing leases. In areas where oil and gas 

development may conflict with other resources, the areas may be closed to leasing in accordance with decisions made from this document. Regulations at part 43 CFR 3100.0-3(d); 

the Secretary’s general authority to prevent the waste and dissipation of public property; and the Attorney General’s Opinion of April 2, 1941 (Vol. 40 Op. Atty. Gen 41) allow the BLM 

to lease lands that are otherwise unavailable for leasing if oil and gas is being drained from such lands. If the unavailable lands were under the jurisdiction of another agency, leasing 

of such lands would only occur following consultation, and consent if necessary, from the surface managing agency.

On Bureau of Reclamation or Corps of Engineers lands, in addition to the resource specific stipulations under each alternative (e.g., wildlife, recreation); stipulations that are 

recommended by the Bureau of Reclamation or Corps of Engineers would be used (see Oil and Gas section in Appendix D – Fluid Minerals).

Lands unavailable under this RMP (Table 2.8) would be leased only if a state or fee well is proposed or completed within the same spacing unit, or if the lands are within a producing 

unit. These lands would be leased with a no surface occupancy and no subsurface occupancy stipulation with no waiver, modification or exception provisions. There would only be a 

paper transaction with no physical impacts on the unavailable lands. There would be no exploration or development (drilling or production) within the unavailable lands. After issuance 

of a lease, the lease would be committed to a communitization agreement and the United States would then receive revenue in proportion to its acreage interest as it bears to the 

entire acreage interest committed to the agreements.

Additional information can be provided to the lessee in the form of a lease notice. This notice does not place restrictions on lease operation, but does provide information about 

applicable laws and regulations, and the requirements for additional information to be supplied by the lessee.

After lease issuance, the lessee may conduct lease operations with an approved permit. Proposed drilling and associated activities must be approved before beginning operations. 

The operator must file an Application for Permit to Drill or Sundry Notice that must be approved according to (1) lease stipulations, (2) Onshore Oil and Gas Order, and (3) regulations 

and laws. (See Permitting in the Oil and Gas section of Appendix D– Fluid Minerals).

Follow BLM Manual 6330 guidance for mineral leasing in WSAs as appropriate. All WSAs would be closed to new oil and gas leases.

Oil and gas geophysical activity which is administered by the BLM is governed by regulations found at 43 CFR Subparts 3150, 3151 and 3154. Additional guidance is found in BLM 

Manual Section 3150 and Handbook 3150. For additional information on geophysical operations and the BLM’s procedures and regulations see the Geophysical Operations portion of 

the oil and gas section of the Appendix D - Fluid Minerals.

The BLM would review Notices of Intent to Conduct Geophysical Exploration in the planning area and develop appropriate mitigation measures so as not to create undue and 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-157

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

unnecessary degradation. A site-specific environmental analysis would be prepared for each NOI filed.

Lands in the planning area would be available for geothermal leasing, unless located within wilderness or WSAs or in instances where it is determined that issuing the lease would 

cause unnecessary or undue degradation to public lands or resources. Other areas that would be made unavailable are listed in the Record of Decision and RMP Amendments for 

Geothermal Leasing in the Western United States (December, 2008) which is incorporated in this RMP. A site-specific environmental analysis would be prepared as needed should 

interest be expressed in exploring for or developing geothermal resources in the planning area. This analysis would address the application of stipulations and develop any additional 

mitigating measures over and above the lease stipulations required.

Stipulations developed in this document for oil and gas leases would be applied to any geothermal lease issued if appropriate. If geothermal exploration and production activity is 

sufficiently different from oil and gas, the stipulations developed would be modified. 

Priority would be given to leasing and development of fluid mineral resources, including geothermal, outside of PHMA and GHMA. When analyzing leasing and authorizing 

development of fluid mineral resources, including geothermal, in PHMA and GHMA, and subject to applicable stipulations for the conservation of Greater Sage-Grouse, priority would

be given to development in non-habitat areas first and then in the least suitable habitat for Greater Sage-Grouse. The implementation of these priorities would be subject to valid 

existing rights and any applicable law or regulation, including, but not limited to, 30 U.S.C. 226(p) and 43 C.F.R. 3162.3-1(h).

Where a proposed fluid mineral development project on an existing lease could adversely affect GRSG populations or habitat, the BLM would work with the lessees, operators, or 

other project proponents to avoid, reduce and mitigate adverse impacts to the extent compatible with lessees' rights to drill and produce fluid mineral resources. The BLM would work 

with the lessee, operator, or project proponent in developing an APD for the lease to avoid and minimize impacts to sage-grouse or its habitat and would ensure that the best 

information about the GRSG and its habitat informs and helps to guide development of such Federal leases.

Energy and Mineral Resources – Fluid Minerals – Management Common to Action Alternatives

No similar management decision provided Where the federal government owns the 

mineral estate in PHMAs and GHMAs, and 

the surface is in non-federal ownership, 

apply the same stipulations, COAs, and/or 

conservation measures and RDFs applied 

if the mineral estate is developed on BLMadministered lands in that management 

area, to the maximum extent permissible 

under existing authorities, and in 

coordination with the landowner. 

No similar management decision provided Where the federal government owns the 

surface and the mineral estate is in nonfederal ownership in PHMA and GHMA, 

apply appropriate surface use COAs, 

stipulations, and mineral RDFs through 

ROW grants or other surface management 

instruments, to the maximum extent 

permissible under existing authorities, in 

coordination with the mineral estate 

owner/lessee.

Energy and Mineral Resources – Fluid Minerals – Management Actions by Alternative

Oil and Gas

Manage 237,336 acres as open to Manage 41,103 acres as open to leasing, Manage 319,133 acres as open to Manage 44,142 acres as open to leasing, 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-158 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

leasing, subject to standard lease terms 

(Map 50)

subject to standard lease terms (Map 51) leasing, subject to standard lease terms

(Map 52)

subject to standard lease terms (Map 53)

Manage 624,961 acres as open to 

leasing subject to moderate constraints 

(CSU/TL stipulations) (Map 54).

Manage 422,595 acres as open to leasing 

subject to moderate constraints (CSU/TL 

stipulations) (Map 55).

Manage 505,322 acres as open to 

leasing subject to moderate constraints 

(CSU/TL stipulations) (Map 56).

Manage 412,600 acres as open to leasing 

subject to moderate constraints (CSU/TL 

stipulations) (Map 57).

Manage 34,145 acres as open to leasing 

subject to major constraints (NSO) (Map 

54). 

Manage 196,033 acres as open to leasing 

subject to major constraints (NSO) (Map 55). 

Manage 70,980 acres as open to leasing 

subject to major constraints (NSO) (Map 

56). 

Manage 420,126 acres as open to leasing 

subject to major constraints (NSO) (Map 

57). 

Manage 61,100 acres as closed to 

leasing in the following areas (NL) (Map 

54):

Non-Discretionary:

 Pompeys Pillar NM

 Big Horn Tack-on WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

Discretionary:

 Bridger Fossil Area ACEC 

 East Pryor ACEC 

 Four Dances ACEC 

 Meeteetse Spires ACEC (965

acres)

 Petroglyph Canyon ACEC 

 PMWHR

 Lands with wilderness

characteristics

Manage 300,907 acres as closed to leasing 

in the following areas (NL) (Map 55):

Non-Discretionary:

 Pompeys Pillar NM

 Big Horn Tack-on WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

Discretionary:

 Bridger Fossil Area ACEC 

 East Pryor ACEC

 Four Dances ACEC 

 Grove Creek ACEC

 Meeteetse Spires ACEC (965 acres)

 Petroglyph Canyon ACEC 

 Pryor Foothills RNA ACEC 

 Weatherman Draw ACEC (4,986 acres)

 PMWHR

 Steamboat Butte

 Bruder-Janich Site

 Paul Duke Site

 Demi-John Flat NR District

 Bighorn Mouth North Cliffs Rock Art

Site

 Gyp Springs

 Site Hoskins Basin Archaeological

District

 Lands with wilderness characteristics

 State Wildlife Management Areas,

Manage 66,449 acres as closed to 

leasing in the following areas (NL) (Map 

56):

Non-Discretionary:

 Pompeys Pillar NM

 Big Horn Tack-on WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

Discretionary:

 East Pryor ACEC

 Four Dances ACEC 

 Meeteetse Spires ACEC

(965 acres)

 PMWHR

 Lands with wilderness

characteristics

Manage 60,359 acres as closed to leasing 

in the following areas (NL) (Map 57):

Non-Discretionary:

 Pompeys Pillar NM

 Big Horn Tack-on WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

Discretionary:

 Bridger Fossil Area ACEC

 East Pryor ACEC

 Four Dances ACEC 

 Meeteetse Spires ACEC (965 acres)

 Petroglyph Canyon ACEC

 Weatherman Draw ACEC (4,986

acres)

 PMWHR

 Lands with wilderness characteristics
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-159

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Fishing Access sites, and State Parks

 WSR-suitable segments

 Greater Sage-Grouse Habitat ACEC

(Sage –grouse PHMAs)

No similar action Unitization would be required when deemed 

necessary for proper development and 

operation of an area (with strong oversight 

and monitoring) to minimize impacts to 

Greater Sage-Grouse according to the 

Federal Lease Form 3100-11, sections 4 and 

6

No similar action No similar action

No similar action For development within Greater SageGrouse PHMAs, BLM would require a full 

reclamation bond specific to the site. Insure 

bonds are sufficient for costs relative to 

reclamation (Connelly et al. 2000, Hagen et 

al. 2007) that would result in full restoration. 

Base the reclamation costs on the 

assumption that contractors for the BLM 

would perform the work.

No similar action No similar action

Geophysical exploration 

Geophysical exploration would not be 

allowed in the following areas:

 Pompeys Pillar NM & ACEC 

 East Pryor Mountain ACEC 

 Four Dances ACEC 

 Meeteetse Spires ACEC

 Petroglyph Canyon ACEC 

 Stark Site ACEC

 Weatherman Draw ACEC

 Within 1⁄2 mile of bald and golden

eagle nest sites which have been

active within the past 7 years and

within bald and golden eagle

nesting habitat in riparian areas.

 Within 1⁄2 mile of ferruginous hawk

nest sites which have been active

within the past 2 years.

 Within 1 mile of peregrine falcon

Geophysical exploration would not be 

allowed in the following areas:

 Pompeys Pillar NM & ACEC 

 East Pryor ACEC 

 Four Dances ACEC 

 Grove Creek ACEC

 Meeteetse Spires ACEC

 Petroglyph Canyon ACEC 

 Pryor Foothills RNA ACEC 

 Stark Site ACEC

 Weatherman Draw ACEC

 Within 1mile of bald and golden eagle

nest sites which have been active

within the past 7 years and within bald

and golden eagle nesting habitat in

riparian areas.

 Within 1⁄2 mile of ferruginous hawk nest

sites which have been active within the

Geophysical exploration would not be 

allowed in the following areas:

 Pompeys Pillar NM & ACEC 

 East Pryor ACEC 

 Four Dances ACEC 

 Meeteetse Spires ACEC

 Petroglyph Canyon ACEC 

 Stark Site ACEC

 Weatherman Draw ACEC

 Within 1⁄4 mile of bald and golden

eagle nest sites which have been

active within the past 7 years and

within bald and golden eagle

nesting habitat in riparian areas.

 Within 300 feet of ferruginous hawk

nest sites which have been active

within the past 2 years.

 Within 1⁄4 mile of peregrine falcon

Geophysical exploration would not be 

allowed in the following areas:

 Pompeys Pillar NM & ACEC 

 East Pryor ACEC 

 Four Dances ACEC 

 Meeteetse Spires ACEC

 Petroglyph Canyon ACEC 

 Pryor Foothills RNA ACEC 

 Stark Site ACEC

 Weatherman Draw ACEC

 Within 1⁄2 mile of bald and golden

eagle nest sites which have been

active within the past 7 years and

within bald and golden eagle nesting

habitat in riparian areas.

 Within 1⁄2 mile of ferruginous hawk

nest sites which have been active

within the past 2 years.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-160 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

nesting sites.

 Within 1⁄2 mile of raptor nests

(stipulations for peregrine,

ferruginous and bald and golden

eagles noted above) from March 1

to August 1 which have been active

within the last 2 years.

 Bighorn Sheep Habitat

past 2 years.

 Within 1 mile of peregrine falcon

nesting sites.

 Within 1⁄2 mile of raptor nests

(peregrine, ferruginous and bald and

golden eagles noted above) from March

1 to August 1 which have been active

within the last 2 years.

 Bighorn Sheep Habitat

nesting sites.

 Within 1⁄4 mile of raptor nests

(peregrine, ferruginous and bald

and golden eagles noted above) 

which have been active within the

last 2 years if the activity would

result in nest abandonment.

 Bighorn Sheep Habitat

 Within 1 mile of peregrine falcon

nesting sites (distance may be

reduced if natural barriers reduce line

of site).

 Within 1⁄2 mile of raptor nests

(peregrine, ferruginous and bald and

golden eagles noted above) from 

March 1 to August 1 which have been

active within the last 2 years

(distance may be reduced).

 Bighorn Sheep Habitat

Energy and Mineral Resources: Locatable Minerals

The BLM goals and objectives for energy and mineral resources (locatable minerals) is to allow the development of minerals in a manner that prevents degradation of sensitive resources and 

landscapes. The management actions below identify varying degrees of proposed development by identifying public lands that would be unavailable for locatable mineral development.

Energy and Mineral Resources: Locatable Minerals – Desired Outcomes (Goals and Objectives)

 Encourage and facilitate development of locatable minerals in the manner to prevent unnecessary or undue degradation , as defined in 3809.5. Provide land use opportunities contributing to

economic benefits while protecting or minimizing adverse impacts to other resources.

 Identify the public lands open to locatable mineral entry in accordance with existing laws and regulations (43 CFR 3700 and 3800).

Energy and Mineral Resources: Locatable Minerals – Management Common to All Alternatives

Standard management practices in the public land administration of locatable minerals would continue across all alternatives. BLM would coordinate with MDEQ during the review, 

approval, inspection and reclamation of mining operations. At a minimum, conduct an annual compliance inspection on each active notice, and two times per year for Plan of 

Operations. 

Requirements of all state and federal laws would be met in the management of mining operations. 

In cases involving valid mining claims, exploration would occur under all alternatives. Administration of locatable minerals on public lands would continue as required by law and 

regulation (43 CFR 3809) by taking the following steps: 

 Review and process notices to ensure the proposed action does not create unnecessary or undue degradation of the environment.

 Review and process plans of operation to ensure the proposed action does not create unnecessary or undue degradation of the environment.

 Conduct at a minimum, annual compliance inspections on each active notice and plan of operation.

 Allow casual use where work is done by hand and no explosives are used. Refer inquiries to appropriate agencies for further guidance on other permit requirements.

Terms and conditions would be applied to mining activities (within the constraints of the mining law) to meet land health standards for uplands, riparian and wetlands, water quality, air 

quality, and native plant and animal species (see Appendices H and AA for Greater Sage-Grouse specific measures). Note: All withdrawal actions (including mineral withdrawals) are 

processed in the Realty, Cadastral Survey, and Lands program. Restrictions applicable to locatable minerals are limited to the prevention of unnecessary or undue degradation, as 

defined in 43 CFR 3809.5.

Valid, existing mineral rights, within the planning area would not be changed by any decision in this document. None of the alternatives give BLM the discretion to prohibit mineral 

exploration or development on valid leases or mining claims.

Management Actions by Alternative

The following areas are currently closed 

and withdrawn from mineral entry (1,855 

The following areas are currently closed and 

would continue to be recommended for 

The following areas are currently closed 

and would continue to be recommended 

The following areas are currently closed 

and would continue to be recommended 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-161

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

acres)(Map 58): 

 Britton Springs Administrative Site

Crooked Creek Natural Area (WY) 

 Four Dances ACEC 

 Petroglyph Canyon ACEC 

 Pompeys Pillar NM

 Weatherman Draw ACEC (600

acres)

The following areas are closed and 

recommended for withdrawal from 

mineral entry (37,845 acres):

 Meeteetse Spires ACEC

 East Pryor ACEC 

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

 Lands with wilderness

characteristics

All other federal mineral estate within the 

planning area would be available for 

locatable mineral entry and would be 

managed according to policy, as 

described in management common. 

withdrawal from mineral entry (1,855 acres)

(Map 59):

 Britton Springs Administrative Site

Crooked Creek Natural Area (WY) 

 Four Dances ACEC 

 Petroglyph Canyon ACEC 

 Pompeys Pillar NM

 Weatherman Draw ACEC (600 acres)

The following areas would be recommended 

for withdrawal from all locatable mineral entry 

(289,296 acres) 

 Bridger Fossil Area ACEC

 East Pryor ACEC 

 Grove Creek ACEC

 Meeteetse Spires ACEC

 Pompeys Pillar ACEC 

 Pryor Foothills RNA/ACEC 

 Stark Site ACEC

 Weatherman Draw ACEC (4,386 acres)

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

 Greater Sage-Grouse Habitat ACEC 

(Greater Sage-Grouse PHMAs)

 Lands with wilderness characteristics

 Cave and Karst Areas

for withdrawal from mineral entry (1,855 

acres) (Map 60): 

 Britton Springs Administrative Site

Crooked Creek Natural Area (WY) 

 Four Dances ACEC 

 Petroglyph Canyon ACEC 

 Pompeys Pillar NM

 Weatherman Draw ACEC (600

acres)

The following areas would be 

recommended for withdrawal from all 

locatable mineral entry (46,768 acres):

 Bridger Fossil Area ACEC 

 Meeteetse Spires ACEC

 Pompeys Pillar ACEC,

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

 Lands with wilderness

characteristics

for withdrawal from mineral entry (1,855 

acres) (Map 61): 

 Britton Springs Administrative Site

Crooked Creek Natural Area (WY) 

 Four Dances ACEC 

 Petroglyph Canyon ACEC 

 Pompeys Pillar NM

 Weatherman Draw ACEC (600 acres)

The following areas would be 

recommended for withdrawal from all 

locatable mineral entry (60,204 acres):

 Bridger Fossil Area ACEC 

 East Pryor ACEC

 Meeteetse Spires ACEC

 Pompeys Pillar ACEC 

 Pryor Foothills RNA/ACEC 

 Stark Site ACEC

 Weatherman Draw ACEC (4,386

acres)

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

 Lands with wilderness characteristics

No similar action Make any existing claims within the 

withdrawal area subject to validity patent 

exams or buy out. Include claims that have 

been subsequently determined to be null and 

void in the proposed withdrawal.

No similar action No similar action

Energy and Mineral Resources: Mineral Materials (Saleable Minerals)

The BLM goals and objectives for mineral materials would be to allow mineral use while providing protection to sensitive resources and habitat. The BLM would identify areas of BLM-administered 

public lands open to mineral material disposal in accordance with existing laws and regulations. The management actions by alternative below meet this overall goal by achieving varying degrees 

of development and protection while still meeting the goals and objectives. 

Energy and Mineral Resources: Mineral Materials – Desired Outcomes (Goals and Objectives)

 Provide land-use opportunities contributing to economic benefits and meet local infrastructure needs while protecting or minimizing adverse impacts to other resources and resource uses.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-162 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

 Identify the public lands open to minerals materials disposal in accordance with existing laws and regulations (43 CFR 3600).

Energy and Mineral Resources: Mineral Materials – Management Common to All Alternatives

BLM would dispose of saleable minerals on unpatented mining claims only for a public purpose when no reasonable alternative exists. Saleable mineral sites would have an approved 

mining and reclamation plan and an environmental analysis prior to being opened. Mineral material would be sold at a fair market value to the public, but would be free to state, 

county, or other local governments when used for public projects. Mineral material sales would be processed on a case-by-case basis.

The BLM would continue to provide for the exploration and development of mineral materials unless closed.

New mineral material sites would be evaluated on a case-by-case basis. With the exception of lands withdrawn from all mineral entry, the planning area would be available for 

establishment of future sites, pending site-specific analysis. Terms and conditions to protect public land and resource values would be applied on a case-by-case basis.

Energy and Mineral Resources: Mineral Materials – Management Actions by Alternative

The following areas are closed to mineral 

material disposals (44,583 acres) (Map 

62):

 Bridger Fossil Area ACEC 

 East Pryor ACEC 

 Four Dances ACEC

 Meeteetse Spires ACEC

 Pompeys Pillar NM

 Stark Site ACEC

 Weatherman Draw ACEC

 Lands with wilderness

characteristics

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

The following areas are closed to mineral 

material disposals 343,749 acres) (Map 63):

 Bridger Fossil Area ACEC 

 East Pryor ACEC 

 Four Dances ACEC 

 Grove Creek ACEC

 Meeteetse Spires ACEC

 Petroglyph Canyon ACEC 

 Pompeys Pillar NM and ACEC

 Pryor Foothills RNA/ACEC 

 Stark Site ACEC

 Weatherman Draw ACEC

 Lands with wilderness characteristics

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

 Greater Sage-Grouse Habitat ACEC 

(Greater Sage-Grouse PHMAs)

 Greater Sage-Grouse RAs

 Shepherd Ah-Nei Recreation Area

 Acton Recreation Area

The following areas are closed to mineral 

material disposals (261,260 acres) (Map 

64):

 Four Dances ACEC 

 Pompeys Pillar NM and ACEC

 Weatherman Draw ACEC

 Lands with wilderness

characteristics

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA. (If Twin Coulee

WSA is released from further 

consideration, the area may be

open to mineral material disposals.)

 Greater Sage-Grouse PHMAs –

closed to new salable minerals;

existing permits would be renewed

with no increase in the permitted

boundary.

The following areas are closed to mineral 

material disposals (281,597 acres) (Map 

65):

 Four Dances ACEC 

 Petroglyph Canyon ACEC 

 Pompeys Pillar NM and ACEC

 Pryor Foothills RNA/ACEC 

 Stark Site ACEC

 Weatherman Draw ACEC

 Lands with wilderness characteristics

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA. (If Twin Coulee

WSA is released from further 

consideration, the area may be open

to mineral material disposals.)

 Greater Sage-Grouse PHMAs -

closed to new salable minerals;

existing permits would be renewed

with no increase in the permitted

boundary. However, these areas

remain “open” to free use permits and

the expansion of existing active pits,

only if the following criteria are met:

 the activity is within the

Biologically Significant Unit

(BSU) and project area

disturbance cap;

 the activity is subject to the
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-163

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

provisions set forth in the 

mitigation framework [Appendix 

AA, sections E and F];

 all applicable required design

features are applied; and [if

applicable] the activity is

permissible under the specific

sub-regional screening criteria.

 Shepherd Ah-Nei Recreation Area

 Acton Recreation Area

 Asparagus Point

Forestry and Woodland Products

The BLM would manage the public forests and woodlands to maintain and enhance the health, productivity, and biological diversity of these ecosystems. A balance of natural resource benefits 

would be provided to present and future generations. The management of forest and woodland resources would be consistent with the principles of multiple use and sustained yield. The Federal 

Land Policy and Management Act of 1976 (FLPMA) directs the BLM to prepare interdisciplinary land use plans based on the principles of multiple-use and sustained yield. The ecosystem 

management concept is at the core of FLPMA and the basis for all forestry activities in the BLM. All forest management actions would meet or exceed the Montana Streamside Management Zone 

(SMZ) law and Water Quality Best Management Practices for Montana Forests (BMPs) to ensure the protection of soil, water, riparian, and fisheries resources. The BLM’s forestry program 

promotes forest and woodland communities that are healthy, resilient, and vigorous. Forestland mosaics are managed for a diversity of stand structures and species components that complement 

other resource values, including but not limited to recreation, wildlife, rangelands, fisheries, and wood fiber production. 

Forestry and Woodland Products – Desired Outcomes (Goals and Objectives)

 Manage forest resources to provide a sustained flow of local economic benefits and protect non-market economic values, consistent with other resource objectives.

 Provide forest products while maintaining a balance between public demand and the health and productivity of native and desired vegetative communities. Forest product sales include over 

the-counter sales of firewood, Christmas trees or other products, and small amounts of materials removed as a result of other authorizations such as rights-of-way, road use agreements,

grazing leases, or other land uses.

 Provide forest and woodland products including, but not limited to; sawlogs, pulp, post/poles, fuel wood, and biomass on a sustainable basis.

 Manage forests and woodlands to meet or exceed the standards identified in BLM’s Standards for Rangeland Health (Standards 1 and 5)

Forestry and Woodland Products – Management Common to All Alternatives

Commercial harvest of forest products would normally be associated with vegetative restoration (including forest health and fuels treatments) and would be designed to meet 

objectives for forest management, wildlife habitat management, fire hazard reduction, hazard tree removal, special status species management, visuals, recreation, travel 

management, and any other relevant resource concerns.

Provide forest products as practical where forests have been damaged by wildfire and/or insects/disease.

Biomass and small diameter materials associated with forest/fuels treatments would be made available for use.

Forest products would be managed according to sustainability limits and where consistent with other resource management objectives.

Removal of dead or down trees would be allowed for firewood cutting, unless otherwise restricted (e.g., WSAs, ACECs, riparian areas, etc.). Cutting of live trees for firewood for 

personal use or commercial purposes would be authorized on a case by case basis after review and compliance with NEPA. Forest products use would be allowed except where 

prohibited. 

Forestry and Woodland Products – Management Actions by Alternative
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-164 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Accommodate demand for the sale of 

commercial forest products (PSQ appx. 

84 MBF/year).

Meet public demand for commercial forest 

products (PSQ appx. 134 MBF/year).

PSQ values may be adjusted based on 

monitoring evaluations, due to unforeseen 

events such as wildfires, current inventories, 

insect/disease, or climate conditions.

Accommodate the demand for 

commercial forest products (PSQ appx. 

223 MBF/year).

PSQ values may be adjusted based on 

monitoring evaluations, due to 

unforeseen events such as wildfires, 

current inventories, and insect/disease, 

or climate conditions.

Accommodate the demand for commercial 

forest products (PSQ appx. 178

MBF/year).

PSQ values may be adjusted based on 

monitoring evaluations, due to unforeseen 

events such as wildfires, current 

inventories, and insect/disease, or climate 

conditions.

No current management decision 

provided

Restrict permits for other forest products 

(e.g., Christmas trees, fuel wood, juniper, 

wildlings, mushrooms, etc.), when harvest 

would conflict with other resource values. 

Allow unlimited permits/year, unless 

otherwise restricted, for other forest 

products (e.g., Christmas trees, fuel 

wood, juniper, wildings, mushrooms, 

etc.). 

Restrict permits for other forest products 

(e.g., Christmas trees, fuel wood, juniper, 

wildlings, mushrooms, etc.), when harvest 

would conflict with other resource values. 

No current management decision 

provided

Forest treatments would occur in areas 

already accessible by the current road 

system. 

Temporary road construction would follow 

Montana’s Water Quality BMPs for Montana 

Forests and would be decommissioned and 

reclaimed as soon as the project is 

completed. 

New roads would be built where multiple 

entries would be necessary to meet 

objectives. 

New road construction would follow 

Montana’s Water Quality BMPs for 

Montana Forests and would be added to 

the existing travel management plan for 

the given area if travel plan objectives for 

the area are met.

Temporary road construction would 

follow Montana’s Water Quality BMPs for 

Montana forests and be 

decommissioned, with reclamation 

initiated within 1 year of project 

completion.

New roads would be built where multiple 

entries would be necessary to meet 

objectives. 

New road construction would follow 

Montana’s Water Quality BMPs for 

Montana forests. New roads may be left 

open to the public if travel plan objectives 

for the area are met. 

Temporary road construction would follow 

Montana’s Water Quality BMPs for 

Montana forests and be decommissioned, 

with reclamation initiated within 1 year of 

project completion. 

No current management decision 

provided

Where contiguous acres of dead and dying 

forest exceed 1,000 acres, up to 50% of the 

forested area may be treated. 

Harvest treatments within the remaining 

project area may include creation of forest 

openings and/or selective thinning between 

openings.

Salvage may proceed with appropriate 

mitigation measures applied

When salvage is proposed in dead and 

dying forests, contiguous acres of 

undisturbed standing and down woody 

material would be retained on a site 

specific basis, consistent with wildlife 

species, forest health restoration, and 

other resource requirements (e.g., soils, 

riparian, visual resources, etc.). 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-165

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Realty, Cadastral Survey, and Lands: Land Tenure Adjustment and Access

The goals and objectives of land tenure adjustment and access would be to retain public lands with high resource values in public ownership, as well as provide for adjustments in land ownership 

to consolidate public land holdings, acquire lands with high public resource values, and meet public and community needs. All proposed land ownership adjustment actions would be considered at 

project specific environmental reviews. Public access would be maintained or improved through all land ownership adjustments transactions. Section 102(a)(1) of FLPMA provides that “. . . the 

public lands be retained in Federal ownership, unless as a result of the land use planning procedure provided for in this Act, it is determined that disposal of a particular tract would serve the 

national interest.” Lands generally identified for disposal have low or unknown resource values or are isolated or fragmented from other public lands. 

Realty, Cadastral Survey, and Lands: Land Tenure Adjustment and Access – Desired Outcomes (Goals and Objectives)

 Manage the acquisition, disposal, withdrawal, and use of public lands to meet the access needs of internal and external customers and to preserve important resource values.

 Acquire or retain access to public lands to improve management efficiency, to facilitate multiple uses and public enjoyment of BLM public lands in coordination with private landownership,

local, state or federal entities.

 Maintain and/or acquire access across state/private lands to public lands for recreational opportunities and management of public land resources.

 Public access would be maintained or improved through all land ownership adjustment transactions.

Realty, Cadastral Survey, and Lands: Land Tenure Adjustment and Access – Management Common to All Alternatives

Newly acquired lands would be managed for the highest potential purpose and greatest public benefit for which they are acquired and would be managed similar to adjacent and/or 

surrounding lands. 

Lands or interest in lands would be acquired by purchase, exchange, revocation of another agency’s withdrawals, administrative transfer from another agency, cooperative 

agreement, donation, or other authority, and evaluated against the criteria in Appendix J. All land or mineral ownership adjustments would be based on a willing buyer, willing seller 

basis and would be managed as similar lands are under the approved RMP. Administration of other federal lands could occur through revocation of withdrawals, jurisdictional or 

administrative transfer, or agreement.

Evaluate the proposed disposal tracts (Category III) using the land tenure criteria identified in Appendix J.

Parcels of land administered by BLM and discovered through land status updates and corrections would be managed as similar lands are under the approved RMP. 

Lands acquired within or adjoining Congressionally designated areas (NM, NHT, etc.) or within administratively designated special management areas, such as ACECs and SRMAs, 

which have unique or fragile resources, would be managed the same as the special management area.

Acquisition of patented mining claims would be addressed on a case-by-case basis. Patented claims so acquired would be withdrawn from mineral entry.

Use all methods available to acquire access: easements from land or land exchange with willing parties would be the preferred methods of access acquisition.

Retain existing access to BLM-administered lands, or other public lands, in conveyance documents.

Participate and adopt National Historic Trails Land Acquisition Plans

The specifically authorized acreage for land use should be avoided by oil and gas exploration and development activities. All authorized surface land uses are valid claims to prior 

existing rights unless the authorization states otherwise. (LN)

Realty, Cadastral Survey, and Lands: Land Tenure Adjustment and Access – Management Common to Action Alternatives

No current management decision 

provided

Oil and gas exploration, leasing and development would be allowed with a No Surface occupancy stipulation on lands acquired with Land 

and Water Conservation Funds (NSO) 

Retention zones as identified in the 

current plan.

Special Designations (including ACECs and WSAs), archeological sites/historic districts, and lands acquired through Land Water 

Conservation Funds would be managed as Category I – Retention.

No current management decision Oil and gas facilities would not be allowed within 500 feet of human occupied dwellings (LN).
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-166 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

provided

No current management decision provided Lands classified as priority habitat and 

general habitat (or habitat classification 

appropriate for the sub-region) for Greater 

Sage-Grouse would be retained in federal 

management unless: (1) the agency can 

demonstrate that disposal of the lands 

would provide a net conservation gain to 

the Greater Sage-Grouse or (2) the agency 

can demonstrate that the disposal of the 

lands would have no direct or indirect 

adverse impact on conservation of the 

Greater Sage-Grouse.

Surface occupancy and use is prohibited 

300 feet from occupied buildings

Surface occupancy and use is prohibited for oil and gas exploration and development within and 500 feet from unincorporated towns or 

human occupied residential structures (structures that are regularly occupied by persons at least 20 hours per week) (NSO).

Consider land ownership adjustments 

according to the established criteria and 

zones.

Land ownership adjustments would be considered through site-specific analysis, based on retention, acquisition and disposal criteria

(Appendix J). 

Establish three (3) adjustment categories based on BLM land tenure adjustment classes:

 Category I – Retention: Lands managed in Category I – Retention would include all lands with Special Designations (including

ACECs, WSAs, National Historic Trails, National Monuments, etc.), lands with wilderness characteristics, National Register listed

archeological/historic sites/districts, and lands acquired through LWCF. Category I lands would not be transferred from BLM 

management by any method for the life of the plan.

 Category II- Retention/Limited Land Ownership Adjustment: Public lands within Category II would be considered for limited land

ownership adjustments; however lands in Category II would not be available for sale under section 203 of FLPMA. 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 sales): 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 by

alternative in Appendix J. 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.

Realty, Cadastral Survey, and Lands: Land Tenure Adjustment and Access – Management Actions by Alternative

Manage 26,616 acres for Retention Manage 68,300 acres in Category I –

Retention

Manage 108,184 acres in Category I –

Retention 

Manage 83,507 acres in Category I –

Retention 

No current management decision 

provided

Manage 365,804 acres in Category II -

Retention/Limited Land Ownership 

Adjustment (no land disposals through direct 

sale). Land exchanges would be considered.

Manage 321,747 acres in Category II -

Retention/Limited Land Ownership 

Adjustment (no land disposals through 

direct sale). Land exchanges would be 

considered. 

Manage 353,829 acres in Category II -

Retention/Limited Land Ownership 

Adjustment (no land disposals through 

direct sale). Land exchanges would be 

considered.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-167

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Manage 7,529 acres for Disposal, and 

2,088 acres were identified for further 

study. (Map 171)

Manage 50 acres in Category III – Disposal 

(land ownership adjustments, including direct 

sale). (Map 172)

Manage 4,223 acres in Category III –

Disposal (land ownership adjustments, 

including direct sale or land exchanges).

(Map 173)

Manage 264.4 acres in Category III –

Disposal (land ownership adjustments, 

including direct sale or land exchanges).

(Map 174)

Consider applications for Recreation and 

Public Purposes (R&PP) Act transfers 

and airport grants on a case-by-case 

basis.

Consider applications for R&PP 

leases/patents and airport grants only in 

Category III.

Consider applications for R&PP 

leases/patent and airport grants in all 

Categories II and III. 

Consider applications for R&PP 

leases/patents and airport grants only in 

Category II and Category III.

Make lands available for state grants, 

agricultural entries, and Indian allotments 

on a case-by-case basis. 

BLM public lands would be available for state indemnity grants, as legally required in Categories II and III lands. 

There are no lands in the Billings Field Office that are suitable for agricultural entry or Indian allotments. This is based on a combination 

of poor soil types, a lack of water, available water rights, and rugged topography.

Realty, Cadastral Survey, and Lands: Rights-of-Way, Leases, and Permits

The BLM goals for the management of Rights-of-Way (ROW), leases, and permits within the Billings Field Office are to protect resources while meeting transportation and ROW needs in the 

planning area. To accomplish this, the Billings Field Office proposes to implement a variety of management activities that allow to various land actions or authorizations, with a range of restrictions 

based on resource concerns to help meet the goals and objectives of other resources. Actions specific to lands ROWs, leases and permits are listed below, by alternative and are primarily focused 

categorizing ROWs in areas as exclusion areas and avoidance areas, as well as how and under what conditions land use authorizations may occur within the decision area. 

Realty, Cadastral Survey, and Lands: Rights-of-Way, Leases, and Permits – Desired Outcomes (Goals and Objectives)

 Manage public lands to meet transportation and rights-of-way (ROW) needs while protecting resources.

 Address the needs of industry, utilities, the public, or government entities for land use authorizations while minimizing impacts to other resource values.

 Maintain availability of public lands to meet the habitation, cultivation, trade, mineral development, recreation, and manufacturing needs of external customers and the general public.

Realty, Cadastral Survey, and Lands: Rights-of-Way, Leases, and Permits – Management Common to All Alternatives

Analyze requests for land use authorizations and apply mitigation measures as appropriate (Appendix B). 

Land use authorizations would not be issued for uses that involve the disposal or storage of materials which would contaminate the land (hazardous waste disposal sites, landfills, rifle 

ranges, etc.). 

New ROW facilities would be located within or adjacent to existing rights-of-way to the extent possible. 

New communication site users would be encouraged to locate within existing communication site buildings or within boundaries defined by communication site plans. 

Reclamation of sites would be required where documented resource damage has occurred from unauthorized use. 

ROW exclusion or avoidance areas would be subject to valid existing rights.

Terms and conditions for ROWs, corridors and development areas would incorporate best management practices.

Issues in connection with RS2477 roads would be subject to the current guidance 

If a BLM ROW, lease, permit, conservation easement, or R&PP lease or patent occurs on an oil and gas lease, the lessee would be notified 

The following five ROW areas are designated for communication sites: Wall Creek, north of Pompeys Pillar, Bridger, Tin Can Hill, and Four Dances Natural Area ACEC. Applicants 

are encouraged to utilize existing communication site facilities to minimize disturbance.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-168 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Upon project completion, roads used for commercial access on public lands would be reclaimed, unless, based on site-specific analysis, the route provides specific benefits for public 

access and does not contribute to resource conflicts.

Pursue reciprocal rights for public access when granting a BLM right-of-way, as appropriate.

Overhead powerlines, where authorized, would follow the recommendations in Avian Protection on Powerlines, State of the Art in 2006 (APLIC). Power poles and other tall structures 

would be designed to prevent raptors from perching on the poles and reflectors attached.

No current management decision 

provided

Geophysical carbon sequestration would be allowed in the planning area in accordance with the goals and objectives for resources in the 

RMP. The BLM would comply with policy for issuing ROWs or leases for the purpose of geophysical carbon sequestration.

GRSG PHMAs open for ROWs. Exclusion area for major and minor ROWs, 

except for valid existing rights.

Avoidance area for major and minor 

ROWs. 

However ROWs would only be allowed in 

GRSG PHMAs where habitat functionality 

would be maintained.

Same as C

GRSG RAs open for ROWs Avoidance area for major and minor ROWs. Avoidance area for major and minor 

ROWs. 

However ROWs would only be allowed in

GRSG RAs where habitat functionality 

would be maintained.

Same as C

GRSG GHMAs open for ROWs GRSG GHMAs would be avoidance areas for 

major and minor ROWs.

ROWs would be allowed .

Utilities and similar facilities would be 

located adjacent to other facilities where 

practical and only when habitat can be 

maintained.

GRSG GHMAs would be avoidance areas 

for major ROWs. 

GRSG GHMAs would be open to minor 

ROWs. 

Utilities and similar facilities would be 

located adjacent to other facilities where 

practical and only when habitat can be 

maintained.

Low voltage powerlines would be buried 

if feasible.

BLM would require powerlines 69kV and less 

in size to be buried if feasible. 

BLM would require powerlines 69kV and 

less in size to be authorized in a manner 

that ensures habitat is maintained (e.g. 

burying, perch, collision and electrocution

prevention measures, or line location).

BLM would require powerlines 69kV and 

less in size to be buried if feasible. BLM 

would require powerlines 69kV and less in 

size to be authorized in a manner that 

ensures habitat is maintained (e.g. burying, 

perch, collision, and electrocution 

prevention measures, or line location).

Corridors

A multi-modal (pipeline and electrical transmission) Section 368 corridor (identified as Segment 79-216) would continue to be a designated corridor and is 5.2 miles in length, 3,500 

feet in total width, located east of Highway 310 in Carbon County (Map 76).

No current management decision Silver Tip Road would not be designated a Silver Tip Road in Carbon County would 

be designated as a ROW corridor (1 mile 

Silver Tip Road in Carbon County would be 

designated as a ROW corridor (1,750 feet 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-169

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

provided ROW corridor (Map 76). on either side of the center line of Silver 

Tip Road) (Map 77). 

on either side of the center line of Silver 

Tip Road). This corridor would have a total 

width of 3,500 feet and 6 miles in length on 

public land, with the exception of the 

portion of this corridor occurring in the Elk 

Basin GRSG Restoration Area which 

would be 1,320 feet on either side of the 

center line of Silver Tip Road (total width of 

2,640 feet) (Map 78).

No current management decision 

provided.

Applicants would be encouraged, but not 

required, to use designated corridors; ROW 

requests would be considered on a case by 

case basis. 

Applicants would be encouraged, but not 

required, to use designated corridors; 

ROW requests would be considered on a 

case by case basis. ROW application 

processing time would be expedited by 

the use of a designated corridor. 

Same as C.

ROW Exclusion Areas 

ROW exclusion areas include (44,014

acres) (Map 72):

The following are ROW exclusion areas:

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

 Bridger Fossil Area ACEC 

 East Pryor ACEC 

 Meeteetse Spires ACEC

 Petroglyph Canyon

 Pompeys Pillar ACEC – Historic

Zone except those necessary to

service the site facilities.

 Stark Site ACEC

 Weatherman Draw ACEC

 Lands with wilderness

characteristics

ROW Exclusion Areas: (211,384 acres) and 

include the following areas (Map 73):

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

 In addition, if not designated by

Congress as Wilderness, the WSAs

would continue to be managed as ROW

exclusion areas.

 Bridger Fossil Area ACEC 

 Castle Butte ACEC 

 East Pryor ACEC 

 Grove Creek ACEC

 Meeteetse Spires ACEC

 Petroglyph Canyon

 Pompeys Pillar ACEC – Zone A and B,

except those necessary to service the

site facilities.

 Pryor Foothills RNA ACEC

 Stark Site ACEC

 Portion of Weatherman Draw ACEC 

(original ACEC and acquisition).

ROW Exclusion Areas: (39,491 acres) 

and include the following areas (Map 74):

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

 Meeteetse Spires ACEC

 Petroglyph Canyon

 Pompeys Pillar ACEC – Zone A and

B except those necessary to service

the site facilities

 Portion of Weatherman Draw ACEC 

(original ACEC and acquisition).

 Lands with wilderness

characteristics

ROW Exclusion Areas: (48,258 acres) and 

include the following areas (Map 75):

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA.

 In addition, if not designated by

Congress as Wilderness, the WSAs

would continue to be managed as

ROW exclusion areas.

 Bridger Fossil Area ACEC 

 Meeteetse Spires ACEC

 Petroglyph Canyon

 Pompeys Pillar ACEC – Zone A and

B, except those necessary to service

the site facilities

 Portion of Weatherman Draw ACEC 

(original ACEC and acquisition).

 Lands with wilderness characteristics
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-170 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

 Lands with wilderness characteristics

 Cave and karst areas would be

managed as a ROW exclusion area.

 Greater Sage-Grouse Habitat ACEC

(Greater Sage-Grouse PHMAs) would

be ROW exclusion areas

ROW Avoidance Areas 

ROW avoidance areas include 24,203 

acres (Map 68):

 Castle Butte ACEC

 Four Dances ACEC

 Pompeys Pillar ACEC (Historicdeveloped and General

Management Zones (avoidance

area and restricts ROW to a 500’

wide path paralleling the southern

boundary of the public lands along

Highway 312)

 Asparagus Point, Steamboat Butte

 Red Dome, Red Valley, Portion of

Acton, Portion of Shepherd Ah-Nei,

 Bad Canyon, East and Red Pryor

Mountains

 Hoskins Basin Archeological

District, Demi-John Flat

Archeological District, Beartooth

Mountain Front (2 mile strip

bordering the eastern boundary of

the Custer National Forest)

ROW avoidance areas would include 

185,607 acres (Map 69):

 Four Dances ACEC,

 Pompeys Pillar ACEC (Zone C-restricts

ROW to a 500’ wide path paralleling the

southern boundary of the public lands

along Highway 312) 

 L&C NHT and NP NHT

 Asparagus Point, Steamboat Butte,

Portion of Acton, Portion of Shepherd

Ah-Nei, Bad Canyon, East and Red

Pryor Mountains

 Hoskins Basin Archeological District,

Demi-John Flat Archeological District,

Beartooth Mountain Front (2 mile strip

bordering the eastern boundary of the

Custer National Forest)

 WSR eligible segments

 Big Horn Sheep Winter Range

 Big Game Winter Range

 Greater Sage-Grouse RAs

 Greater Sage-Grouse GHMAs

ROW avoidance areas would include 

355,601 acres (Map 70):

 Bridger Fossil Area ACEC

 Castle Butte ACEC

 East Pryor ACEC

 Four Dances ACEC

 Grove Creek ACEC

 Pompeys Pillar ACEC (Zone C -

restricts ROW to a 500’ wide path

paralleling the southern boundary of

the public lands along Highway

312) 

 Pryor Foothills RNA/ACEC

 Stark Site ACEC

 Weatherman Draw (expansion

area)

 Cave and karst areas

 L&C NHT and NP NHT

 Asparagus Point, Steamboat Butte,

Portion of Acton, Portion of

Shepherd Ah-Nei, Bad Canyon,

East and Red Pryor Mountains,

 Hoskins Basin Archeological

District, Demi-John Flat

Archeological District, Beartooth

Mountain Front (2 mile strip

bordering the eastern boundary of

the Custer National Forest)

 WSR eligible segments

 Big Horn Sheep Winter Range

 Big Game Winter Range

 Greater Sage-Grouse PHMAs and

ROW avoidance areas would include 

378,958 acres (Map 71):

 Castle Butte ACEC

 East Pryor ACEC

 Four Dances ACEC

 Grove Creek ACEC Pompeys Pillar 

ACEC (Zone C - restricts ROW to a

500’ wide path paralleling the

southern boundary of the public lands

along Highway 312) 

 Pryor Foothills RNA/ACEC

 Stark Site ACEC Weatherman Draw 

(expansion area)

 Cave and karst areas would be

managed as ROW avoidance areas.

 L&CNHT and NPNHT corridors would

managed as ROW avoidance areas

 Asparagus Point, Steamboat Butte,

portion of Acton, portion of Shepherd

Ah-Nei, Bad Canyon, East and Red

Pryor Mountains

 Hoskins Basin Archeological District,

Demi-John Flat Archeological District,

Beartooth Mountain Front (2 mile

strip bordering the eastern boundary

of the Custer National Forest)

 WSR eligible segments

 Big Horn Sheep Winter Range

 Big Game Winter Range

 Greater Sage-Grouse GHMA

 Greater Sage-Grouse PHMAs and

RAs would remain avoidance areas.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-171

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

RAs would remain avoidance areas. 

However ROWs would only be 

allowed in Greater Sage-Grouse 

PHMAs and RAs where habitat 

functionality would be maintained.

However ROWs would only be

allowed in Greater Sage-Grouse 

PHMAs and RAs where habitat 

functionality would be maintained. 

Realty, Cadastral Survey, and Lands: Withdrawals

The BLM goals for the management of Withdrawals within the Billings Field Office are to protect significant resources through mineral withdrawal actions that accomplish the required purposes of 

the withdrawal. To accomplish this, the Billings Field Office has proposed, by alternative, withdrawal actions to protect the identified resource values. The BLM would follow departmental and 

bureau policies in consideration of any new proposed withdrawals. Lands recommended for closure to the mining laws would be the minimum area required for the intended use. 

Realty, Cadastral Survey, and Lands: Withdrawals – Desired Outcomes (Goals and Objectives)

 Protect significant resources or significant government investments.

 Use withdrawal actions with the least restrictive measures and minimum size necessary to accomplish the required purposes of the withdrawal.

Realty, Cadastral Survey, and Lands: Withdrawals – Management Common to All Alternatives

Review withdrawals two (2) years prior to termination either to extend, modify, or revoke. If withdrawals are no longer needed, in whole or in part, for the intended purpose for which 

they were created, the withdrawal would be revoked or modified.

Consider other agency requests for new withdrawals, relinquishments, extensions or modifications on a case-by-case basis with consideration given to determining if the lands would 

be suitable for return to BLM public domain.

All Classification and Multiple Use classifications in the planning area have been terminated. 

Withdrawal proposals would be evaluated at the project level and would not be approved unless the land management is consistent with maintaining and protecting BLM resource 

values (see BMP (Appendix B) and GRSG (Appendix AA) Appendices as appropriate).

The following areas are currently closed 

and withdrawn from mineral entry (1,855 

acres): 

 Britton Springs Administrative Site

Crooked Creek Natural Area (WY) 

 Four Dances ACEC 

 Petroglyph Canyon ACEC 

 Pompeys Pillar NM

 Weatherman Draw ACEC (600

acres)

The following areas are closed and 

recommended for withdrawal from 

mineral entry (37,845 acres):

 Meeteetse Spires ACEC

 East Pryor ACEC 

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

The following areas are currently closed and 

would continue to be recommended for 

withdrawal from mineral entry (1,855 acres):

 Britton Springs Administrative Site

Crooked Creek Natural Area (WY) 

 Four Dances ACEC 

 Petroglyph Canyon ACEC 

 Pompeys Pillar NM

 Weatherman Draw ACEC (600 acres)

The following areas would be closed and 

recommended for withdrawal from mineral 

entry (289,296 acres) 

 Bridger Fossil Area ACEC 

 East Pryor ACEC 

 Grove Creek ACEC

 Meeteetse Spires ACEC

 Pompeys Pillar ACEC 

 Pryor Foothills RNA/ACEC 

 Stark Site ACEC

The following areas are currently closed 

and would continue to be recommended 

for withdrawal from mineral entry (1,855 

acres): 

 Britton Springs Administrative Site

Crooked Creek Natural Area (WY) 

 Four Dances ACEC 

 Petroglyph Canyon ACEC 

 Pompeys Pillar NM

 Weatherman Draw ACEC (600

acres)

The following areas would be closed and 

recommended for withdrawal from 

mineral entry (46,768 acres):

 Bridger Fossil Area ACEC 

 Meeteetse Spires ACEC

 Pompeys Pillar ACEC,

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

The following areas are currently closed 

and would continue to be recommended 

for withdrawal from mineral entry (1,855 

acres):

 Britton Springs Administrative Site

Crooked Creek Natural Area (WY) 

 Four Dances ACEC 

 Petroglyph Canyon ACEC 

 Pompeys Pillar NM

 Weatherman Draw ACEC (600 acres)

The following areas would be closed and 

recommended for withdrawal from mineral 

entry (60,204 acres):

 Bridger Fossil Area ACEC 

 East Pryor ACEC

 Meeteetse Spires ACEC

 Pompeys Pillar ACEC 

 Pryor Foothills RNA/ACEC 

 Stark Site ACEC
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-172 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

 Lands with wilderness

characteristics

All other federal mineral estate within the 

planning area would be available for 

locatable mineral entry and would be 

managed according to policy, as 

described in management common. 

 Weatherman Draw ACEC (4,386 acres)

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

 Greater Sage-Grouse PHMAs

 Lands with wilderness characteristics

 Cave and Karst Areas

 Pryor Mountain WSA

 Twin Coulee WSA

 Lands with wilderness

characteristics

 Weatherman Draw ACEC (4,386

acres)

 Big Horn Tack-On WSA

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

 Lands with wilderness characteristics

Livestock Grazing

The Bureau of Land Management livestock grazing program is mandated by law to provide opportunities for grazing in a manner that maintains and/or improves rangeland health. 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.). Livestock grazing management actions that are common to all alternatives focus primarily on meeting the Standards for Rangeland Heath, as outlined in 

Appendix I. In order to reach the goal of healthy rangelands, the bureau must maintain existing desirable rangeland conditions or improve rangeland health utilizing the Guidelines for Grazing 

Management, also outlined in Appendix I. It is critical that grazing management actions are monitored and evaluated to determine if rangeland and riparian conditions are improving, or at minimum, 

being maintained. Prescribed grazing strategies and systems as well as natural and mechanical vegetation improvements also maintain the number of Animal Unit Months (AUMs) available for 

livestock grazing that support and sustain local ranching communities. The integration of livestock grazing with other multiple-use needs and objectives is also essential. When issuing or 

transferring grazing authorizations a thorough review of these actions is conducted. 

Livestock Grazing – Desired Outcomes (Goals and Objectives)

 Provide opportunities for livestock grazing as a part of multiple-use in a manner that meets and/or exceeds rangeland health standards.

 Maintain existing desirable (allotment categorization) rangeland conditions or improve rangeland health utilizing best grazing management practices.

 Monitor and evaluate rangeland health to determine appropriate management actions.

 Integrate livestock use and associated management practices with other multiple-use needs and objectives to maintain, protect, and improve rangeland health.

Livestock Grazing – Management Common to All Alternatives

Monitor and evaluate grazing allotments to maintain or improve rangeland productivity.

AUM levels would be sustained on an allotment-by-allotment basis for livestock grazing, providing Montana Standards for Healthy Rangelands are being met.

Adjust permit terms and conditions (e.g. increased/decreased permitted use, season of use, and kind and class of livestock) when grazing permits are issued or as otherwise deemed 

necessary by site specific evaluation of monitoring data and environmental analysis.

Use livestock grazing to enhance ecosystem health, wildlife habitat, or mitigate resource issues (e.g., noxious/invasive weed control and hazardous fuel reduction) where supported 

by site-specific environmental analysis.

During periods of drought, adjust livestock numbers commensurate with the needs of other resources in the area (riparian, wildlife, etc.)

Exclude livestock grazing from small areas (such as springs) within allotments that cannot meet Rangeland Health Standards with livestock grazing.

Site-specific management actions that protect riparian areas would be addressed at the project level.

Grazing treatments and systems would be adaptive to new research, science and methodologies.

In areas of resource conflicts, installation of structural range improvements would only be considered where grazing practices (change in season of use, reduction of AUMs, increased 

rest, etc.) are unable to resolve the resource concern. Structural range improvements could be considered where necessary to facilitate the change in grazing management practices. 

Existing range improvements would be evaluated and modified to address impacts on wildlife populations (e.g. Greater Sage-Grouse/fence conflicts). 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-173

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Newly acquired lands would be evaluated for livestock grazing during the acquisition process, and subject to 43CFR 4110.1-1.

Livestock Grazing – Management Common to Action Alternatives

No similar action All allotments wholly located in Greater Sage-Grouse PHMAs would be considered for retirement, where the base property owner 

relinquishes their preference.

No similar action Site specific Greater Sage-Grouse habitat 

and management objectives would be 

developed for BLM land within Greater 

Sage-Grouse Priority Habitat Management 

Areas. These objectives would be 

incorporated into the respective allotment 

management plans or livestock grazing 

permits as appropriate.

No similar action The NEPA analysis for renewals and 

modifications of livestock grazing 

permits/leases that include lands within 

PHMAs would include specific 

management thresholds based on GRSG 

Habitat Objectives Table (Table 2.3) and 

Land Health Standards (43 CFR 4180.2) 

and one or more defined responses that 

would allow the authorizing officer to make 

adjustments to livestock grazing that have 

already been subject to NEPA analysis.

No similar action  The BLM would prioritize (1) the

review of grazing permits/leases, in

particular to determine if modification

is necessary prior to renewal, and (2)

the processing of grazing

permits/leases in PHMAs. In setting

workload priorities, precedence would

be given to existing permits/leases in

these areas not meeting Land Health

Standards, with focus on those

containing riparian areas, including

wet meadows. The BLM may use

other criteria for prioritization to

respond to urgent natural resource

concerns (ex., fire) and legal

obligations.

 The NEPA analysis for renewals and

modifications of livestock grazing
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-174 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

permits/leases that include lands 

within PHMAs would include specific 

management thresholds based on 

GRSG Habitat Objectives Table 

(Table 2.3) and Land Health 

Standards (43 CFR 4180.2), 

ecological site potential, and one or 

more defined responses that would

allow the authorizing officer to make 

adjustments to livestock grazing that 

have already been subjected to NEPA 

analysis. 

 Allotments within PHMAs, and

focusing on those containing riparian

areas, including wet meadows, would

be prioritized for field checks to help

ensure compliance with the terms and

conditions of the grazing permits.

Field checks could include monitoring

for actual use, utilization, and use

supervision.

 At the time a permittee or lessee

voluntarily relinquishes a permit or 

lease, the BLM would consider 

whether the public lands where that

permitted use was authorized should

remain available for livestock grazing

or be used for other resource

management objectives, such as

reserve common allotments or fire

breaks.

Livestock Grazing – Management Actions by Alternative

Areas open to Grazing, AUM Allocation, and Monitoring

Total Acres Available to livestock grazing: 434,154

Isolated parcels not included within grazing allotments: 9,522 acres

Total acres permitted for livestock 

grazing: 387,057

Total acres permitted for livestock grazing: 

386,092

Total acres permitted for livestock 

grazing: 386,822

Total acres permitted for livestock grazing: 

387,057

Total acres closed to permitted livestock 

use for the life of the plan: 37,408 acres 

Areas specifically closed to livestock 

grazing include: 

Total acres closed to permitted livestock use 

for the life of the plan: 38,373 acres

Areas specifically closed to livestock grazing 

include: 

Total acres closed to permitted livestock 

use for the life of the plan: 28,622 acres 

Areas specifically closed to livestock 

grazing include: 

Total acres closed to permitted livestock 

use for the life of the plan: 28,387 acres

Areas specifically closed to livestock 

grazing include: 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-175

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

 Pryor Mountain Herd Area: 28,387

acres

 Pompeys Pillar ACEC: 432 acres

 Bundy Island: 78 acres

 Sundance Lodge Recreation Area:

387 acres

 Four Dances Natural Area ACEC:

784 acres

 Asparagus Point: +/- 26 acres (that

portion north of the Musselshell

River and accessible from State

Hwy 12)

 Meeteetse Spires ACEC: 558 acre

acquisition area

 Twin Coulee WSA: 6,756 acres

 Pryor Mountain Herd Area: 28,387

acres

 Pompeys Pillar ACEC: 432 acres

 Bundy Island: 78 acres

 Sundance Lodge Recreation Area: 387

acres

 Four Dances Natural Area ACEC: 784

acres

 Asparagus Point: +/- 26 acres (that

portion north of the Musselshell River 

and accessible from State Hwy 12)

 Meeteetse Spires ACEC: 1,523 acres

 Twin Coulee WSA: 6,756 acres

 Pryor Mountain Herd Area: 28,622

acres (Bad Pass Allotment (149

acres) is within the formal boundary

of the Pryor Mountain Herd Area

boundary and would be open to

trailing and therefore open to

grazing.)

 Pryor Mountain Herd Area: 28,387

acres

Total acres available for prescriptive use 

of livestock grazing: 9,021 acres

The following areas could be open to 

livestock grazing on a temporary basis for 

the treatment of noxious weeds or as a 

prescriptive treatment (targeted grazing) 

to meet site specific vegetation or other 

resource management goals:

 Pompeys Pillar ACEC: 432 acres

 Bundy Island: 78 acres

 Sundance Lodge Recreation Area:

387 acres

 Four Dances Natural Area ACEC:

784 acres

 Asparagus Point: +/- 26 acres (that

portion north of the Musselshell

River and accessible from State

Hwy 12)

 Meeteetse Spires ACEC: 558

acres

 Twin Coulee WSA: 6,756 acres

Same as C

Current available AUMs are 54,873. Maintain current available AUMs (up to 

54,873). Adjustments to permitted use would 

Maintain current available AUMs (up to 

54,873). Implement range improvements 

Same as B
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-176 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

be authorized, based on allotment specific 

standards and conformance reviews.

that meet forage demand.

Current suspended non-use allocation -

7,746 AUMs.

Maintain current AUMs in suspense (7,746) 

for watershed health or wildlife habitat.

Make current AUMs suspended non-use 

(7,746) available for livestock grazing 

use.

Consider adjusting (increase or decrease) 

suspended AUMs, based on monitoring 

data and range conditions. 

Maintain existing allotment management 

categories (see Appendix S)

Designate those allotments within or 

containing Greater Sage-Grouse PHMAs as 

management category I. All other allotments 

would maintain their existing designation and 

would be updated as resource conditions 

change

Same as A Same as B 

Monitor and evaluate the appropriate 

management actions (grazing systems 

and range improvements) to ensure 

range condition and objectives are met 

on I allotments and maintained on M and 

C allotment.

Priority Allotments for monitoring and 

evaluation would be allotments which:

 Are not meeting standards for 

rangeland health

 Contain special status species habitat

(including Greater Sage-Grouse

PHMAs / RAs)

 Contain impaired streams

 Contain non-functional or functioning at

risk downward trend riparian areas.

 Contain invasive plant species.

Same as A Priority Allotments for monitoring and 

evaluation would be allotments which:

 Are not meeting standards for 

rangeland health

 Contain special status species habitat

(including Greater Sage-Grouse

PHMAs / RAs)

 Contain impaired streams

 Contain non-functional or functioning

at risk downward trend riparian areas.

 Contain invasive plant species.

 Allotments that have established and

implemented management plans

during the life of the plan.

Riparian areas are assessed every 10 

years (permit renewal). 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.

Assess PFC on all fish bearing streams on a 

3 year rotation (approx. 46 miles). 

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.

Same as A Assess PFC on all fish bearing streams on 

a 3 year rotation, with the exception of 

areas that are free of existing or potential 

threats (approx. 30 miles). (ex: Piney and 

Crooked Creek are the current exceptions).

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.

No current management decision 

provided.

No supplement or salt placement within 1⁄2 

mile of known special status plant sites.

No supplement or salt placement within 

1⁄4 mile of known special status plant 

sites.

No supplement or salt placement within 1⁄4 

mile of known special status plant sites, 

unless livestock is otherwise excluded 

(fence or barrier).
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-177

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Permit and Lease Renewal and Relinquishments

No current management decision 

provided 

Grazing permits/leases would be transferred 

or renewed for C category grazing allotments 

where the new grazing authorization:

(1) Contains the same mandatory terms and 

conditions (kind of livestock, the active use 

previously authorized is not exceeded, and 

grazing does not occur more than 14 days 

earlier or later than as specified on the 

previous permit/lease). 

(2) Have evaluation reports documenting that 

they are meeting land health standards. A 

screening criteria checklist (Appendix L) 

would be reviewed prior to renewal. If the 

answer to each of the questions is “NO”, the 

renewal is within scope and NEPA 

compliance can be achieved by preparing a 

Documentation of NEPA Adequacy (DNA) 

form which references this RMP/EIS. If the 

answer to any question is “YES”, the 

proposed action represents an exception, 

and site-specific analysis would be prepared.

Category I and M allotments would not meet 

the criteria for this type of action. 

Grazing permits/leases would be 

transferred or renewed for C and M 

category grazing allotments where the 

new grazing authorization (Same as B).

Category I allotments would not meet the 

criteria for this type of action.

Same as C

No current management decision 

provided

Relinquished AUMs would be retired. Relinquished AUMs would remain 

available for transfer. 

Relinquished AUMs would be transferred 

or managed as reserve common 

allotments for neighboring allotments with 

conflict or resource condition issues.

No current management decision 

provided

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. 

Areas with active surface disturbance 

would be available 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.

Same as C

Sheep or goats would not be permitted 

within 9 miles from known bighorn sheep 

habitat. This distance would be greater if 

deemed necessary through site specific 

Conversions from cattle to domestic sheep or 

goats would be prohibited in allotments 

within occupied wild sheep habitat (Map 17).

New sheep and goat allotments or 

Conversions from cattle to domestic 

sheep or goats would be prohibited in 

allotments within occupied wild sheep 

habitat (Map 17).

Domestic sheep/goat permits – No new 

grazing permits authorizing sheep or goats 

would be allowed within 14.3 air miles or 

23 Kilometers in bighorn sheep range (Map 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-178 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

analysis. conversions from cattle to sheep or goats 

would not be permitted within 14.3 miles from 

known bighorn sheep habitat. This distance 

would be greater if deemed necessary 

through site specific analysis. 

New sheep and goat allotments or 

conversions from cattle to sheep or goats 

would not be permitted within 12.4 miles 

from known bighorn sheep habitat. This 

distance would be greater if deemed 

necessary through site specific analysis.

17) or as determined through consultation

with MTFWP. 

Sheep and goat grazing allotments 

in areas with risk of contact between 

bighorn sheep and domestic sheep and/or 

goats in the planning area would be 

reviewed and managed, or reclassified if 

necessary, to achieve effective separation 

(both temporal and/or spatial at 23 

kilometers (14.3 miles) or as determined 

through consultation with 

MTFWP. Contact risk would be based on 

habitat, distance between bighorn sheep 

range (current and anticipated), sheep and 

goat allotments, movement potential, and 

current science and guidelines. Domestic 

sheep/goats would not be allowed within 

bighorn sheep range unless mechanisms 

are in place to achieve effective separation 

from wild sheep.

Recreation and Visitor Services

The Federal Land Policy and Management Act provides for recreation use of public land as an integral part of multiple use management. Dispersed, unstructured activities typify the recreational 

uses occurring throughout the majority of the planning area. BLM Manual 8320 directs the BLM to designate recreation management areas (RMAs). RMAs can be either Special Recreation 

Management Areas (SRMAs) where recreation is managed as the priority; or Extensive Recreation Management Areas (ERMAs) where recreation is managed commensurately with other 

resources and resources uses. Public lands that are not designated (PLND) as RMAs are managed to meet basic recreation and resource needs. Management within special recreation 

management areas focuses on providing recreation opportunities that would not otherwise be available to the public, reducing conflicts among users, minimizing damage to resources, and reducing 

visitor health and safety problems. The ERMA is an administrative unit that requires specific management consideration in order to address recreation use, demand, or recreation program 

investments. All other lands not designated as a SRMA or an ERMA are lands where recreation is not emphasized, however recreation activities may occur in equal emphasis with other resources 

and activities except on those lands closed to public use. The PLND lands are managed to allow recreation uses that are not in conflict with the primary uses of these lands and have minimal 

recreation program investment.

Recreation and Visitor Services – Desired Outcomes (Goals and Objectives)

 Public lands managed by the Billings Field Office provide a diverse array of benefits to the public, including economic, environmental, personal, and social ones.

 The BLM policy is to develop and maintain cooperative relationships with national, state, and local recreation providers, tourism entities, and local recreational groups.

 BLM’s goal is to develop and maintain appropriate recreational facilities, balancing public demand, protection of public land resources, and fiscal responsibility.

 The management direction is to emphasize and support collaborative public outreach, awareness events, and programs that promote public service and stewardship, and to encourage

sustainable travel and tourism development with local communities and provide community-based conservation support for visitor service. The emphasis is placed on providing interpretive

and informational signs and materials for public lands visitors, maintaining facilities to a high standard consistent with the recreational setting, and limiting development of additional facilities to

those areas where public recreational use of surrounding public lands requires them.

Recreation and Visitor Services – Management Common to All Alternatives

Conduct periodic accessibility, safety, and condition assessments in accordance with Bureau policy at developed recreation sites. Prioritize available funds to resolve deferred and 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-179

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

corrective maintenance needs.

Monitoring. Monitoring of recreation resources and human use including the following: visitor use and use patterns; recreation caused resource effects or impacts; visitor satisfaction; 

and effectiveness or attainment of outcomes-focused management objectives, recreation setting characteristics, and standards and indicators will be developed and implemented as a 

Implementation-Plan level Decision component.

Allow non-commercial dispersed camping subject to length of stay limitations, without a permit on BLM-administered lands in the planning area, except where prohibited. Evaluate the 

need for future developed camping locations in SRMA plans, based on select criteria such as habitat, resources, cultural, and socio-economic needs. 

Mineral exploration activities would be coordinated for timing to minimize conflicts during peak use periods (e.g., weekends, holidays, summer use season, etc.). 

Cooperate with FWP, private landowners, and other partners to improve hunter access and the availability of public lands for hunting in accordance with EO 13443. Lands closed to 

hunting are 51 acres at the Pompeys Pillar National Monument and 784 acres at Four Dances Natural Area SRMA/ACEC. 

Use off-site interpretation, education, and outreach as a means to protect public resources. 

Allow target shooting in appropriate areas and prohibit target shooting in areas with resource conflicts (refer to management actions by alternative below for areas available/prohibited 

to target shooting). The Billings Field office would not designate specific target shooting sites but would pursue or facilitate the transfer of fee title ownership of suitable areas 

commonly used for shooting areas, to interested local governments or organizations. The Billings Field office can also employ the patent provisions of the Recreation and Public 

Purposes (R&PP) Act, 43 U.S.C. § 1721, to convey ownership of lands for shooting ranges to non-profit organizations or local governments with the stipulation of non-revision of fee 

title and with no monitoring requirements by BLM (refer to the Land Tenure and Access section).

The Bureau of Land Management (BLM) would not issue permits or other land use authorizations for commercial services providing for the disposal of cremated remains on public 

lands. Individual, non-commercial scattering of cremated remains is subject to applicable state law and is considered casual use under 43 CFR 2920.0-5(k). Inquiries from individuals 

and families to scatter cremated remains should be handled on a case-by-case basis. 

If the level of use associated with individual, non-commercial scattering of cremated remains exceeds casual use criteria and causes resource concerns, the BiFO may establish 

notification requirements to determine the extent of use and whether an authorization process for this activity needs to be implemented, and may provide guidelines to users about 

appropriate scattering procedures and locations. If warranted, the BiFO may establish a process for issuing letters of authorization through the Lands, Realty, and Cadastral Survey 

Division, after the appropriate level of public scoping, National Environmental Policy Act (NEPA) analysis, and consultation have been completed.

The landing of fixed wing aircraft and rotary wing helicopters, for non-emergency purposes, would be restricted to existing or designated roads. The landing of aircraft for non-casual, 

commercial use such as guiding or air taxi services would be addressed on a case-by-case basis in the development of an SRP. Develop an appropriate method to allocate air taxi 

operator and guiding permits, such as lottery, sealed bid, or ranking criteria. 

Monitoring of recreation resources would continue to occur, with emphasis placed on developed recreation sites and SRMAs. Monitoring would include regular patrols to check on 

signing, visitor use, recreation related impacts, and user conflicts. Monitoring would also emphasize identification of areas with compliance problems. Actual visitor numbers and/or 

vehicle counts would be documented at developed sites for trend analysis. Monitoring of SRPs would be conducted for compliance with the terms, conditions, and stipulations of the 

SRP as well as annual monitoring and evaluation of compliance with administrative requirements. Periodic assessments would be made to ensure that uses in SRMAs and ERMAs 

are consistent with their management objectives. 

Cultivation for wildlife habitat improvements at the Sundance Lodge Recreation Area and at Pompeys Pillar ACEC would continue. Changes in cultivation patterns, seasons of use, 

and type of activity, including termination of use, could occur during project level review.

All signs would conform to the sign policies, guidelines, directives, and plans (Appendix AC). 

As emerging technologies cause new types of recreational activities to be developed or proposed for use on lands managed by the BLM Billings Field Office, these new recreational 

activities would be evaluated on a case-by-case basis, taking into account the resource values present, the types of activities proposed and their potential impacts. The emphasis on 

permitting these activities would be to allow them only if they avoid any impacts on high value resource locations (WSAs, ACECs, PMWHR, visual resources, areas of high soil 

erosion, critical wildlife habitats, cultural and paleontological sites, etc.).
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-180 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Recreation and Visitor Services – Management Common to Action Alternatives

No current management decision 

provided

No Surface Occupancy for oil and gas leasing, exploration and development within agency-designated fishing access sites.

No current management decision provided In PHMA, do not construct new recreation 

facilities (e.g., campgrounds, trails, 

trailheads, staging areas) unless the 

development would have a net 

conservation gain to GRSG habitat (such 

as concentrating recreation, diverting use 

away from critical areas, etc.), or unless the 

development is required for visitor health 

and safety or resource protection.

Special Recreation Management Areas

No current management decision 

provided

Special recreation management areas (SRMAs) management plans would be initiated within 5 years. Existing SRMA plans would be 

reviewed for consistency and revised as needed.

No current management decision 

provided

Distinct recreation settings, recreation objectives, recreational experiences, and activities for each SRMA and recreation management 

zone (RMZ) are identified in Appendix N.

No current management decision 

provided

Construction and maintenance of non-motorized recreational trails would be considered during the development of SRMA management 

plans. 

Recreation and Visitor Services – Management Actions by Alternative

Manage the following areas as SRMAs

(2 SRMAs – 1,171 acres) (Maps 80, 84, 

85):

 Sundance Lodge Recreation Area

(387 acres) 

 Four Dances Natural Area/ ACEC

(784 acres)

The following areas would be managed as 

SRMAs (6 SRMAs – 90,783 acres)

(Maps 81, 84, 85, 86a, 90, 92,101) :

 Sundance Lodge Recreation Area (387

acres)

 Four Dances Natural Area/ ACEC (784

acres)

 Shepherd Ah -Nei Recreation Area

(4,680 acres)

 Acton Recreation Area (3,697 acres)

 Bundy Island (98 acres)

 Pryor Mountain TMA (81,227 acres)

The following areas would be managed 

as SRMAs (11 SRMAs – 147,181 acres)

(Maps 82, 84, 85, 86a, 88, 90, 92, 94, 98, 

99, 100): 

 Sundance Lodge Recreation Area

(387 acres)

 Four Dances Natural Area ACEC

(784 acres)

 Shepherd Ah-Nei Recreation Area

(4,680 acres)

 Acton Recreation Area (3,697

acres)

 Yellowstone River Corridor (1⁄2 mile

corridor from centerline) (6,311

acres) 

 South Hills TMA (1,357 acres)

 Mill Creek/Bundy TMA(34,239

The following areas would be managed as 

SRMAs (9 SRMAs – 110,862 acres) (Maps 

83, 84, 85, 86a, 88, 90, 92, 94, 98, 99): 

 Sundance Lodge Recreation Area

(387 acres)

 Four Dances Natural Area ACEC 

(784 acres)

 Shepherd Ah-Nei Recreation Area

(4,680 acres)

 Acton Recreation Area (3,697 acres)

 Yellowstone River Corridor (1⁄2 mile

corridor from centerline) (6,311

acres)

 Asparagus Point (158 acres) (Would

be managed as an SRMA provided that 

the course of the Musselshell River 

stabilizes to a condition that management 

as an SRMA is feasible or practical.)
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-181

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

acres)

 Pryor Mountain TMA (81,227 acres)

 Horsethief TMA (12,261 acres)

 17 Mile (2,080 acres)

 Asparagus Point (158 acres)

 South Hills TMA (1,357 acres)

 Pryor Mountain TMA (81,227 acres)

 Horsethief TMA (12,261 acres)

Manage the following 7 areas as ERMAs 

(105,460 acres) (Maps 86, 87, 89, 91, 

93, 95, 97):

 Shepherd Ah-Nei Recreation Area

(4,680 acres)

 Acton Recreation Area (3,697

acres)

 South Hills TMA (1,357 acres)

 Pryor Mountain TMA (81,227

acres)

 Horsethief TMA (12,261 acres) 

 17 Mile (2,080 acres)

 Asparagus Point Area (158 acres)

Manage the following 5 areas as ERMAs 

(7,668 acres) (Maps 87, 93, 95, 97, 99a) : 

 Horsethief TMA (12,261 acres) 

 17 Mile (2,080 acres)

 Asparagus Point (158 acres)

 Yellowstone River Corridor (1⁄2 mile

corridor from centerline) (6,213 acres)

 South Hills TMA (1,357 acres)

Manage the following areas as ERMAs: 

 None

Manage the following 2 areas as ERMAs 

(36,319 acres) (Maps 95, 100a):

 17 Mile (2,080 acres)

 Mill Creek/Bundy TMA (34,239 acres)

All Lands not designated as SRMAs are 

managed as ERMAs. (327, 518 acres) 

Manage the following areas as nondesignated areas: 

The remaining public lands not identified 

above as SRMAs or ERMAs.

(327,421 acres) 

Manage the following areas as nondesignated areas: 

The remaining public lands not identified 

above as SRMAs or ERMAs.

(288,495 acres)

Manage the following areas as nondesignated areas:

The remaining public lands not identified 

above as SRMAs or ERMAs. 

(322,418 acres)

No current management decision 

provided

Surface disturbing activities related to 

recreation facility development and 

maintenance, at developed recreation sites 

would be subject to mitigation guidelines. 

Surface disturbing activities that benefit 

recreational facilities and visitor 

experiences would be allowed with an 

approved mitigation plan. 

Surface disturbing activities related to 

facility development and maintenance 

would be subject to mitigation guidelines.

No current management decision 

provided

Close the following areas to trapping:

 Sundance Lodge Recreation Area

SRMA

 Shepherd Ah-Nei Recreation Area

SRMA

 Four Dances Natural Area and

ACEC/SRMA

Allow trapping in the other designated SRMAs 

(see individual ACECs (Table 2.12) for 

trapping restrictions in ACECs)

Sundance Lodge Recreation Area SRMA 

and Shepherd Ah-Nei Recreation Area 

SRMA would be open to trapping. 

Four Dances Natural Area ACEC/SRMA 

would remain closed to trapping.

Same as B

NSO in developed recreation areas and Oil and gas leasing, exploration and Oil and gas leasing, exploration and Oil and gas leasing, exploration and 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-182 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

areas receiving high concentrated use. development activities would be allowed with 

No Surface Occupancy (NSO):

 Sundance Lodge Recreation Area

 Four Dances Natural Area ACEC 

 Shepherd Ah-Nei Recreation Area

 Acton Recreation Area

 Bundy Island

 South Hills TMA

 Pryor Mountain TMA

development allowed with a CSU, in 

developed recreation areas and SRMAs. 

development would be allowed with an 

NSO stipulation in the following SRMAs:

 Sundance Lodge Recreation Area

 Four Dances Natural Area ACEC 

 Shepherd Ah-Nei Recreation Area

 Acton Recreation Area

 Yellowstone River Corridor: 1⁄2 mile

corridor

Oil and gas leasing, exploration and 

development allowed with a CSU:

 Asparagus Point

 Pryor Mountain TMA

 Horsethief TMA

 South Hills TMA

No current management decision The following SRMAs or ERMAs would be 

managed as VRM Class II:

 Sundance Lodge Recreation Area

SRMA (387 acres)

 Four Dances Natural Area ACEC/SRMA

(784 acres)

 Shepherd Ah-Nei Recreation Area

SRMA (RMZ 2) (3,664 acres)

 Acton Recreation Area SRMA (3,697

acres)

 Bundy Island SRMA (98 acres)

 Yellowstone River Corridor (6,311

acres)

 Pryor Mountain TMA SRMA (which

includes WSA, lands w/ wilderness

characteristics, and ACECs) 

The following SRMAs or ERMAs would 

be managed as VRM Class II:

 Sundance Lodge Recreation Area

SRMA (387 acres)

 Four Dances Natural Area

ACEC/SRMA (784 acres)

 Shepherd Ah-Nei Recreation Area

SRMA (RMZ 2) (3,664 acres)

 Acton Recreation Area SRMA

(3,697 acres)

 Yellowstone River Corridor

 Pryor Mountain TMA SRMA (which

includes WSA, lands w/ wilderness

characteristics, and ACECs) 

 Mill Creek/Bundy TMA SRMA (YRC

only)

The following SRMAs or ERMAs would be 

managed as VRM Class II:

 Sundance Lodge Recreation Area

SRMA (387 acres)

 Four Dances Natural Area

ACEC/SRMA (784 acres)

 Shepherd Ah-Nei Recreation Area

SRMA (RMZ 2) (3,664 acres)

 Acton Recreation Area SRMA (3,697

acres)

 Yellowstone River Corridor

 Pryor Mountain TMA SRMA (which

includes WSA, lands w/ wilderness

characteristics, and ACECs) 

 Mill Creek/Bundy TMA/ERMA (YRC

only)

Sundance Lodge Recreation Area 

SRMA and Four Dances Natural Area 

ACEC/SRMA would be managed as 

VRM Class III

The following SRMAs or ERMAs would be 

managed as VRM Class III: 

 Shepherd Ah-Nei Recreation Area

SRMA (RMZ 1 (OHV area)) (976 acres)

 Horsethief TMA ERMA (12,261 acres)

 17 Mile Recreation Area ERMA (2,080

acres)

 Asparagus Point Recreation Area ERMA

(158 acres)

 South Hills TMA ERMA (1,357 acres)

The following SRMAs or ERMAs would 

be managed as VRM Class III: 

 Shepherd Ah-Nei Recreation Area

SRMA (RMZ 1 (OHV area)) (976

acres)

 Horsethief TMA SRMA (12,261

acres)

 17 Mile Recreation Area SRMA

(2,080 acres)

 Asparagus Point Recreation Area

The following SRMAs or ERMAs would be 

managed as VRM Class III: 

 Shepherd Ah-Nei Recreation Area

SRMA (RMZ 1 (OHV area)) (976

acres)

 Acton Recreation Area SRMA

(parking area)

 Horsethief TMA SRMA (12,261

acres)

 17 Mile Recreation Area ERMA
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-183

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

 YRC?

 Pryor Mountain TMA SRMA (all lands

outside of ACEC, lands w/ wilderness

characteristics and WSA)

SRMA (158 acres)

 South Hills TMA SRMA (1,357

acres)

 Yellowstone River Corridor

 Pryor Mountain TMA SRMA (all

lands outside of ACEC, lands w/

wilderness characteristics, and

WSA)

 Mill Creek/Bundy TMA/SRMA

(lands outside of the YRC)

(2,080 acres)

 Asparagus Point Recreation Area

SRMA (158 acres)

 South Hills TMA SRMA (1,357 acres)

 Mill Creek/Bundy TMA ERMA (lands

outside of YRC)

 Pryor Mountain TMA SRMA (all lands

outside of ACEC, lands w/ wilderness

characteristics, and WSA )

Special Recreation Permits

The BLM would issue special recreation use permits as appropriate for commercial, competitive, and special events subject to guidelines in BLM Handbook 2930, resource 

capabilities, social conflict concerns, professional qualifications, public safety, and public needs. SRPs would only be allowed in priority habitat if they are consistent with the goals and 

objectives for that habitat or species. 

Issuance of Special Recreation Permits and special stipulations attached per permit for both commercial and non-commercial permits would be determined by set monitoring 

indicators, BLM policies, and identified through site specific analysis. 

No current management decision 

provided

Issue special recreation permits, as appropriate, in an equitable manner for specific recreational uses of public lands and related waters 

as a means to minimize user conflicts, control visitor use, protect recreation resources, and provide for private and commercial recreation 

use. “Activity level planning would be developed through an environmental review process with public involvement. This management 

approach would identify the necessary indicators to monitor all permit conditions of approval that include the standards and stipulations 

necessary to change operations in the future.” Individual Special Recreation Permits (ISRP) would continue to be issued at Shepherd AhNei per regulation of the Federal Land Recreation Enhancement Act (FLREA) and follow the business plan for Shepherd Ah-Nei.

Target Shooting: Areas Open/Closed. (Note: acreages proposed for shooting vary by alternative due to other resource and activity decisions. Specifically, refer to Appendix E for 

changes in ACEC acreage.)

Four Dances Natural Area ACEC/SRMA

784 acres closed for resource (cultural, 

historical, wildlife) and public safety 

concerns (private inholdings, proximity to 

urban area, topography and vegetation 

screening)

0 acres open

784 acres closed for resource (cultural, historical, wildlife) and public safety concerns (private inholdings, proximity to urban area,

topography and vegetation screening)

0 acres open

Managed as SRMA

Sundance Lodge SRMA

387 acres closed for resource (cultural,

historical, wildlife) and public safety 

concerns (proximity to suburban 

residential areas, vegetation and 

topography screening)

0 acres open

387 acres closed for resource (cultural, historical, wildlife) and public safety concerns (proximity to suburban areas, vegetation 

screening)

0 acres open

Managed as SRMA

Acton Recreation Area 

3,697 acres closed for resource (cultural, 

historical) and public safety concerns 

3,697 acres closed for resource (cultural, historical) and public safety concerns (vegetation and topography screening, number of other 

users)
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-184 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

(vegetation and topography screening, 

number of users)

0 acres open

0 acres open

designated an SRMA

Shepherd Ah-Nei Recreation Area

4,689 acres closed for public safety 

(other recreation users) due to vegetation 

and topography screening factors. 

0 acres open

4,689 acres closed for public safety (other recreation users).

0 acres open

SRMA designated for motorized and non-motorized activities, specifically: OHVs less than 50 “ 

South Hills Recreation Area

1,357 acres closed for public safety 

concerns (adjacent housing tracts, golf 

course, roads). 

0 acres open 

1,357 acres closed for public safety concerns (adjacent housing tracts, golf course, roads).

0 acres open

Pompeys Pillar National Monument and ACEC

432 acres closed for resource (cultural, 

historical) and public safety concerns 

(major destination site by Act of 

Congress: visitor center, parking lots, 

trails, other facilities, adjacent private 

lands)

0 acres open 

432 acres closed for resource (cultural, historical) and public safety concerns (major destination site: visitor center, parking lots, trails, 

other facilities, adjacent private lands).

0 acres open. Management emphasis is on historical significance

17 Mile Recreation Area 

0 acres closed

2,080 acres open

No specific management emphasis

0 acres closed

2,080 acres open

ERMA designated – no specific management 

emphasis

0 acres closed

2,080 acres open

SRMA designated with emphasis on 

shooting 

0 acres closed

2,080 acres open

ERMA designated – no specific 

management emphasis

Castle Butte ACEC

0 acres closed

184 acres open

ACEC designation

184 acres closed for resource concerns (historical and cultural)

0 acres open 

Managed as ACEC

Weatherman Draw ACEC

0 acres closed

4,365 acres open – ACEC designation

4,986 acres closed for resource concerns 

(Historical and cultural) ACEC size increased

0 acres open 

12,277 acres closed for resource concerns (historical and cultural) ACEC size increased

0 acres open

Petroglyph Canyon ACEC

O acres closed

240 acres open

ACEC designation

240 acres closed for resource (historical and cultural significance) and public safety concerns (topography screening) 

0 acres open 

ACEC designation 

Pryor Mountain Wild Horse Range and East Pryor ACEC (using East Pryor ACEC acreages in Alt C and different acreage in Alt D)

0 acres closed

29,550 acres open

PMWHR – Congressional designation, 

8,301 acres closed year-round for resource 

concerns (wild Horse population), safety

concerns (number of people present, 

0 acres closed

32,767 acres open 

PMWHR Congressional designation and 

Shooting not allowed only in T. 8 S., R 28 

E., from Memorial Day through Labor Day 

for resource (wild horse population), public 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-185

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

and ACEC designation topography and vegetation screening) 

PMWHR Congressional designation and 

ACEC designation in place

ACEC designation in place safety concerns (number of people 

present). Total area seasonally closed is 

approximately 6,720 acres. 

Asparagus Point Area

2 acres closed for public safety concerns 

(developed site)

156 acres open

Managed as ERMA

2 acres closed for public safety concerns 

(developed site)

156 acres open

Managed as ERMA

2 acres closed for public safety concerns 

(developed site)

156 acres open

Managed as SRMA

2 acres closed for public safety concerns 

(developed site)

156 acres open

Managed as SRMA

Stark Site ACEC

0 acres closed 

799 acres open

ACEC designation

799 acres closed for resource concerns 

(cultural and Historical resources) 

0 acres open

ACEC designation

0 acres closed 

799 acres open

ACEC designation

799 acres closed for resource concerns 

(cultural and Historical resources) 

0 acres open

ACEC designation

Grove Creek ACEC

0 acres closed

8,251 acres open

8,251 acres closed for public safety concerns 

(adjacent private residences) 

0 acres closed

8,251 acres open

0 acres closed

8,251 acres open

Total Field Office BLM-administered public lands

11,348 acres closed to target shooting

422,185 acres open to target shooting 

(map 102) 

34,109 acres closed for resource safety 

concerns (map 103)

400,045 acres open to target shooting

24,049 acres closed for resource /safety 

concerns (map 104)

410,105 acres open to target shooting

31,586 acres closed or seasonally closed 

for resource/safety concerns (map 105)

402,568 acres open to target shooting

Trails and Travel Management

The BLM manages travel and transportation on public lands in accordance with existing laws, regulations and policies. Program policy guidance provides direction to the field for management and 

administration of all aspects of the travel management program. This guidance is developed at the National, State and District Office level, and includes regulations, manuals, handbooks, Strategic 

Action Plans, Instruction Memorandums, and Information Bulletins. The Billings Field Office Travel Management program would support the accomplishment of management objectives for all 

resource programs. Within this context, the Billings Field Office would identify a transportation system that supports the agency’s mission, management of land and resource programs and their 

goals and objectives, and provides for appropriate public and administrative access. The BLM’s present transportation network is largely inherited, created from past resource uses and public

access patterns.

Trails and Travel Management – Desired Outcomes (Goals and Objectives)

 Manage access to balance public use and protect public land resources,

 Promote safety for all public land users, and

 Minimize conflicts among OHV users and other uses of public lands.

 Goals and objectives would accomplish this by using partnerships with other land managing agencies, local governments, communities, and interest groups through a balanced approach, so

as to protect public lands by minimizing impacts and resources while providing opportunities for the safe use and enjoyment of OHVs

 The Billings Field Office would use a systematic process that considers the unique resource issues and social environments within each individual Travel Management Area (TMA) and

integrate concepts of habitat connectivity into OHV planning to minimize habitat fragmentation.

 Establish a long-term, sustainable, multi-modal transportation system of areas, roads, trails, and primitive roads which addresses public and administrative access needs to and across BLMmanaged lands and related waters.

 Manage travel and transportation on public lands and related waters in accordance with law, Executive Order, proclamation, regulation, and policy.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-186 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Trails and Travel Management – Management Common to All Alternatives

Motorized travel on BLM-administered land (outside of established TMAs) would be limited to existing roads and trails. Measureable limits of change that would occur to the resource 

as a result of these travel modes would include indicators based on Land Health Standards, accelerated soil erosion and/or other resource concerns and potential for natural 

rehabilitation. Site specific travel planning would be initiated. Site specific travel planning would be initiated when those limits are exceeded within a five (5) year period after the BiFO 

ROD is signed. 

To protect resource values 28,631 acres would be managed as closed to motorized vehicle use and 405,523 acres would be managed as limited to motorized vehicle use (refer to the 

specific TMA sections below).

Modifications to a transportation network (routes, re-routes or closures) in the planning area where travel is limited to existing roads and trails may be made through activity-level 

planning. 

Cooperatively develop public outreach programs to promote trail etiquette, environmental ethics and a responsible-use stewardship ethic (e.g., Tread Lightly, Leave No Trace, etc.).

BLM would continue to coordinate with MFWP in the Block Management program, or other access agreements with other landowners, as appropriate. Designated motorized routes 

would conform with seasonal travel limitations, based on annual block management agreements, as determined by the authorized officer on a case-by-case basis. 

Administrative access would limit motorized use to BLM-authorized use only. BLM employees, permittees, contractors, personnel from other agencies and other motorized access 

needs authorized by the authorized officer, would be allowed for resource management, maintenance, inventory, monitoring, or compliance purposes. Public use on administrative 

access routes would be limited to non-motorized access. 

Motorized wheeled cross-country travel to conduct BLM-authorized activities would require prior authorization 

Upon completion of site-specific projects, roads used for commercial or administrative access on BLM-administered lands would be reclaimed, unless the route provides specific 

benefits for public access, minimizes impacts to the resource and would be considered on a case-by-case basis.

The BLM may close or restore unauthorized, user created roads and trails to prevent resource damage.

Motorized off-road travel would be allowed for any military, fire, search and rescue, or law enforcement vehicle for emergency operations. 

Special recreation permits for motorized events, competitive events, or organized group activities would be considered and addressed through site-specific analysis.

Non-motorized recreational trails would be considered during the development of SRMA management plans and travel management plans (refer to Recreation/Visitor Services 

section). 

Motorized off-road big game retrieval would be authorized by the Field Manager on a case-by-case basis for individuals with a disabled hunter access permit (issued by MT FWP). 

Stipulations or limitations would be included in the authorization.

Oil and gas activities would comply with all motorized vehicle use and travel plan restrictions, including seasonal restrictions and areas closed to motorized travel. (CSU)

By BLM Manual 6330, WSAs do not allow for new surface disturbances and there is no cross-country OHV use. Use is restricted to the actual tread width. 

Efforts would be made to acquire easements across private lands to provide for public access.

Motorized travel in designated SRMAs would be allowed on designated routes only.

Motorized travel for all activities would be allowed on designated or existing routes only. Livestock permittees building or maintaining fences as part of the implementation of a grazing 

permit or lease would be exempted.

All motorized routes designated as “Open”, “Closed” or “Administrative Use Only” would be available for use for non-motorized activities.

The NPNHT and Lewis& Clark NHT are non-motorized trails by Congressional designation except for auto tour routes and crossings, and approve motorized use dating prior to the 

enacting legislation.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-187

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Trails and Travel Management – Management Common to Action Alternatives

No current management decision 

provided

BLM would manage to reduce open road densities in big game winter and calving ranges where they exceed 1.0 miles/square mile. 

No current management decision 

provided

Snowmobile use in the decision area would be allowed, except where restricted, and would be subject to the following restrictions: avoid 

locations where wind or topographic conditions may have reduced snow depth and create situations where damage to vegetation or soils 

would occur, or where vegetation is taller than the protective snow cover. Ecologically sensitive areas would be closed to snowmobiling if 

resource damage caused or exacerbated by snowmobile activity is found to be occurring in these areas.

No current management decision 

provided

Where off-highway vehicles are causing or would cause considerable adverse effects upon soil, vegetation, wildlife, wildlife habitat, 

cultural resources, historical resources, threatened or endangered species, wilderness suitability or other authorized uses, or other 

resources, the affected areas would be immediately closed to the type(s) of vehicle causing the adverse effect until the adverse effects 

are eliminated and measures implemented to prevent recurrence. 

No current management decision 

provided

Site specific travel planning within Greater Sage-Grouse PHMAs would be completed within a five (5) year period after the ROD is signed

where it hasn’t already been completed as part of this plan.

No current management decision provided In PHMA and GHMA, temporary closures 

would be considered in accordance with 43 

CFR subpart 8364 (Closures and 

Restrictions); 43 CFR subpart 8351 

(Designated National Area); 43 CFR 

subpart 6320 (Use of Wilderness Areas, 

Prohibited Acts, and Penalties); 43 CFR 

subpart 8341 (Conditions of Use).

Temporary closure or restriction orders 

under these authorities are enacted at the 

discretion of the authorized officer to 

resolve management conflicts and protect 

persons, property, and public lands and 

resources. Where an authorized officer 

determines that off-highway vehicles are 

causing or would cause considerable 

adverse effects upon soil, vegetation, 

wildlife, wildlife habitat, cultural resources, 

historical resources, threatened or 

endangered species, wilderness suitability, 

other authorized uses, or other resources, 

the affected areas shall be immediately 

closed to the type(s) of vehicle causing the 

adverse effect until the adverse effects are 

eliminated and measures implemented to 

prevent recurrence. (43 CFR 8341.2) A 

closure or restriction order should be 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-188 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

considered only after other management 

strategies and alternatives have been 

explored. The duration of temporary 

closure or restriction orders should be 

limited to 24 months or less; however, 

certain situations may require longer 

closures and/or iterative temporary 

closures. This may include closure of 

routes or areas.

Trails and Travel Management – Management Actions by Alternative

Dispersed Camping 

Motorized wheeled cross-country travel 

to a campsite is permissible within 300 

feet of existing roads and trails. Site 

selection must be completed by nonmotorized means and accessed by the 

most direct route. 

This does not apply where existing 

seasonal restrictions prohibit traveling off 

designated routes to a campsite. 

Ecologically sensitive areas or other areas 

restricted to motorized use would be closed 

to dispersed camping if resource damage is 

found to be occurring in these areas.

Same as A. Excluding WSAs and ACECs, OHV use off 

designated routes for the purposes of 

camping would be allowed, for a distance up 

to 150 feet from the centerline of the route. 

Site selection must be completed by nonmotorized means only and accessed by the 

most direct route.

Ecologically sensitive areas or other areas 

restricted to motorized use would be closed 

to dispersed camping if resource damage is 

found to be occurring in these areas.

Game Retrieval 

Motorized off-road big game retrieval not 

allowed for the general public.

OHV use off-road big game retrieval would 

not be allowed for the general public.

OHV use off-road big game retrieval 

would be allowed within 300 feet of an 

open route, excluding WSAs (where it is 

not allowed).

Same as Alternative B.

Snowmobiles (any vehicle capable of over snow travel)

No current management decision 

provided

Unrestricted Snowmobile (OSV) use would be allowed within the Field Office lands except the following areas:

 Restricted to the following designated routes within the PMWHR: Sykes Ridge Road – PM 1002, PM 1001, PM 1006 and

Burnt Timber Road -PM 1011, (except between April 15 and June 15, when Burnt Timber Road is closed to all vehicle use for 

resource protection).

 Not allowed at any time within WSAs in accordance with Manual 6300.

 Motorized over-the-snow travel may be limited by vehicle type, season, snow-depth, or other conditions as necessary.

 Over the snow vehicles would be prohibited in big game winter range.

Landing of Aircraft

Landing of aircraft (helicopters, wheel 

and float planes, ultra-lights, gliders, etc.) 

Landing of aircraft (helicopters, wheel and float planes, ultra-lights, gliders, etc.) is permissible on roads and primitive roads designated 

as “open” within TMAs and routes outside of TMAs.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-189

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

is permissible on existing roads.

Designated Non-motorized Trails

Sundance Lodge Recreation Area – Provide for high-visitation day-use activities while protecting natural resources.

No current management decision, but 

existing trail system has been developed 

and improved

3 trail segments totaling approximately 3.9 miles

Four Dances Natural Area/ACEC – Provide for high-visitation day-use activities while protecting natural resources.

No current management decision, but 

existing trail system has been developed 

and improved

5 trail segments totaling approximately 6.5 miles

Shepherd Ah-Nei Recreation Area – Provide for staging and trail use

No current management decision, but 

existing trail system has been developed 

and improved

3 trail segments totaling approximately 5.4 miles

Weatherman Draw ACEC – provide an emphasis on resource protection with dispersed recreation opportunities through a designated trail system

No current management decision, but 

existing trail system has been used

13 Trail segments totaling approximately 20.2 miles

Acton Recreation Area – Provide for staging and trail use with an emphasis on mountain bike use

No current management decision, but 

existing trail system has been developed 

and improved

12 trail segments totaling approximately 18.3 miles

Meeteetse Spires ACEC – Provide for access to adjacent USFS lands

No current management decision, but 

existing trail system has been developed 

and improved

2 trail segments totaling approximately 2.0 miles

Pryor Mountains - Provide for non-motorized recreational activities

No current management decision, but 

existing trail system has been developed 

and improved

5 trail segments totaling approximately 13.6 miles. 

Billings Field Office WSAs – Provide for primitive recreation opportunities while meeting non-impairment of wilderness values

No current management decision, but

trail system exists and segments are 

identified from the initial route inventory

5 trail segments totaling approximately 5.1 miles
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-190 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Pompeys Pillar National Monument

Interpretation Trail 

Walking Trail 1 3 trail segments totaling approximately 0.5 miles

Walking Trail 2

Other Areas

Lilly Pad Lake Trail 1 trail segment totaling approximately 0.6 miles

Bad Canyon Lands w/ Wilderness 

Characteristics Trail

1 Trail segment totaling approximately 5.9 miles

Burnt Timber Lands w/ Wilderness 

Characteristics Trail

1 Trail segment totaling approximately 8.2 miles

Travel Management Areas (TMAs)

No current management decision 

provided

Establish 11 Travel Management Areas (TMAs) to minimize impacts and provide a spectrum of motorized and non-motorized recreational 

opportunities (Map 106). (refer to Glossary – Travel Management Areas - for definitions of terminology)

No current management decision 

provided

Motorized travel in TMAs would be limited to designated roads, primitive roads, and trails, except in designated Open Areas (South Hills 

OHV Area) or on designated and existing routes (Elk Basin area of the Sub Region III of the Cottonwood/Weatherman Draw TMA) until 

the TMA Implementation Plan is completed or other resource concerns (such as soil erosion or sage grouse habitat concerns) are 

addressed. For the Elk Basin Area boundary defined see Section 3.21.3.11 in the RMP.) 

No current management decision 

provided

An implementation and monitoring plan would be initiated for the TMAs within 3-5 years of the ROD. The plan would include signing, 

mapping, information, and education, and monitoring of impacts associated with continued use on designated open routes, etc. 

Implementation plan would also identify criteria for route variances specific to each TMA.

No current management decision 

provided

Upon project completion, routes used for commercial or other BLM authorized activities would be reclaimed, unless the route provides 

specific benefits for public access, minimizes impacts to the resource and would be considered on a case-by-case basis.

No current management decision 

provided

The BLM would close or restore unauthorized or user created roads and trails to prevent resource damage.

No current management decision 

provided

Variances to travel plan or route designations would be issued based on essential agency administrative actions, data variances due to 

route inventory, boundary adjustments, etc., as determined by the authorized officer.

No current management decision 

provided

Travel management planning is not intended to provide evidence bearing on or addressing the validity of any R.S. 2477 assertions. R.S. 

2477 rights are adjudicated through a separate administrative process. The travel planning process analyzed resources, resource uses 

and associated access to public lands and waters. At such time as a decision is made on any R.S. 2477 assertions, the BLM would 

adjust its travel routes accordingly (refer to Appendix O – Travel Management).

No current management decision 

provided

TMAs can be changed, added, or deleted as conditions warrant, but the management prescriptions remain constant.

Gage Dome/Colony Road TMA

No established boundary for Gage 

Dome/Colony Road area.

Gage Dome/Colony Road TMA Management Objectives: reduce road density to minimize impacts to Greater Sage-Grouse habitat and 

other resource values. Manage the TMA to provide recreational opportunities and access while protecting Greater Sage-Grouse habitat.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-191

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Motorized travel limited to existing roads 

and trails – 96 miles (Map 107).

The following routes would be designated in 

the Gage Dome/Colony Road TMA (Map 

108):

 Open (additional management): 31

miles

 Admin Use Only: 42 miles

 Closed: 20 miles

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP. 

The following routes would be designated 

in the Gage Dome/Colony Road TMA

(Map 109):

 Open: 72 miles

 Open (additional management): 15

miles

 Admin Use Only: 6 miles

To see acres of the total miles, refer to 

the travel area maps in the Map Section 

of the RMP.

The following routes would be designated 

in the Gage Dome/Colony Road TMA (Map 

110):

 Open (additional management): 64

miles

 Admin Use Only: 29 miles

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP.

Horsethief TMA Management Objectives: provide a range of recreational and access opportunities while minimizing impacts to cultural and heritage values and other resources. This 

TMA was expanded to include Stark Site ACEC.

Motorized use allowed on designated 

roads: 36 miles (Map 111)

The following routes would be designated in 

the Horsethief TMA (Map 112):

 Open (additional management): 10

miles

 Admin Use Only: 13 miles

 Closed: 13 miles

 Non-motorized use only: 1 mile

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP.

The following routes would be designated 

in the Horsethief TMA (Map 113):

 Open: 31 miles

 Open (additional management): 3.4

miles

 Admin Use Only: 1 mile

 Closed: 0.1 mile

To see acres of the total miles, refer to 

the travel area maps in the Map Section 

of the RMP.

The following routes would be designated 

in the Horsethief TMA (Map 114):

 Open: 8.4 miles

 Open (additional management): 14

miles

 Admin Use Only: 13 miles

 Closed: 0.1 mile

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP.

No current management decision 

provided

A rock crawl area would not be established. A designated rock crawl area would be 

established – 1.5 miles (open area for 

technical 4WD by permit). The area

would be limited to technical four-wheel 

drive vehicles only. This activity would be 

confined to a single location where it 

would be managed and monitored. 

A rock crawl area would not be 

established. Special recreation permits for 

motorized events or organized group 

activities would be considered on a caseby-case basis. 

Acton TMA Management Objectives: provide a range of recreational and access opportunities while minimizing impacts to cultural properties and other resource values. 

Motorized use allowed on designated

roads: 7.1 miles

Closed: 1.5 miles

(Map 115)

The following routes would be designated in 

the Acton TMA (Map 116):

 Open (cond.): 5.1 miles

 Closed: 3.5 miles

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP.

The following routes would be designated 

in the Acton TMA (Map 117):

 Open (additional management): 8.6

miles

To see acres of the total miles, refer to 

the travel area maps in the Map Section 

of the RMP.

The following routes would be designated 

in the Acton TMA (Map 118):

 Open (seasonal/conditions

restriction) 6.8 miles

 Admin Use Only: 1 mile

 Closed: 0.8 mile

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-192 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Shepherd Ah-Nei TMA. This TMA is delineated into three sub-regions, based on landscape patterns, use, and resource considerations. 

Management Objectives: minimize user conflicts and impacts to resources while providing opportunities for both motorized and non-motorized activities through three distinct 

management zones.

Shepherd Ah-Nei Area I: 53 miles

Limited to motorized vehicles less than 

50” wide): Motorized use limited to 

existing roads and trails (Map 119)

The following routes would be designated in the Shepherd Ah-Nei TMA Area I:

53 miles: Limited to existing roads and trails (conditional and vehicle (less than 50” wide) restrictions apply). 

To see acres of the total miles, refer to the travel area maps in the Map Section of the RMP (Map 120).

Shepherd Ah-Nei Area II:

Closed to all motorized use

Shepherd Ah-Nei Area II:

Admin Use only 

Shepherd Ah-Nei Area III 

Limited to motorized use (by permit only)

Shepherd Ah-Nei Area III:

Admin Use Only

Mill Creek/Bundy TMA

No established boundary for Mill 

Creek/Bundy area

Mill Creek/Bundy TMA Management Objectives: improve access and provide a range of recreational opportunities. Protect cultural and 

resource habitat values within the Castle Butte ACEC boundaries. Emphasis would be placed on minimizing impacts to cultural properties 

and other resource values while providing access for the public, permittees, non-federal landowners, and administrative needs.

Motorized travel limited to existing roads 

and trails: 141 miles

(Map 123)

The following routes would be designated in 

the Mill Creek/Bundy TMA (Map 124):

 Open (additional management): 20

miles

 Admin Use Only: 54 miles

 Closed: 67 miles

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP.

The following routes would be designated 

in the Mill Creek/Bundy TMA (Map 125):

 Open: 70 miles

 Open (additional management): 37

miles

 Admin Use Only: 32 miles

 Closed: 2 miles

To see acres of the total miles, refer to 

the travel area maps in the Map Section 

of the RMP.

The following routes would be designated 

in the Mill Creek/Bundy TMA (Map 126):

 Open: 8 miles

 Open (additional management): 61

miles

 Admin Use Only: 67 miles

 Closed: 5 miles

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP.

South Hills TMA

Manage for motorcycle use. South Hills TMA Management Objectives: minimize user conflicts and impacts to resources while providing opportunities for both 

motorized and non-motorized activities

Manage South Hills open to cross 

country travel - Motorcycles only

1,097 acres Motorcycle Use only 

260 acre Buffer Area - Closed to 

Motorized Use (adjacent to residential 

area) (Map 127)

South Hills would be closed to motorized 

travel (1,357 acres closed)

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP. (Map 128)

Manage South Hills open to cross 

country travel - Motorcycles only

1,296 acres Motorcycle Use only 

61 acre Buffer Area - Closed to Motorized 

Use (adjacent to residential area)

To see acres of the total miles, refer to 

the travel area maps in the Map Section 

of the RMP. (Map 129)

Manage South Hills open to cross country 

travel - Motorcycles only

1,097 acres Motorcycle Use only 

260 acre Buffer Area - Closed to 

Motorized Use (adjacent to residential 

area) (Map 127)

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP. (Map 127)
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-193

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Tin Can Hill TMA

No established boundary for Tin Can Hill 

area.

Tin Can Hill TMA Management Objectives: to provide a range of recreational and access (public and administrative) opportunities. 

Minimize impacts to cultural properties and other resource values and minimize conflicting uses.

Motorized travel is not authorized; a 

temporary closure in place pending 

resource management plan analysis 

Motorized travel limited to existing roads 

and trails (Map 131)

The following routes would be designated in 

the Tin Can Hill TMA:

 Admin Use Only: 3 miles

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP. (Map 132)

The following routes would be designated 

in the Tin Can Hill TMA:

 Open (additional management): 2.5

miles

 Admin Use Only: 0.5 miles

To see acres of the total miles, refer to 

the travel area maps in the Map Section 

of the RMP. (Map 133)

The following routes would be designated 

in the Tin Can Hill TMA:

 Open (seasonal restrictions): 1.5

miles

 Admin Use Only: 0.5 miles

 Closed: 1 mile

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP. (Map 134)

Cottonwood/Weatherman Draw TMA

No established boundary for 

Cottonwood/Weatherman Draw area

This area would be delineated into three sub-regions to address varying resource issues, access and recreational opportunities. 

Sub-Region I - Weatherman Draw/Castle Coulee. The area is described as being all lands in the Cottonwood/Weatherman Draw TMA 

which are east of Cottonwood Road. These lands include the Weatherman Draw ACEC and the Weatherman Draw LWC unit. The 

management objectives are to protect cultural values and resources within the ACEC and the LWC units, minimize impacts to cultural 

values, fragile and erosive soils, scenery and other resources throughout the sub-region.

Sub-Region II - Hollenbeck These lands are described as all lands within the Cottonwood/Weatherman Draw TMA which lie west of Silver 

Tip Road. The management objectives are to provide recreational opportunities with an emphasis on minimizing impacts to Sage-grouse 

habitat, fragile and erodible soils, and other resources.

Sub-Region III - Silver Tip. The area is described as being all lands within the Cottonwood/Weatherman Draw TMA lying between Silver 

Tip Road and Cottonwood Road. These lands include the Elk Basin area which covers the Oil and Gas field and the OHV Motorcycle 

Trail system. The management goals are to provide for motorized recreational opportunities and oil and gas development with emphasis 

on minimizing impacts to fragile and erosive soils, sage grouse habitat, and other resources.

Motorcycle use permitted on designated 

and existing single track trails in the Elk 

Basin Area

Motorcycle use permitted on designated and existing single track trails in the Elk Basin Area (area defined in Section 3.21.3.11) until 

addressed through the follow-on Cottonwood/Weatherman Draw Travel Implementation Plan or through other resource initiatives (soil 

erosion, sage grouse, etc.). 

Weatherman Draw ACEC: motorized 

travel limited to administrative use only. 

No mechanized travel: 24 miles

Motorized travel limited to existing roads 

and trails: 285 miles

(Map 135)

The following routes would be designated in 

the Cottonwood/Weatherman TMA:

 Open (to motorcycles only): 10 miles

 Open (additional management): 123

miles

 Admin Use Only: 68 miles

 Closed: 108 miles

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP. (Map 136)

The following routes would be designated 

in the Cottonwood/Weatherman TMA:

 Open: 196 miles

 Open (to motorcycles only): 6 miles

 Open (vehicles 50” or less): 10

miles

 Open (additional management): 82

mi.

 Admin Use Only: 14 miles

 Closed: 1 mile

The following routes would be designated 

in the Cottonwood/Weatherman TMA:

 Open: 103 miles

 Open (to motorcycles only): 3 miles

 Open (vehicles 50” or less): 10 miles

 Open (additional management): 104

mi

 Admin Use Only: 75 miles

 Closed: 14 miles

To see acres of the total miles, refer to the 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-194 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

To see acres of the total miles, refer to 

the travel area maps in the Map Section 

of the RMP. (Map 137)

travel area maps in the Map Section of the 

RMP. (Map 138)

Warren TMA

No established boundary for Warren area Warren TMA Management Objectives: to provide recreational opportunities with emphasis on protecting key Greater Sage-Grouse

habitat while minimizing impacts to other resources values. Maintain current level of access.

Motorized travel limited to existing roads 

and trails: 34 miles

(Map 139)

The following routes would be designated in 

the Warren TMA:

 Admin Use Only: 18 miles

 Closed: 16 miles

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP. (Map 140)

The following routes would be designated 

in the Warren TMA:

 Open: 29 miles

 Open (additional management): 4

miles

 Admin Use Only: 0.5 miles

 Closed: 0.5 miles

To see acres of the total miles, refer to 

the travel area maps in the Map Section 

of the RMP. (Map 141)

The following routes would be designated 

in the Warren TMA:

 Open: 1 mile

 Open (additional management): 9

miles

 Admin Use Only: 23 miles

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the

RMP. (Map 142)

Pryor Mountain TMA Management Objectives: to protect wilderness values, cultural/heritage/paleontological resources, visual characteristics, special status plants, fragile and 

erosive soils, wild horses, and wild horse habitat.

Motorized travel limited to designated

roads and trails (Map 143):

 Open: 119 miles

 Admin Use Only: 2.5 miles

 Closed: 103.5 miles

The following routes would be designated in 

the Pryor Mountain TMA:

 Open (additional management): 71

miles

 Open (seasonal restrictions): 7 miles

 Admin Use Only: 28.5 miles

 Closed: 118 miles

 Non-motorized use only: 0.5 miles

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP. (Map 144)

The following routes would be designated 

in the Pryor Mountain TMA:

 Open: 175 miles

 Open (additional management): 17

miles

 Open (seasonal restrictions): 1.2

miles

 Admin Use Only: 30.3 miles

 Closed: 1.5 miles

To see acres of the total miles, refer to 

the travel area maps in the Map Section 

of the RMP. (Map 145)

The following routes would be designated 

in the Pryor Mountain TMA:

 Open: 37 miles

 Open (vehicles 50” or less): 2.5 miles

 Open (additional management): 87

miles

 Open (seasonal restrictions): 0.5

miles

 Admin Use Only: 60 miles

 Closed: 38 miles

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP. (Map 146)

Grove Creek TMA

No established boundary for the Grove 

Creek area.

Grove Creek TMA Management Objectives: to minimize impacts to geologic and visual resources, special status plants, and cultural and 

wildlife values, including Greater Sage-Grouse, while providing casual, non-commercial public recreational access. 

Motorized travel limited to existing roads 

and trails: 73 miles

(Map 147)

The following routes would be designated in 

the Grove Creek TMA:

 Open (additional management): 18

miles

The following routes would be designated 

in the Grove Creek TMA:

 Open: 38 miles

 Open (additional management): 32

The following routes would be designated 

in the Grove Creek TMA:

 Open: 12 miles

 Open (additional management): 25
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-195

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

 Admin Use Only: 9 miles

 Closed: 46 miles

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP. (Map 148)

miles

 Admin Use Only: 2.5 miles

 Closed: 0.5 miles

To see acres of the total miles, refer to 

the travel area maps in the Map Section 

of the RMP. (Map 149)

miles

 Admin Use Only: 32 miles

 Closed: 4 miles

To see acres of the total miles, refer to the 

travel area maps in the Map Section of the 

RMP. (Map 150)

Routes may provide non-commercial access to private property; however, even though route has been designated as part of the official 

BLM travel management network, such designation does not constitute or afford the rights of a legally or officially recognized easement 

or ROW.

Renewable Energy

The Bureau of Land Management has placed increased emphasis on development of renewable energy resources to meet the provisions of the Energy Policy Act of 2005 and the Secretary of the 

Interior’s goals as set out in Secretarial Order No. 3285, as amended. Specific areas administered by the Billings Field Office are valuable given their high wind potential, but development may be

constrained due to the presence of other significant resources. Allocations and/or management actions for renewable energy sources such as geothermal and biomass in the Billings Field Office 

are addressed in the Forest and Woodlands and Leasable Minerals sections, respectively. Specific allocations and management actions for solar resources are not discussed in this planning 

document given the low solar insolance levels in Montana that make commercial development unlikely, though the exclusion and avoidance areas outlined for renewable energy would be utilized 

should a solar development application be received.

The allocations and management actions outlined in the alternatives below provide varying degrees of a Renewable Energy program focused on wind energy development in the Billings Field 

Office. Designation by BLM of renewable energy exclusion and avoidance areas would minimize adverse impacts to important resource values. Opportunities for testing and development with the 

least resource conflicts are greatest in open areas based on known resources. Proposals in those areas would likely encounter fewer resource issues and associated mitigation measures. BLM 

would cooperate with project proponents and other agencies and stakeholders to promote the use of these resources in the Billings Field Office, consistent with goals and objectives for other 

resources. 

Renewable Energy – Desired Outcomes (Goals and Objectives)

 Provide opportunities for the development of renewable energy resources from sources such as wind, biomass, and solar, while minimizing adverse impacts to other resource values.

 Make lands available for renewable energy development, consistent with goals and objectives of other resources.

 In cooperation with project proponents, promote and enhance scientific knowledge of renewable energy resources in the planning area.

Renewable Energy – Management Common to All Alternatives

Proposals for renewable energy development would be considered, except in exclusion areas. Proposals would not be entertained in designated exclusion areas. Proposals in 

avoidance areas could be subject to substantial special stipulations given known resource values.

Wind and solar applications would be processed under the Realty, Cadastral Survey, and Lands right-of-way regulations found at 43 CFR 2800, as would biomass energy generating 

facilities. 

Geothermal development would be considered under the geothermal regulations found at 43 CFR 3200; utilization of biomass would generally be authorized under regulations for the 

forestry program found at 43 CFR 5400, and hydropower applications would be considered under provisions of the Federal Power Act, as amended, in coordination with the Federal 

Regulatory Energy Commission (FERC).

Programmatic policies and best management practices identified in the Record of Decision for Implementation of a Wind Energy Development Program as well as BLM policies and 

directives regarding wind energy would be used in processing all wind energy applications.

Renewable Energy – Management Actions by Alternative

Manage 47,496 acres as exclusion areas 

(closed) to renewable energy 

authorizations, including:

 WSAs

 Big Horn Tack-On WSA

Manage 345,491 acres as exclusion areas 

(closed) to renewable energy authorizations, 

including:

 WSAs*

 Big Horn Tack-On WSA

Manage 82,019 acres as exclusion areas 

(closed) to renewable energy 

authorizations, including:

 WSAs

 Big Horn Tack-On WSA

Manage 231,755 acres as exclusion areas 

(closed) to renewable energy 

authorizations, including:

 WSAs*

 Big Horn Tack-On WSA
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-196 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

 National Historic Trails

 Nez Perce NHT

 Lewis & Clark NHT

 Pompeys Pillar NM

 ACECs

 Bridger Fossil Area ACEC

 East Pryor ACEC 

 Meeteetse Spires ACEC

 Petroglyph Canyon ACEC 

 Stark Site ACEC

 Weatherman Draw ACEC

(Map 153)

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

*If released by an Act of Congress, lands

within WSA boundaries would remain closed.

 National Historic Trails

 Nez Perce NHT

 Lewis & Clark NHT

 Pompeys Pillar NM

 ACECs

 Bridger Fossil Area ACEC

 Castle Butte ACEC 

 East Pryor ACEC 

 Four Dances ACEC 

 Grove Creek

 Meeteetse Spires ACEC

 Petroglyph Canyon ACEC 

 Pompeys Pillar NM/ACEC

 Pryor Foothills ACEC

 Stark Site ACEC

 Weatherman Draw ACEC

 Wild and Scenic River Eligible/Suitable

Segments

 Lands with wilderness characteristics

 Pryor Mountain Wild Horse Range

(PMWHR)

 Cultural Sites

 Steamboat Butte

 Bruder-Janich Site

 Paul Duke Site

 Demi-John Flat NR District

 Bighorn Mouth North Cliffs Rock Art

Site

 Hoskins Basin Archaeological District

 Greater Sage-Grouse: PHMAs, RAs

and GHMAs

 VRM Class I areas

 Slopes >30% and/or fragile soils with

low reclamation potential and highly

erodible characteristics.

 Cave and Karst Area

(Map 154)

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

 National Historic Trails

 Nez Perce NHT

 Lewis & Clark NHT

 Pompeys Pillar NM

 ACECs

 Bridger Fossil Area ACEC

 Castle Butte ACEC 

 East Pryor ACEC 

 Four Dances ACEC 

 Grove Creek

 Meeteetse Spires ACEC

 Petroglyph Canyon ACEC 

 Pompeys Pillar NM/ACEC

 Stark Site ACEC

 Weatherman Draw ACEC

 Wild and Scenic River 

Eligible/Suitable Segments

 Lands with wilderness

characteristics

 Pryor Mountain Wild Horse Range

(PMWHR)

 Cultural Sites

 Steamboat Butte

 Bruder-Janich Site

 Paul Duke Site

 Demi-John Flat NR District

 Bighorn Mouth North Cliffs Rock Art

Site

 Hoskins Basin Archaeological

District

 VRM Class I areas

 Slopes >45% and/or fragile soils

with low reclamation potential and

highly erodible characteristics.

(Map 155)

 Burnt Timber Canyon WSA

 Pryor Mountain WSA

 Twin Coulee WSA

*If released by an Act of Congress, lands

within WSA boundaries would remain

closed.

 National Historic Trails

 Nez Perce NHT

 Lewis & Clark NHT

 Pompeys Pillar NM

 ACECs

 Bridger Fossil Area ACEC

 Castle Butte ACEC 

 East Pryor ACEC 

 Four Dances ACEC 

 Grove Creek ACEC

 Meeteetse Spires ACEC

 Petroglyph Canyon ACEC 

 Pompeys Pillar ACEC 

 Pryor Foothills ACEC

 Stark Site ACEC

 Weatherman Draw ACEC

 Wild and Scenic River 

Eligible/Suitable Segments

 Lands with wilderness characteristics

 Pryor Mountain Wild Horse Range

(PMWHR)

 Cultural Sites

 Steamboat Butte

 Bruder-Janich Site

 Paul Duke Site

 Demi-John Flat NR District

 Bighorn Mouth North Cliffs Rock Art

Site

 Hoskins Basin Archaeological District

 VRM Class I areas

 Greater Sage-Grouse PHMAs

 Elk Basin GRSG Restoration Area

(Map 156)
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-197

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Manage 25,144 acres identified as 

avoidance areas for other Realty, 

Cadastral Survey, and Lands

authorizations as avoidance for 

renewable energy authorizations.

If authorizations are allowed, special 

stipulations and mitigation measures 

along with standard stipulations and 

BMPs would be applied as necessary 

through site-specific analysis.

Avoidance areas include:

 Asparagus Point, Steamboat Butte,

Portion of Acton, Portion of

Shepherd Ah-Nei, Bad Canyon,

East and Red Pryor Mountains

 Hoskins Basin Archeological

District, Demi-John Flat

Archeological District, Beartooth

Mountain Front (2 mile strip

bordering the eastern boundary of

the Custer National Forest).

 Pompeys Pillar ACEC

 Four Dances ACEC

(Map 153)

Manage 85,461 acres as avoidance areas for 

renewable energy authorizations, subject to 

special stipulations and mitigation beyond 

standard stipulations and BMPs applied 

through site specific analysis. 

Special stipulations and mitigation include 

provisions such as timing limitations, 

controlled surface use, and other 

constraints/restrictions consistent with fluid 

minerals stipulations that would be applied to 

protect the following particular 

resources/habitats:

 Bald/Golden Eagles

 Ferruginous Hawks

 Greater Sage-Grouse Winter Range

 Big Game Winter Range

 Big Game Parturition

 Bighorn Sheep Habitat

 Sharp-tailed grouse nesting

 Peregrine Falcon

 Mountain Plover

 Raptor Nests

Other avoidance areas include:

 Asparagus Point, Steamboat Butte,

Portion of Acton, Portion of Shepherd

Ah-Nei, Bad Canyon, East and Red

Pryor Mountains

 VRM Class II and III areas

 Within 1⁄2 mile of riparian areas and

wetlands, designated 100 year flood

plains and on water bodies and

streams, except activities are not in

conflict with the desired outcomes.

 Timing limitations apply to development

of facilities, but not to operation or 

maintenance.

(Map 154)

Manage 326,722 acres as avoidance 

areas for renewable energy 

authorizations, subject to special 

stipulations and mitigation beyond the 

standard stipulations and BMPs applied 

through site-specific analysis.

Special stipulations and mitigation 

include provisions such as timing 

limitations, controlled surface use, and 

other constraints/restrictions consistent 

with fluid minerals stipulations that would 

be applied to protect the following 

particular resources/habitats:

 Greater Sage-Grouse

PHMAs, RAs and GHMAs

 Bald/Golden Eagles

 Ferruginous Hawks

 Greater Sage-Grouse Winter Range

 Big Game Winter Range

 Big Game Parturition

 Bighorn Sheep Habitat

 Sharp-tailed grouse

 Peregrine Falcon

 Mountain Plover

 Raptor Nests

Other avoidance areas include:

 Asparagus Point, Steamboat Butte,

Portion of Acton, Portion of

Shepherd Ah-Nei, Bad Canyon,

East and Red Pryor Mountains

 Pryor Foothills ACEC

 Cave and Karst areas

 VRM Class II areas

 Within riparian areas or wetlands,

designated 100 year floodplains

and on water bodies and streams,

except activities that are not in

conflict with desired outcomes.

 Timing limitations apply to

development of facilities, but not to

operation or maintenance.

(Map 155)

Manage 200,278 acres as avoidance areas 

for renewable energy authorizations, 

subject to special stipulations and 

mitigation beyond standard stipulations 

and BMPs applied through site-specific 

analysis.

Special stipulations and mitigation include 

provisions such as timing limitations, 

controlled surface use, and other 

constraints/restrictions consistent with fluid 

minerals stipulations that would be applied 

to protect the following particular 

resources/habitats:

 Greater Sage-Grouse GHMAs

 Greater Sage-Grouse Restoration

Areas outside of Elk Basin

 Bald/Golden Eagles

 Ferruginous Hawks

 Greater Sage-Grouse Winter Range

 Big Game Winter Range

 Big Game Parturition

 Bighorn Sheep Habitat

 Sharp-tailed grouse

 Peregrine Falcon

 Mountain Plover

 Raptor Nests

Other avoidance areas include:

 Asparagus Point, Steamboat Butte,

Portion of Acton, Portion of Shepherd

Ah-Nei, Bad Canyon, East and Red

Pryor Mountains,

 Cave and Karst areas

 VRM Class II areas

 Within 1⁄4 mile of riparian areas and

wetlands, designated 100 year flood

plains and on water bodies and

streams, unless activities are not in

conflict with desired outcomes.

 Surface disturbance on slopes >30%,

soils with low reclamation potential,

and highly erodible characteristics

would be avoided whenever possible.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-198 Chapter 2: Resource Management Alternatives

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

If disturbance could not be avoided 

an approved mitigation and 

reclamation plan would be required 

prior to activities taking place.

 Timing limitations apply to

development of facilities, but not to

operation or maintenance.

(Map 156)

Manage 361,514 acres as Open to 

renewable energy, applying standard 

ROW terms and conditions and wind or 

other BMPs, including in the following 

areas (Map 153):

 Greater Sage-Grouse PHMAs, RAs

and GHMAs

 ACECs

 Castle Butte

 Grove Creek

 Pryor Foothills

 WSR Eligible Segments

 Bad Canyon

 Bear Canyon

 Crooked Creek (upper)

 Crooked Creek (lower) 

 Gyp Springs

 Piney Creek

 Yellowstone River/Pompeys Pillar 

Manage 0 acres as Open to renewable 

energy. (Map 154)

Manage 21,349 acres as Open to 

renewable energy, applying standard 

ROW terms and conditions and wind or 

other BMPs. (Map 155)

Manage 1,512 acres as Open to renewable 

energy, applying standard ROW terms and 

conditions and wind or other BMPs. (Map 

156)

Designate 360 acres of Open acres in 

Class 4 and above as Potential Wind 

Development Areas. At the discretion of 

the Authorized Officer, areas designated 

as Potential Wind Development Areas 

could be offered for competitive leasing.

Transportation and Facilities

The BLM public lands are accessible by a variety of National, State, local and agency road and trail networks. The BLM also has a number of developed facilities to administer its programs; they 

include bridges, major culverts, buildings, recreation and administrative sites, and dams. All facilities, roads, and trails are managed through the Facility Asset Management System (FAMS) 

program. All facilities are identified as public property.

Transportation and Facilities – Desired Outcomes (Goals and Objectives)

 Manage roads, primitive roads and trails for public access or administrative needs, while maintaining or protecting resource values, in coordination with other federal agencies, state and local

governments and private landowners. This action would be done in coordination with the development and implementation of the TMAs.

 Ensure BLM facilities are maintained to meet public health and safety requirements.

Transportation and Facilities – Management Common to All Alternatives

BLM-administered roads included in the transportation system would be assigned maintenance intensities, as needed. These roads would be managed in accordance with objectives

identified in the travel management areas (TMAs), assigned maintenance intensities and in consideration of resources issues and available funding.

Roads and trails would be inspected on an established schedule in accordance with the Bureau’s Condition Assessment guidance. The results of the condition assessments would be 

reviewed to determine the need for reconstruction, maintenance, or disposal.

BLM authorized recreation sites, administrative sites, buildings, bridges, roads, and trails would be maintained within Bureau standards to reduce deferred maintenance costs; meet 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-199

Table 2.11 Detailed Table of Alternatives: Resource Uses and Support

Record#

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

public health and safety requirements; provide universal accessibility as appropriate and to enhance visitor experiences. These activities would be coordinated with other federal, state 

and local government agencies, private landowners and the general public as needed.

Bridges and major culverts would be inspected on an established schedule in accordance with the Bureau’s Condition Assessment guidance. The results of the condition 

assessments would be reviewed to determine the need for reconstruction, maintenance or disposal.

Condition assessments and Emergency Action Planning for hazard class dams would be performed as required by the latest version of the 9177 (Dam Safety) manual section and 

associated handbooks. The results of the condition assessments would be reviewed to determine the need for reconstruction, maintenance, or disposal.

New roads and trails determined to be necessary for permanent or long-term use as part of BLM’s transportation system would be constructed subject to NEPA and approved

engineering standards. Consideration would be given to use demands, location, safety and resource constraints when determining the level of road necessary, in accordance with 

BLM Manuals 9113 and 9114.

Lands available or suitable for transportation facilities within the planning area would be identified. Road repair, road rehabilitation, road construction, and maintenance standards 

appropriate to specific areas would be identified as well as any limitations.

If an existing road, primitive road or trail is substantially contributing to resource impacts, the road would be considered for re-design, re-routing, closure, or decommissioning to 

minimize the adverse impacts.

Provide adequate administrative and other facilities to accommodate management needs, based on management analysis, to maintain, replace, construct, lease; including asset 

disposal. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-200 Chapter 2: Resource Management Alternatives

Table 2.12 Detailed Table of Alternatives: Special Designations

Record#

Alternative A

(No Action) Alternative B Alternative C Alternative D(Proposed Alternative)

Special Designations

Evaluate areas of interest needing special management for special designation 

Retain 9 ACECs for a total of 37,896 

acres

Retain 9 ACECs and designate 3 new 

ACECs for a total of 181,175 acres

Retain 9 ACECs and designate 2 new 

ACECs for a total of 67,079 acres

Retain 9 ACECs and designate 2 new

ACECs for a total of 38,786 acres

Table 2.12 Detailed Table of Alternatives: Special Designations

Pompeys Pillar National Monument (51 acres)

Record# Management Activity Alternative A Alternative B Alternative C Alternative D

Pompeys Pillar National Monument– Desired Outcomes (Goals and Objectives) as expressed in BLM Manual 6220

Comply with the designating Act of Congress and Presidential Proclamation (Appendix W) by conserving, protecting, and restoring the nationally significant landscape, objects, and values for which

PPNM was designated for the benefit of present and future generations.

Effectively manage valid existing rights and compatible uses within the PPNM.

Manage discretionary uses within PPNM to ensure the protection of the objects and values for which the PPNM was designated.

Utilize science, local knowledge, partnerships, and volunteers to effectively manage the PPNM in order to enhance the public’s understanding and enjoyment of the PPNM consistent with the 

designating legislation or proclamation, with an emphasis on youth and veterans. 

PPNM would be managed as a high potential historic site and a high potential route segment along the Lewis and Clark National Historic Trail. The Lewis and Clark high potential route segment 

would be managed consistent with the trailwide goals for the Lewis and Clark National Historic Trail.

PPNM is included within the Lewis and Clark National Historic Trail Management corridor. Where multiple NLCS designations overlap, as in this case with the PPNM and the Lewis and Clark National 

Historic Trail, the BLM must comply with all applicable statutes. In order to do so, the more protective management requirements would likely apply. However, this would be evaluated on a case-bycase basis.

Pompeys Pillar National Monument– Management Common to All Alternatives

Manage Pompeys Pillar NM (51) acres to protect the historical and cultural objects for which it was nominated a National Monument.

Develop and maintain relationships with other Federal agencies, tribal governments, state and local governments, national-level partnership organizations and non-profit groups, and the 

general public in order to effectively manage the PPNM in accordance with designating legislation and proclamations, other applicable laws, and BLM policy.

Land Use 

Authorizations

Exclusion area, except for those necessary to serve the site facilities.

Land Tenure land disposals not allowed

Visual Resource 

Management

Class II for the National Historic Landmark (6 acres) for protection of the significant historical resource and VRM Class III for the remainder of the PPNM for 

consideration of potential facility development and public management concerns.

BLM Road Maintenance Limited to the designated roadway and only that work necessary to ensure public safety and serviceability of the road to meet government standards.

Fluid Mineral Leasing, 

Locatable Minerals, 

Solid Leasable 

Minerals, Mineral 

All Federal lands and interest in lands within the boundaries of PPNM are appropriated and withdrawn from all forms of entry, location, selection, sale, or leasing 

or other disposition under the public land laws, including, but not limited to withdrawal from location, entry, and patent under the mining laws, and from 

disposition under all laws relating to mineral and geothermal leasing, subject to valid existing rights. Consider acquiring minerals from willing sellers.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-201

Table 2.12 Detailed Table of Alternatives: Special Designations

Pompeys Pillar National Monument (51 acres)

Record# Management Activity Alternative A Alternative B Alternative C Alternative D

Materials Sales and 

Permits

Geophysical Exploration closed to geophysical exploration

Fuelwood cutting/Wood 

Product Sales

not allowed

Hunting Closed to hunting for public safety and resource concerns

Target Shooting Not allowed for public safety and resource concerns

Road Maintenance Limited to the designated roadway and only that work necessary to ensure public safety and serviceability of the road and to meet government standards

Site Facilities When new administrative offices, visitor centers, contact stations, and similar facilities are needed for the Monument, the BLM would generally develop, or 

encourage the development of, these facilities within nearby communities to enhance local economic vitality and quality of life and to minimize disturbance within 

the Monument.

Management Zones Historic (Natural) Zone – (29 acres). Objective: provide 

visitor access to Clark’s signature and other historic 

inscriptions/rock art, and to enhance the visitors’ experience 

by providing landscapes that appear similar to the natural 

setting Clark viewed in 1806. 

Historic (Developed) Zone – (54 acres). Objective: provide 

an area where most facilities would be placed. Facilities 

would be designed to enhance visitor experiences. Farming 

is to be excluded and currently tilled ground restored to a 

setting characteristic of 1806. (Map 157)

Front Country Zone – includes all of the National Monument lands (51 acres) and 34 acres 

outside of and immediately adjacent to the National Monument (Map 158). In this zone the BLM

would: 

1. Inventory existing facilities and determine whether to remove, maintain, restore, enhance, or

allow natural disintegration of each facility. Subject to applicable law and valid existing rights, the 

BLM would consider removal of facilities that do not have administrative, public safety, 

recreational, cultural, or historic value.

2.Use this zone area to develop new facilities, including structures and roads, where they are

necessary for public health and safety, are required under law, are necessary for the exercise of 

valid existing rights or other non-discretionary uses, prevent impacts to fragile resources, or 

further the purposes for which the NM was designated.

3.Facilities within the Monument, including utility, water, and electrical supply lines, would be

designed and sited in a manner that minimizes impacts to the objects and values and the area’s 

scenic characteristics; emphasizes energy efficiency and, where possible, the use of small-scale 

renewable energy installations; and conforms to best management practices for visual resources 

management and the BLM Guidelines for a Quality Built Environment.

4.Facilities would be designed to enhance visitor experiences

Off-Highway Vehicles 

and Bicycles

Limited to designated roads and trails (administrative use or 

other authorized use allowed).

Limited to designated roads and trails (2). Administrative use or other authorized use allowed on 

a case-by-case basis.

Plant Collecting No current management decision provided Not allowed

Renewable Energy No current management decision provided Closed (6) to commercial renewable energy facilities and development.

Fire Suppression Water use only within NHL (6 acres). Appropriate fire 

management for the rest of the PPNM (full protection 

strategies).

Water use only within monument (51 acres).

Livestock Grazing Allowed only as a management tool. Livestock grazing would not be Livestock grazing may be allowed on a temporary 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-202 Chapter 2: Resource Management Alternatives

Table 2.12 Detailed Table of Alternatives: Special Designations

Pompeys Pillar National Monument (51 acres)

Record# Management Activity Alternative A Alternative B Alternative C Alternative D

allowed. basis, for the treatment of noxious weeds, or as a 

prescription to meet site specific vegetation or other 

resource management goals.(6) 

Fuels Management No current management decision provided. Fuels management and prescribed fire (7) may be allowed in the entire PPNM

Range Improvements No current management decision provided Conditionally Allowed (4)

Noxious/Invasive Weed 

Treatments

Utilize integrated weed management to reduce the incidence 

of noxious/non-native species.

Allowed (4) (9)

Animal 

Trapping/Traplines

Allowed Allowed for administrative purposes in the entire PPNM.

Non-Commercial 

Collection of Common 

Invertebrate and Plant 

Fossils

No current management decision provided. Not allowed

Cremains Scattering No current management decision provided Not allowed

Special Recreation 

Permits and Letters of 

Authorization 

Allowed Allowed (4)

SRPs would initially be limited to existing SRPs. Additional (new) SRPs would be permitted only 

when determined not to result in impacts to the values for which the ACEC was designated.

Other Permitted 

Activities

Allowed Allowed (4)

Geocaching Allowed Generally not allowed (10)

Other Management 

Activities

No current management decision provided Other management activities and/or uses would be considered in subsequent site-specific 

analysis, and would consider the values for which the PPNM is designated (4).

Notes: 

1 Avoidance area; granting Rights-of-Way (surface, subsurface, aerial) within the area should be avoided, but rights-of-way may be granted if there is minimal or no conflict with identified resource values and impacts to ACEC resource values can be 

fully mitigated. 

2 Off-highway vehicle, and bicycle, use would be limited to designated routes only. 

3 Commercial collection of plant materials, including common species, authorized by permit only. Casual use allowed. 

4 The activity is allowed in the area on a case-by-case basis and only if there is minimal or no conflict with identified resources values and impacts to PPNM resource values can be fully mitigated. Additional NEPA analysis required. Cultural inventories 

will be required for surface disturbing activities. Native American coordination/consultation required on activities within PPNM (especially if cultural resources are one of the values for PPNM designation).. 

5 This includes all commercial renewable energy facilities, including those for testing, monitoring, and development. 

6 Livestock grazing will be controlled through terms and conditions on the grazing permit. 

7 Evaluate fire potential and remove fuels where needed to protect resource values. Types of treatments permitted include: mechanical treatments, treatment or application of chemicals, and other treatments that would not negatively impact the values 

of the PPNM. 

8 Open to mineral material activities on a case-by-case basis and subject to controlled surface use, seasonal timing restrictions, restricted or no uses in avoidance areas (e.g. riparian areas, areas with special wildlife or plant features, areas of high 

cultural significance, and sensitive viewsheds), and additional NEPA analysis required. 

9 Treatments may include any combination of herbicide application, mechanical treatments, burning, grazing, and the use of insects or pathogens. 

10 If geocache location/activity does not conflict with the resource values of the PPNM this activity could be considered. BLM resource specialists (archaeologist and wildlife biologist), BLM ORP, and PPNM manager must agree activity does not impact 

PPNM values.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-203

Table 2.12 Detailed Table of Alternatives: Special Designations

Pompeys Pillar ACEC (432 acres)

Record# Management Activity Alternative A Alternative B Alternative C Alternative D

Pompeys Pillar ACEC– Desired Outcomes (Goals and Objectives), as expressed in BLM Manual 1613

Pompeys Pillar ACEC would be managed as a high potential historic site and a high potential route segment along the Lewis and Clark National Historic Trail. The Lewis and Clark high potential route 

segment would be managed consistent with the trail-wide goals for the Lewis and Clark National Historic Trail. 

Pompeys Pillar ACEC is included within the Lewis and Clark National Historic Trail Management corridor.

Give priority to the management and protection of the resources for which the ACEC was designated, according to FLPMA. The identified resources are primarily significant cultural resources, and 

also a functional riparian ecosystem and fish and wildlife habitat.

Pompeys Pillar ACEC– Management Common to All Alternatives

The 432 acre ACEC includes the 51 acre National Monument. The following management is for the ACEC (347 acres) outside of the National Monument and Front Country Zone.

Land Use 

Authorizations

Avoidance (1) Area –restricts ROW to a 500’ wide path paralleling the southern boundary of the public lands along Highway 312.

Land Tenure Land disposals not allowed, with the possible exception of the three acre parcel south of Interstate 94. 

Visual Resource 

Management

Class II established for consistency with the Lewis and Clark National Historic Trail management.

BLM Road Maintenance Limited to the designated roadway and only that work necessary to ensure public safety and serviceability of the road to meet government standards.

Fluid Mineral leasing No surface occupancy

Fuelwood cutting/Wood 

Product Sales

not allowed

Target Shooting Not allowed for public safety and resource concerns

Hunting Allowed. Management restrictions would be implemented to ensure public safety. Alterations to restrictions would be made if conditions require. Hunting is not 

allowed in a portion of the ACEC located in proximity to developed facilities and an area of high public use. (Approximately 58 acres) for safety considerations.

Management Zones General Management Zone – (349 acres). Objective: 

improve and/or maintain wildlife habitat condition, enhance 

recreation opportunities and utilize agriculture to further 

general management. (Map 157)

General Management Zone – (347 acres) - entire ACEC outside of the PPNM/Front Country 

Zone:

The management objective is to improve and/or maintain wildlife habitat, protect significant 

cultural and riparian ecosystem, provide for or enhance recreational opportunities, visitor 

services, and wildlife viewing. Priority may be given to resource protection measures for identified 

needs, but decisions may also include facility development, if needed.

(Map 158)

OHV and Bicycle use Limited to existing roads and trails Limited to designated roads and trails (2). Administrative use or other authorized use allowed on 

a case-by-case basis.

Plant Collecting No current management decision provided Not allowed Allowed but with restrictions (3) 

Locatable minerals No current management decision provided Recommend withdrawal from mineral entry and location under the Mining Law of 1872, as 

amended. Subject to valid existing rights. 

Solid leasable minerals No current management decision provided. Closed and recommend for withdrawal from solid leasable mineral entry, subject to valid existing 

rights.

Mineral materials sales 

and permits

No current management decision provided Not allowed

Renewable Energy No current management decision provided Not allowed (6) 

Geophysical exploration No current management decision provided Closed to geophysical exploration
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-204 Chapter 2: Resource Management Alternatives

Table 2.12 Detailed Table of Alternatives: Special Designations

Pompeys Pillar ACEC (432 acres)

Record# Management Activity Alternative A Alternative B Alternative C Alternative D

Fire Suppression Appropriate fire management for the ACEC (full protection 

strategies).

No heavy equipment in riparian area. Full range of fire management activities would be used in 

remainder of ACEC.

Fuels Management No current management decision provided. Fuels management (8) allowed in the 

entire ACEC. Prescribed fire allowed.

Fuels management and prescribed fire (8) may be 

allowed in the ACEC.

Livestock grazing Allowed only as a management tool. Livestock grazing would not be 

allowed.

Livestock grazing may be allowed on a temporary 

basis, for the treatment of noxious weeds, or as a 

prescription to meet site specific vegetation or other 

resource management goals.(7) 

Range Improvements No current management decision provided Allowed (5)

Noxious/Invasive Weed 

Treatments

Utilize integrated weed management to reduce the incidence 

of noxious/non-native species.

Allowed (5) (10)

Animal 

Trapping/Traplines

Allowed Allowed for administrative purposes in the entire ACEC.

Non-Commercial 

Collection of Common 

Invertebrate and Plant 

Fossils

No current management decision provided. Not allowed

Cremains Scattering No current management decision provided Not allowed

Special Recreation 

Permits and Letters of 

Authorization 

Allowed Allowed (5)

SRPs would initially be limited to existing SRPs. Additional (new) SRPs would be permitted only 

when determined not to result in impacts to the values for which the ACEC was designated.

Other Permitted 

Activities

Allowed Allowed (5)

Geocaching Allowed Generally not allowed but could be if conditions are met (11)

Road Maintenance No current management decision provided Allowed (4)

Other management 

activities

No current management decision provided Other management activities and/or uses would be considered in subsequent site-specific 

analysis, and would consider the values for which the ACEC is designated (5).

Notes: 

1. Avoidance area; granting Rights-of-Way (surface, subsurface, aerial) within the area should be avoided, but rights-of-way may be granted if there is minimal or no conflict with identified resource values and impacts to ACEC resource values can be fully

mitigated. 

2. Off-highway vehicle, and bicycle, use would be limited to designated routes only.

3. Commercial collection of plant materials, including common species, authorized by permit only. Casual use allowed.

4. Road maintenance will be limited to the designated roadway and only that necessary to ensure public safety and serviceability of the road.

5. The activity is allowed in the area on a case-by-case basis and only if there is minimal or no conflict with identified resources values and impacts to ACEC resource values can be fully mitigated. Additional NEPA analysis required. Cultural inventories will

be required for surface disturbing activities. Native American coordination/consultation required on activities within ACEC (especially if cultural resources are one of the values for ACEC designation). 

6. Closed to renewable energy facilities and renewable energy development. This includes all commercial renewable energy facilities, including those for testing, monitoring, and development.

7. Livestock grazing will be controlled through terms and conditions on the grazing permit.

8. Evaluate fire potential and remove fuels where needed to protect resource values. Types of treatments permitted include: mechanical treatments, treatment or application of chemicals, and other treatments that would not negatively impact the values of 

the ACEC. 

9. Open to mineral material activities on a case-by-case basis and subject to controlled surface use, seasonal timing restrictions, restricted or no uses in avoidance areas (e.g. riparian areas, areas with special wildlife or plant features, areas of high cultural

significance, and sensitive viewsheds), and additional NEPA analysis required. 

10. Treatments may include any combination of herbicide application, mechanical treatments, burning, grazing, and the use of insects or pathogens.

11. If geocache location/activity does not conflict with the resource values of the ACEC this activity could be considered. BLM resource specialists (archaeologist and wildlife biologist), BLM ORP, must agree activity does not impact ACEC values
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-205

Table 2-12 Detailed Table of Alternatives: Special Designations

Bridger Fossil Area ACEC

Record# Management Activity Alternative A (577 acres) Alternative B (577 acres) Alternative C (577 acres) Alternative D (577 acres)

Bridger Fossil Area ACEC – Desired Outcomes (Goals and Objectives)

The Bridger Fossil Area ACEC would be managed to protect paleontological values. In addition, the values for which the Bridger Fossil Area National Natural Landmark was designated would be 

maintained.

Bridger Fossil Area ACEC – Management Actions by Alternative

Land use authorization, 

including ROWs

Exclusion area Exclusion area Avoidance area (1) Same as B

Land tenure No current management decision provided Category I retention land: no land disposal would occur

Off-highway vehicle use Limited to existing roads. Limited to designated roads and trails 

(refer to Warren TMA).

Limited to designated roads and 

trails (refer to Warren TMA).

Limited to designated roads and 

trails (refer to Warren TMA).

BLM road maintenance No current management decision provided Limited (4) Same as B Same as B

Visual resource 

management

Class IV Class III Class III Class II 

Plant collecting No current management decision provided Not allowed Allowed (3)

Fluid Mineral leasing Closed (NL) Closed (NL) NSO with no Waivers, 

Exceptions, Modifications

Closed (NL)

Locatable minerals No current management decision provided Recommend withdrawal from mineral entry and location under the Mining Law of 1872, as amended. Subject 

to valid existing rights.

Solid leasable minerals No current management decision provided Closed

Mineral materials sales and 

permits

Not allowed Same as A Allowed (9)

Renewable energy No current management decision provided Closed (6)

Geophysical exploration for 

oil and gas

Allowed if no damage to paleontological 

resources. If monitoring indicates fossil 

damage, this activity would not be allowed.

Not allowed Same as A Allowed (5) if no damage to 

paleontological resources. If 

monitoring indicates fossil damage, 

this activity would not be allowed.

Use of explosives for 

geophysical exploration for 

oil and gas

Not allowed

Fire suppression No current management decision provided With the exclusion of heavy equipment, a full range of fire management activities would be used in the ACEC.

Fuels management No current management decision provided Fuels removed where there would be threat of loss of resource (8)

Fuel wood cutting/wood 

product sales

Not allowed

Livestock grazing Allowed Available (7)

Range improvements No current management decision provided Not allowed Allowed if no conflicts with ACEC values (5)

Noxious/Invasive weed 

treatments

No current management decision provided Allowed (5) (10)

Animal trapping/traplines No current management decision provided Not allowed Allowed
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-206 Chapter 2: Resource Management Alternatives

Table 2-12 Detailed Table of Alternatives: Special Designations

Bridger Fossil Area ACEC

Record# Management Activity Alternative A (577 acres) Alternative B (577 acres) Alternative C (577 acres) Alternative D (577 acres)

Target shooting No current management decision provided Not allowed Allowed Allowed – monitor to ensure no 

conflicts with resource values.

Non-commercial collection 

of common invertebrate and 

plant fossils

Allowed Allowed (5) by BLM authorization only 

Cremains scattering No current management decision provided Not allowed Allowed (5) Allowed (5)

Special Recreation Permits

and letters of authorization

Allowed Not allowed Allowed (5) Allowed (5)

SRPs would initially be limited to 

existing SRPs. Additional (new) 

SRPs would be permitted only 

when determined not to result in 

impacts to the values for which 

the ACEC was designated.

Other permitted activities Allowed Not allowed. Allowed (5) Allowed (5)

Transportation No current management decision provided No new permanent road or trail development for motorized vehicles.

Geocaching Allowed Not allowed (11)

Other management activities No current management decision provided Other management activities and/or uses would be considered in subsequent site-specific analysis, and would 

consider the values for which the ACEC is designated (5).

Notes: (Map 159 and 175)

1 Avoidance area; granting Rights-of-Way (surface, subsurface, aerial) within the area should be avoided, but rights-of-way would be granted if there is minimal or no conflict with identified resource values and impacts to 

ACEC resource values can be fully mitigated.

2 Off-highway vehicle, and bicycle, use would be limited to designated routes only.

3 Commercial collection of plant materials, including common species, authorized by permit only. Casual use allowed.

4 Road maintenance will be limited to the designated roadway and only that necessary to ensure public safety and serviceability of the road.

5 The activity is allowed in the area on a case-by-case basis and only if there is minimal or no conflict with identified resources values and impacts to ACEC resource values can be fully mitigated. Additional NEPA 

analysis required. Cultural inventories will be required for surface disturbing activities. Native American coordination/consultation required on activities within ACEC (especially if cultural resources are one of the values 

for ACEC designation).

6 Closed to renewable energy facilities and renewable energy development

7 Livestock grazing will be controlled through terms and conditions on the grazing permit.

8 Evaluate fire potential and remove fuels where needed to protect resource values and meet the objectives of the ACEC values. Types of treatments permitted: No surface disturbing heavy equipment use, most types of 

fire/fuels treatments permitted, check with archaeologist prior to retardant use 

9 Open to mineral material activities on a case-by-case basis and subject to controlled surface use, seasonal timing restrictions, restricted or no uses in avoidance areas (e.g. riparian areas, areas with special wildlife or 

plant features, areas of high cultural significance, and sensitive viewsheds), and additional NEPA analysis required. 

10 Treatments may include any combination of herbicide application, mechanical treatments, burning, grazing, and the use of insects or pathogens.

11 If geocache location/activity does not conflict with the resource values of the ACEC, this activity could be considered. BLM Resource Specialist (arch) and BLM ORP must agree activity does not impact ACEC values.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-207

Table 2-12 Detailed Table of Alternatives: Special Designations

Castle Butte ACEC

Record# Management Activity Alternative A (184 acres) Alternative B (184 acres) Alternative C (184 acres) Alternative D (184 acres)

Castle Butte ACEC – Desired Outcomes (Goals and Objectives)

The Castle Butte ACEC would be managed to protect unique cultural values.

Castle Butte ACEC – Management Common to All Alternatives

Consider acquiring mineral estate from willing sellers for the ACEC.

Castle Butte ACEC – Management Actions by Alternative

Land use authorizations Allowed if significant cultural sites avoided Exclusion area. Avoidance (1) Avoidance (1)

Land tenure No current management decision provided Category I retention land: no land disposal would occur

Off-highway vehicle use Limited to designated roads and trails. Limited to designated routes (refer 

to Mill Creek TMA). 

Limited to designated routes (refer 

to Mill Creek TMA). 

Limited to designated routes 

(refer to Mill Creek TMA). 

BLM road maintenance No current management decision provided Limited (4)

Visual resource 

management

Class III Class III Class III Class II

Plant collecting No current management decision provided Not allowed Allowed (3)

Fluid Mineral leasing No federal minerals

Locatable minerals No federal minerals

Solid leasable minerals No federal minerals

Mineral materials sales 

and permits

No federal minerals

Renewable energy No current management decision provided Closed (6)

Geophysical exploration 

for oil and gas

Not allowed on the significant cultural 

sites, surface methods and vibroseis 

allowed in the remainder of the area

Not allowed Same as A Same as B

Use of explosives for 

geophysical exploration 

for oil and gas

No current management decision provided Not allowed

Fire suppression Conditional fire suppression No heavy equipment use; no retardant or foam use on Castle Butte; full range of fire management activities 

would be used in remainder of ACEC.

Fuels management No current management decision provided Fuels removed where there would be threat of loss of resource (8).

Fuel wood cutting/wood 

product sales

Not allowed

Livestock grazing Allowed Available (7)

Range improvements Allowed Not allowed Allowed if no conflicts with ACEC values (5)

Noxious/Invasive weed 

treatments

No current management decision provided Allowed (5) (10)

Animal trapping/traplines No current management decision provided Not allowed Not allowed within 150 feet of 

Castle Butte rock formation; 

allowed in remaining ACEC

Same as B

Target shooting No current management decision provided Not allowed

Non-commercial 

collection of common 

plant fossils

No current management decision provided Allowed
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-208 Chapter 2: Resource Management Alternatives

Table 2-12 Detailed Table of Alternatives: Special Designations

Castle Butte ACEC

Record# Management Activity Alternative A (184 acres) Alternative B (184 acres) Alternative C (184 acres) Alternative D (184 acres)

Cremains scattering No current management decision provided Not allowed Allowed (5) Same as B

Special Recreation 

Permits and letters of 

authorization

Allowed (5) Not allowed Allowed (5) Allowed (5)

SRPs would initially be limited 

to existing SRPs. Additional 

(new) SRPs would be 

permitted only when 

determined not to result in 

impacts to the values for 

which the ACEC was 

designated.

Other permitted activities Allowed on a case-by-case basis Allowed (5)

Transportation No current management decision provided No new road or trail development

Geocaching Allowed Not allowed (11)

Other management 

activities

No current management decision provided Other management activities and/or uses would be considered in subsequent site-specific analysis, and 

would consider the values for which the ACEC is designated (5).

Notes: (Map 159 and 176)

1 Avoidance area; granting Rights-of-Way (surface, subsurface, aerial) within the area should be avoided, but rights-of-way may be granted if there is minimal or no conflict with identified resource values and impacts 

to ACEC resource values can be fully mitigated.

2 Off-highway vehicle, and bicycle, use would be limited to designated routes only

3 Commercial collection of plant materials, including common species, authorized by permit only. Casual use allowed.

4 Road maintenance will be limited to the designated roadway; and only that necessary to ensure public safety and serviceability of the road.

5 The activity is allowed in the area on a case-by-case basis and only if there is minimal or no conflict with identified resources values and impacts to ACEC resource values can be fully mitigated. Additional NEPA 

analysis required. Cultural inventories will be required for surface disturbing activities. Native American coordination/consultation required on activities within ACEC (especially if cultural resources are one of the 

values for ACEC designation).

6 Closed to renewable energy facilities and renewable energy development

7 Livestock grazing will be controlled through terms and conditions on the grazing permit.

8 Evaluate fire potential and remove fuels where needed to protect resource values and meet the objectives of the ACEC values. Types of treatments permitted: hand cutting or, chainsaw use only on the Castle Butte 

rock formation, elsewhere in the ACEC other types of treatment would be allowed.

9 Open to mineral material activities on a case-by-case basis and subject to controlled surface use, seasonal timing restrictions, restricted or no uses in avoidance areas (e.g. riparian areas, areas with special wildlife 

or plant features, areas of high cultural significance, and sensitive viewsheds), and additional NEPA analysis required. 

10 Treatments may include any combination of herbicide application, mechanical treatments, burning, grazing, and the use of insects or pathogens. 

11 If geocache location/activity does not conflict with the resource values of the ACEC, this activity could be considered. BLM resource specialist (archaeologist) and BLM ORP must agree activity does not impact ACEC 

values.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-209

Table 2-12 Detailed Table of Alternatives: Special Designations

East Pryor ACEC

Record# Management Activity Alternative A (29,550 acres) Alternative B (8,301 acres) Alternative C (32,767 acres) Alternative D (11,122 acres)

East Pryor ACEC – Desired Outcomes (Goals and Objectives)

The East Pryor ACEC would be managed to protect wild horse and wildlife habitat, historical/cultural resources, special status plant species, and paleontological values. In addition, the values for 

which the Crooked Creek Natural Area and the Crooked Creek National Natural Landmark were designated would be maintained. (Maps 177, 178, 179, 180)

East Pryor ACEC – Management Actions by Alternative

Land use 

authorization

Exclusion area Exclusion area, except valid existing 

rights.

Avoidance (1)

Land tenure No current management decision provided Category I retention land: no land disposal would occur

Off-highway vehicle 

use including 

snowmobiles (OSVs)

Limited to designated routes (refer to Pryor 

TMA and Table 2.11 Trails and Travel 

Management – Management Actions by 

Alternative. Snowmobiles (OSVs )

Limited to designed routes (refer to 

Pryor TMA and Table 2.11Trails and 

Travel Management – Management 

Actions by Alternative. Snowmobiles 

(OSVs). 

Limited to designated routes 

(refer to Pryor TMA and Table 

2.11Trails and Travel 

Management – Management 

Actions by Alternative. 

Snowmobiles (OSVs).

Limited to designated routes 

(refer to Pryor TMA and Table 

2.11 Trails and Travel 

Management – Management 

Actions by Alternative. 

Snowmobiles (OSVs). 

BLM road 

maintenance

No current management decision provided Limited (4)

Visual resource 

management

Class II

Plant collecting No current management decision provided Allowed for scientific use or 

range/forestry studies. No collection 

of special status species without a 

permit.

Allowed for personal use as well 

as scientific use and 

range/forestry studies. No 

collection of special status 

species without a permit.

Allowed (3)

Fluid Mineral leasing Closed to oil and gas leasing and 

development (NL) 

Closed to oil and gas leasing and 

development (NL).

Closed to oil and gas leasing and 

development (NL).

Closed to oil and gas leasing 

and development (NL).

Locatable minerals Closed and recommended for withdrawal Recommend withdrawal from mineral 

entry and location under the Mining 

Law of 1872, as amended. Subject 

to valid existing rights.

Open Same as B

Solid leasable 

minerals

No current management decision provided Closed, subject to valid existing 

rights.

Open (5) Same as B

Mineral materials 

sales and permits

Not allowed Not allowed Allowed (9)

Renewable energy No current management decision provided Closed (6)

Geophysical 

exploration for oil and 

gas

Not allowed
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-210 Chapter 2: Resource Management Alternatives

Table 2-12 Detailed Table of Alternatives: Special Designations

East Pryor ACEC

Record# Management Activity Alternative A (29,550 acres) Alternative B (8,301 acres) Alternative C (32,767 acres) Alternative D (11,122 acres)

Use of explosives for 

geophysical 

exploration for oil and 

gas

No current management decision provided Not allowed

Fire suppression Conditional fire suppression Wildfire management (natural 

ignitions) for resource benefit. 

Full range of fire management 

activities would be used in ACEC in 

response to human-ignited fires. 

Full range of fire management 

activities would be used in

ACEC.

Same as B

Fuels management No current management decision provided Allowed (8)

Fuel wood 

cutting/wood product 

sales

Not allowed Not allowed Casual collection of dead and down allowed for personal use only 

while recreating.

Livestock grazing Closed within PMWHR boundary, except

trailing allowed through Bad Pass only. 

Available outside PMWHR (7)

Same as A Closed within PMWHR boundary, 

except Bad Pass Trail Allotment.

Available outside PMWHR (7)

Same as C

Wild Horses Managed only within the PMWHR 

Range improvements No current management decision provided Allowed (5)

Noxious/Invasive 

weed treatments

No current management decision provided Allowed (5) (10)

Animal trapping/trap 

lines

No current management decision provided Not allowed Allowed

Target shooting No current management decision provided Not allowed Allowed Not allowed on 8S 28E 

Memorial Day weekend 

through Labor Day weekend.

Allowed in remainder of ACEC

Non-commercial 

collection of common 

invertebrate and plant 

fossils

Allowed

Cremains scattering No current management decision provided Not allowed

Special Recreation 

Permits and letters of 

authorization

No current management decision provided SRPs would initially be limited to existing SRPs. Additional (new) SRPs would be permitted only when 

determined not to result in congestion, wild horse displacement, cause an adverse experience for members 

of the public viewing wild horses outside of an SRP experience through monitoring of existing SRPs and 

visitation, and when determined not to result in impacts to the values for which the ACEC was designated. (5)

Other permitted No current management decision provided Allowed (5)
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-211

Table 2-12 Detailed Table of Alternatives: Special Designations

East Pryor ACEC

Record# Management Activity Alternative A (29,550 acres) Alternative B (8,301 acres) Alternative C (32,767 acres) Alternative D (11,122 acres)

activities

Transportation No current management decision provided No net increase in road density Routes for commercial or other 

BLM authorized activities may be 

considered on a case-by-case 

basis if the route meets public 

access needs.

Same as C

Geocaching Allowed Not allowed (11)

Other management 

activities

No current management decision provided Other management activities and/or uses would be considered in subsequent site-specific analysis, and 

would consider the values for which the ACEC is designated (5).

WSA No current management decision provided Until Congress acts to either release or designate the WSAs as Wilderness, the area would continue to be 

managed under the BLM Manual 6300 prescriptions. If Congress releases the lands from WSA status, the 

special management prescriptions as an ACEC would comprise the management direction. These 

management prescriptions are slightly different from the WSA prescriptions. A more detailed ACEC 

Management Plan would be initiated within 2 years following WSA release. This ACEC management plan 

would be developed through a public process. If at that time management decisions are proposed that would 

significantly alter the resource allocations outlined in this RMP, a Plan Amendment would likely be 

undertaken. 

Notes: (Maps 159 and 177, 178, 179, 180 )

1 Avoidance area; granting Rights-of-Way (surface, subsurface, aerial) within the area should be avoided, but rights-of-way may be granted if there is minimal or no conflict with identified resource values and impacts to 

ACEC resource values can be fully mitigated.

2 Off-highway vehicle, and bicycle, use would be limited to designated routes only.

3 Commercial collection of plant materials, including common species, authorized by permit only. Casual use allowed.

4 Road maintenance will be limited to the designated roadway; and only that necessary to ensure public safety and serviceability of the road.

5 The activity is allowed in the area on a case-by-case basis and only if there is minimal or no conflict with identified resources values and impacts to ACEC resource values can be fully mitigated. Additional NEPA 

analysis required. Cultural inventories will be required for surface disturbing activities. Native American coordination/consultation required on activities within ACEC (especially if cultural resources are one of the 

values for ACEC designation).

6 Closed to renewable energy facilities and renewable energy development

7 Livestock grazing will be controlled through terms and conditions on the grazing permit.

8 Evaluate fire potential and remove fuels where needed to protect resource values. Most types of fire and fuels treatments are permitted. 

9 Open to mineral material activities on a case-by-case basis and subject to controlled surface use, seasonal timing restrictions, restricted or no uses in avoidance areas (e.g. riparian areas, areas with special wildlife or 

plant features, areas of high cultural significance, and sensitive viewsheds), and additional NEPA analysis required. 

10 Treatments may include any combination of herbicide application, mechanical treatments, burning, grazing, and the use of insects or pathogens. 

11 If geocache location/activity does not conflict with the resource values of the ACEC, this activity could be considered. BLM resource specialists (Wild Horse Specialist, wildlife biologist, and archaeologist) and BLM 

ORP must agree activity does not impact ACEC values. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-212 Chapter 2: Resource Management Alternatives

Table 2-12 Detailed Table of Alternatives: Special Designations

Four Dances Natural Area ACEC

Record# Management Activity Alternative A (784 acres) Alternative B (784 acres) Alternative C (784 acres) Alternative D (784 acres)

Four Dances Natural Area ACEC – Desired Outcomes (Goals and Objectives)

The Four Dances Natural Area ACEC would be managed to protect significant historic, cultural, and scenic values, peregrine falcon nesting habitat, and managed for the natural hazards of the 

cliffs.

Four Dances Natural Area ACEC – Management Common to All Alternatives

Consider acquiring minerals from willing sellers for the ACEC.

Four Dances Natural Area ACEC – Management Actions by Alternative

Land use authorization Avoidance area. Uses and practices would be 

consistent with the Deed of Conservation 

Easement.

A restricted quantity of ROWs, temporary use 

permits, and land authorizations are available if 

the actions are consistent with ACEC 

objectives. 

Avoidance (1). Uses and practices would be consistent with the Deed of Conservation Easement.

Land Tenure No land sales, R&PPs, conveyances, or longterm leases for habitation or industrial use.Category I retention land: no land disposal would occur

Off-highway vehicle use OHV use (including bicycles) limited to 

administrative or authorized use only. No 

snowmobiles and no off-road vehicle use.

Same as A Closed to motorized public use. 

Mechanized (bicycle) travel would be 

considered in a future SRMA plan.

Same as C

BLM road maintenance No current management decision provided Limited (4)

Visual resource 

management

Class III Class III Class III Class II

(parking lot – Class III)

Plant collecting No current management decision provided Not allowed Allowed (3)

Fluid Mineral leasing Closed to oil and gas leasing, exploration and development. 

Locatable minerals Closed and withdrawn from mineral entry. Closed and continue withdrawal from mineral entry.

Solid leasable minerals Closed and withdrawn from mineral entry. Closed and continue withdrawal from mineral entry.

Mineral materials sales 

and permits

Not allowed

Renewable energy No current management decision provided Closed (6)

Geophysical exploration 

for oil and gas

Not allowed

Use of explosives for 

geophysical exploration 

for oil and gas

Not allowed

Fire suppression Appropriate management response to wildfire 

would be aggressive fire suppression. 

Appropriate response would include use of 

natural barriers and hand constructed fire lines. 

Use of bulldozers and retardant avoided unless 

Fire suppression would include use of natural barriers and hand constructed fire lines. Use of heavy 

equipment and retardant would be avoided unless approved by the authorized officer. No heavy 

equipment use near vision quest site, no retardant use within 100 feet of Will James cabin or rock art. 

Full range of fire management activities would be used in remainder of ACEC.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-213

Table 2-12 Detailed Table of Alternatives: Special Designations

Four Dances Natural Area ACEC

Record# Management Activity Alternative A (784 acres) Alternative B (784 acres) Alternative C (784 acres) Alternative D (784 acres)

approved by the authorized officer.

Fuels management Prescribed fire would be used to reduce 

hazardous fuels and meet other resource 

objectives.

Allowed only during favorable smoke dispersal 

conditions with stable atmospheric conditions.

Allowed (5) (8) Same as B

Fuel wood cutting/wood 

product sales

Wood product sales permits would not be 

issued. Commercial timber harvest not 

allowed. 

Timber management for the safety and 

enhancement of other values would be 

practiced in the woody draws, on the islands, 

and along the Yellowstone River bottom

Not allowed Wood product sales and commercial timber harvest would not be 

allowed. 

Timber management for the safety and enhancement of other values 

would be allowed in the woody draws, on the islands, and along the 

Yellowstone River bottom.

Livestock grazing Only authorized to meet other resource 

objectives consistent with ACEC designation. 

Grazing must meet Standard and Guidelines.

Buffalo grazing not permitted.

Buffalo grazing not permitted. 

Livestock grazing would be allowed. Only authorized to meet other resource objectives consistent with 

ACEC designation. Grazing must meet Standard and Guidelines. (7)

Range improvements No current management decision provided. Not allowed Allowed if no conflicts with ACEC objectives (5)

Noxious/Invasive weed 

treatments

Treatments may include any combination of 

herbicide application, burning, grazing, and the 

use of insects or pathogens. The use of 

chemicals would be minimized.

Allowed (5) (10)

Animal 

trapping/traplines

No current management decision provided. Not allowed

Hunting/target shooting No discharging of firearms. Archery hunting may be allowed, if deemed necessary by Montana Fish, Wildlife, and Parks (authorization from BLM required).

Cremains scattering No current management decision provided. Not allowed

Special Recreation 

Permits and letters of 

authorization

Authorizations would be required or timing and 

locations would be specified for events, such 

as cross country races.

Some limitations on use by the general public 

may be required to facilitate Native American 

religious activities. These would be limited to 

specific time periods and specific portions of 

the property.

Not allowed Allowed (5)

Authorizations would be required or timing and locations would be 

specified for events, such as cross country races.

Some limitations on use by the general public may be required to 

facilitate Native American religious activities. These would be limited 

to specific time periods and specific portions of the property.

SRPs would initially be limited to existing SRPs. Additional (new) 

SRPs would be permitted only when determined not to result in 

impacts to the values for which the ACEC was designated.

Other permitted 

activities

No current management decision provided Not allowed Allowed (5)

Transportation No current management decision provided No new roads No increase in road density

Recreation Day use area only Same as A Day use area only
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-214 Chapter 2: Resource Management Alternatives

Table 2-12 Detailed Table of Alternatives: Special Designations

Four Dances Natural Area ACEC

Record# Management Activity Alternative A (784 acres) Alternative B (784 acres) Alternative C (784 acres) Alternative D (784 acres)

Closed to horseback riding, use of fireworks, 

hang gliding, rock climbing, paint ball, 

discharging of fire arms, and exercising pets off 

leash

Closed to horseback riding (with the exception of authorized Native 

American religious ceremonies), hang gliding, rock climbing, paint 

ball, and discharging of fire arms. 

Pets must be leashed within parking area.

Wildlife Special management and priority would be given to protecting falcon eyries by restricting human activity along the rims that might adversely affect the 

nesting birds. Non-ACEC values may be adjusted as necessary.

Geocaching Allowed Not allowed (11)

Other management 

activities

No current management decision provided Other management activities and/or uses would be considered in subsequent site-specific analysis, and 

would consider the values for which the ACEC is designated (5).

Notes: (Map 159 and 181)

1 Avoidance area; granting Rights-of-Way (surface, subsurface, aerial) within the area should be avoided, but rights-of-way may be granted if there is minimal or no conflict with identified resource values and impacts to 

ACEC resource values can be fully mitigated.

2 Off-highway vehicle, and bicycle, use would be limited to designated routes.

3 Commercial collection of plant materials, including common species, authorized by permit only. Casual use allowed.

4 Road maintenance will be limited to the designated roadway and only that necessary to ensure public safety and serviceability of the road.

5 The activity is allowed in the area on a case-by-case basis and only if there is minimal or no conflict with identified resources values and impacts to ACEC resource values can be fully mitigated. Additional NEPA 

analysis required. Cultural inventories will be required for surface disturbing activities. Native American coordination/consultation required on activities within ACEC (especially if cultural resources are one of the 

values for ACEC designation).

6 Closed to renewable energy facilities and renewable energy development.

7 Livestock grazing will be controlled through terms and conditions on the grazing permit.

8 Evaluate fire potential and remove fuels where needed to protect resource values and meet the objectives of the ACEC. Types of treatments permitted: prescribed fire throughout ACEC allowed, handcutting/chainsaw 

use preferred around rock art sites.

9 Open to mineral material activities on a case-by-case basis and subject to controlled surface use, seasonal timing restrictions, restricted or no uses in avoidance areas (e.g. riparian areas, areas with special wildlife or 

plant features, areas of high cultural significance, and sensitive viewsheds), and additional NEPA analysis required. 

10 Treatments may include any combination of herbicide application, mechanical treatments, burning, grazing, and the use of insects or pathogens. 

11 If geocache location/activity does not conflict with the resource values of the ACEC, this activity could be considered. BLM resource specialists (archaeologist and wildlife biologist) and BLM ORP must agree activity 

does not impact ACEC values.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-215

Table 2-12 Detailed Table of Alternatives: Special Designations

Grove Creek ACEC

Record# Management Activity Alternative A (No ACEC Designation) Alternative B (8,251 acres) Alternative C (9,445 acres) Alternative D (8,251 acres)

Grove Creek ACEC – Desired Outcomes (Goals and Objectives)

The Grove Creek ACEC would be managed to protect significant archaeological and traditional cultural values and special status plants. (Maps 182, 182)

Grove Creek ACEC – Management Actions by Alternative

Land use authorization Allowed Exclusion area Avoidance (1) Avoidance (1)

Land tenure Land adjustments (acquisitions, exchanges, 

disposals) subject to existing land tenure criteria.

Category I retention land: no land disposal would occur

Off-highway vehicle use Limited to existing roads and trails Limited to designated routes (refer to Grove Creek TMA). 

BLM road maintenance No current management decision provided Limited (4)

Visual resource 

management

Class III Class III Class III Class III

Plant collecting Allowed Allowed (3) Allowed Same as B

Fluid Mineral leasing Open, subject to standard stipulations Closed to oil and gas leasing, 

exploration and development (NL). 

COAs for existing leases

NSO. Conditions of Approval for existing leases

Locatable minerals Open Recommend withdrawal from mineral 

entry and location under the Mining 

Law of 1872, as amended. Subject to 

valid existing rights.

Open Same as B

Solid leasable minerals Open Closed and recommend withdrawing 

from mineral entry

Open (5) Same as B

Mineral materials sales 

and permits

Allowed Not allowed Allowed (9)

Renewable energy Open Closed (6)

Geophysical exploration 

for oil and gas

Allowed Not allowed Allowed (5)

Use of explosives for 

geophysical exploration 

for oil and gas

Allowed Not allowed

Fire suppression Full suppression Wildfire management (natural ignitions) 

for resource benefit. Full range of fire 

management activities would be used 

in ACEC in response to human-ignited 

fires. No heavy equipment use within 

ACEC.

No heavy equipment use within 

ACEC; full range of fire management 

activities would be used in response 

to human-ignited fires.

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.

Fuels management Allowed Allowed (8)

Fuel wood cutting Allowed Not allowed Allowed if no conflicts with ACEC values (5)
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-216 Chapter 2: Resource Management Alternatives

Table 2-12 Detailed Table of Alternatives: Special Designations

Grove Creek ACEC

Record# Management Activity Alternative A (No ACEC Designation) Alternative B (8,251 acres) Alternative C (9,445 acres) Alternative D (8,251 acres)

Wood product sales Allowed Not allowed Allowed if no conflicts with ACEC values (5)

Livestock grazing Available Available (7)

Range improvements Allowed Not allowed Allowed if no conflicts with ACEC values (5)

Noxious/Invasive weed 

treatments

Allowed Allowed (5) (10)

Herbicide applications would be by hand, not by boom or aerial in order to protect special status plants

Animal 

trapping/traplines

Allowed Not allowed Same as A

Target shooting Allowed Not allowed Same as A

Cremains scattering Allowed Not allowed Allowed (5) Same as B

Special Recreation 

Permits and letters of 

authorization

Allowed Not allowed Allowed (5)

SRPs would initially be limited to existing SRPs. Additional (new) 

SRPs would be permitted only when determined not to result in 

impacts to the values for which the ACEC was designated.

Other permitted 

activities

Allowed Not allowed Allowed (5)

Transportation Open No increase in road density New routes for commercial or other 

BLM authorized activities may be 

considered if the route meets public 

access needs.

Same as B

Geocaching Allowed Not allowed (11)

Other management 

activities

No current management decision provided Other management activities and/or uses would be considered in subsequent site-specific analysis, and would 

consider the values for which the ACEC is designated (5).

Notes: (Map 159 and 182, 183) 

1 Avoidance area; granting Rights-of-Way (surface, subsurface, aerial) within the area should be avoided, but rights-of-way may be granted if there is minimal or no conflict with identified resource values and impacts to 

ACEC resource values can be fully mitigated. 

2 Off-highway vehicle, and bicycle, use would be limited to designated routes only 

3 Commercial collection of plant materials, including common species, authorized by permit only. Casual use allowed. 

4 Road maintenance will be limited to the designated roadway; shoulder barrow/ditch construction will be limited to only that necessary to ensure public safety and serviceability of the road. 

5 The activity is allowed in the area on a case-by-case basis and only if there is minimal or no conflict with identified resources values and impacts to ACEC resource values can be fully mitigated. Additional NEPA 

analysis required. Cultural inventories will be required for surface disturbing activities. Native American coordination/consultation required on activities within ACEC (especially if cultural resources are one of the values 

for ACEC designation). 

6 Closed to renewable energy facilities and renewable energy development 

7 Livestock grazing will be controlled through terms and conditions on the grazing permit. 

8 Evaluate fire potential and remove fuels where needed to protect resource values and meet the objectives of the ACEC. Types of treatments permitted: hand cutting, chainsaw, mechanical, prescribed fire. 

9 Open to mineral material activities on a case-by-case basis and subject to controlled surface use, seasonal timing restrictions, restricted or no uses in avoidance areas (e.g. riparian areas, areas with special wildlife or 

plant features, areas of high cultural significance, and sensitive viewsheds), and additional NEPA analysis required. 

10 Treatments may include any combination of herbicide application, mechanical treatments, burning, grazing, and the use of insects or pathogens. 

11 If geocache location/activity does not conflict with the resource values of the ACEC, this activity could be considered. BLM resource specialists (archaeologist and botanist) and BLM ORP must agree activity does not 

impact ACEC values.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-217

Table 2-12 Detailed Table of Alternatives: Special Designations

Meeteetse Spires ACEC

Record# Management Activity Alternative A (965 acres) Alternative B (1,523 acres) Alternative C (2,173 acres) Alternative D (1,523 acres)

Meeteetse Spires ACEC – Desired Outcomes (Goals and Objectives)

The Meeteetse Spires ACEC would be managed to protect and enhance unique vegetation (rare plants) and conserve scenic values. (Maps 184, 185, 186)

Meeteetse Spires ACEC – Management Common to All Alternatives

Consider acquiring minerals from willing sellers for the ACEC.

Meeteetse Spires ACEC – Management Actions by Alternative

Land use authorization Exclusion area

Land tenure No current management decision provided Category I retention land: no land disposal would occur

Off-highway vehicles Limited to existing roads and trails Designated routes (refer to Grove Creek TMA)

BLM road maintenance No current management decision provided Not allowed Limited (4) Same as B

Visual resource 

management

Class II

Plant collecting No current management decision provided Allowed for scientific use or range/forestry studies. No collection of special status species without a permit.

Fluid Mineral leasing Closed (NL) Closed (NL) (original ACEC – 965 acres)

Manage remainder of ACEC for no surface occupancy (no federal minerals)

Locatable minerals Closed and recommended for withdrawal Recommend withdrawal from mineral entry and location under the Mining Law of 1872, as amended. Subject to 

valid existing rights. (original ACEC – 965 acres).

Remainder of ACEC would be Open (no federal minerals)

Solid leasable minerals Open Open (5)

Mineral materials sales 

and permits

Not allowed Not allowed Allowed (9) 

Renewable energy No current management decision provided Closed (6)

Geophysical exploration Not allowed in the special status plant areas, 

on the remaining area, exploration access by 

air only. Shot holes and above ground shots 

only. No vibroseis.

Not allowed Same as A Same as B

Use of explosives for 

geophysical exploration 

for oil and gas

Not allowed

Fire suppression Conditional suppression Wildfire management (natural ignitions) for 

resource benefit. Full range of fire 

management activities would be used in 

ACEC in response to human-ignited fires. 

No heavy equipment use within ACEC.

Full range of fire management activities 

would be used in remainder of ACEC 

Same as B

Fuels management No current management decision provided Allowed (8)

Fuel wood cutting Not allowed Not allowed

Wood product sales Select timber harvest allowed periodically to

protect resource values. Wood product sales 

not allowed.

Not allowed Allowed if no conflicts with ACEC values (5)
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-218 Chapter 2: Resource Management Alternatives

Table 2-12 Detailed Table of Alternatives: Special Designations

Meeteetse Spires ACEC

Record# Management Activity Alternative A (965 acres) Alternative B (1,523 acres) Alternative C (2,173 acres) Alternative D (1,523 acres)

Livestock grazing Livestock grazing permitted, except for sheep Closed Livestock grazing permitted, except for sheep on 965 acres (original 

ACEC -). The 558 acre acquisition is not suitable for livestock 

grazing.

Range improvements Allowed Not allowed Allowed if no conflicts with ACEC values (5)

Noxious/Invasive weed 

treatments

Allowed Allowed (5) (10)

Herbicide applications would be by hand, not by boom or aerial in order to protect special status plants

Animal trapping/traplines No current management decision provided Allowed

Target shooting No current management decision provided Allowed

Cremains scattering No current management decision provided Not allowed

Special Recreation 

Permits and letters of 

authorization

Allowed Not allowed Allowed (5)

SRPs would initially be limited to existing SRPs. Additional (new) 

SRPs would be permitted only when determined not to result in 

impacts to the values for which the ACEC was designated.

Other permitted activities Allowed Not allowed Allowed (5)

Transportation No current management decision provided No net increase in road density

Geocaching Allowed Not allowed (11)

Other management 

activities

No current management decision provided Other management activities and/or uses would be considered in subsequent site-specific analysis, and would 

consider the values for which the ACEC is designated (5).

Notes: (Map 159 and 184, 185, 186)

1 Avoidance area; granting rights-of-way (surface, subsurface, aerial) within the area should be avoided, but rights-of-ways may be granted if there is minimal or no conflict with identified resource values and impacts to 

ACEC resource values can be fully mitigated.

2 Off-highway vehicle, and bicycle, use would be limited to designated routes only.

3 Commercial collection of plant materials, including common species, authorized by permit only. Casual use allowed.

4 Road maintenance will be limited to the designated roadway; and only that necessary to ensure public safety and serviceability of the road.

5 The activity is allowed in the area on a case-by-case basis and only if there is minimal or no conflict with identified resources values and impacts to ACEC resource values can be fully mitigated. Additional NEPA analysis 

required. Cultural inventories will be required for surface disturbing activities. Native American coordination/consultation required on activities within ACEC (especially if cultural resources are one of the values for ACEC 

designation).

6 Closed to renewable energy facilities and renewable energy development

7 Livestock grazing will be controlled through terms and conditions on the grazing permit.

8 Evaluate fire potential and remove fuels where needed to protect resource values and must meet objectives of ACEC. Types of treatments permitted: hand cutting, chainsaw, mechanical, prescribed and non-surface 

disturbing treatments.

9 Open to mineral material activities on a case-by-case basis and subject to controlled surface use, seasonal timing restrictions, restricted or no uses in avoidance areas (e.g. riparian areas, areas with special wildlife or 

plant features, areas of high cultural significance, and sensitive viewsheds), and additional NEPA analysis required. 

10 Treatments may include any combination of herbicide application, mechanical treatments, burning, grazing, and the use of insects or pathogens.

11 If geocache location/activity does not conflict with the resource values of the ACEC, this activity could be considered. BLM resource specialist (botanist) and BLM ORP must agree activity does not impact ACEC values.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-219

Table 2-12 Detailed Table of Alternatives: Special Designations

Petroglyph Canyon ACEC

Record# Management Activity Alternative A (240 acres) Alternative B (240 acres) Alternative C (240 acres) Alternative D (240 acres)

Desired Future Conditions (Goals and Objectives)

The Petroglyph Canyon ACEC would be managed to protect unique cultural values. 

Management Actions by Alternative

Land use authorization Exclusion Area

Land tenure No current management decision provided Category I retention land: no land disposal would occur

Off-highway vehicle use Closed to vehicle use Designated routes only (refer to Pryor 

TMA)

Designated routes only (refer to 

Pryor TMA)

Designated routes only (refer to 

Pryor TMA)

BLM road maintenance No current management decision provided Limited (4)

Visual resource 

management

Class IV Class II Class III Class II

Plant collecting Allowed Not allowed Allowed (3)

Fluid Mineral leasing Closed (NL) NSO (no WEMs) Closed (NL)

Locatable minerals Closed and withdrawn from mineral entry Closed and continue withdrawal from mineral entry

Solid leasable minerals No current management decision provided Closed Open with NSO (5) Same as B

Mineral materials sales 

and permits

No current management decision provided Not allowed Allowed (9) Same as B

Renewable energy No current management decision provided Closed (6)

Geophysical exploration 

for oil and gas

Not allowed

Use of explosives for 

geophysical exploration 

for oil and gas

No current management decision provided Not allowed

Fire suppression No current management decision provided No heavy equipment use, no retardant or foam use; 

Fuels management No current management decision provided Allowed (8)

Fuel wood cutting/wood 

product sales

Not allowed

Livestock grazing Allowed Available (7)

Range improvements Allowed Not allowed Allowed if no conflicts with ACEC values (5)

Noxious/Invasive weed 

treatments

No current management decision provided Allowed (5) (10)

Animal 

trapping/traplines

No current management decision provided Not allowed Allowed Same as B

Target shooting No current management decision provided Not allowed
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-220 Chapter 2: Resource Management Alternatives

Table 2-12 Detailed Table of Alternatives: Special Designations

Petroglyph Canyon ACEC

Record# Management Activity Alternative A (240 acres) Alternative B (240 acres) Alternative C (240 acres) Alternative D (240 acres)

Cremains scattering No current management decision provided Not allowed

Special Recreation 

Permits and letters of 

authorization

No current management decision provided Not allowed Allowed (5) Allowed (5)

SRPs would initially be limited to 

existing SRPs. Additional (new) 

SRPs would be permitted only 

when determined not to result in 

impacts to the values for which 

the ACEC was designated.

Other permitted 

activities

No current management decision provided Not allowed Allowed (5)

Transportation No current management decision provided No net increase in road density

Geocaching Allowed Not allowed (11)

Other management 

activities

No current management decision provided Other management activities and/or uses would be considered in subsequent site-specific analysis, and would 

consider the values for which the ACEC is designated (5).

Notes: (Map 159 and 187)

1 Avoidance area; granting Rights-of-Way (surface, subsurface, aerial) within the area should be avoided, but rights-of-way may be granted if there is minimal or no conflict with identified resource values and impacts to 

ACEC resource values can be fully mitigated.

2 Off-highway vehicle, and bicycle, use would be limited to designated routes only.

3 Commercial collection of plant materials, including common species, authorized by permit only. Casual use allowed. 

4 Road maintenance will be limited to the designated roadway; and only that necessary to ensure public safety and serviceability of the road.

5 The activity is allowed in the area on a case-by-case basis and only if there is minimal or no conflict with identified resources values and impacts to ACEC resource values can be fully mitigated. Additional NEPA 

analysis required. Cultural inventories will be required for surface disturbing activities. Native American coordination/consultation required on activities within ACEC (especially if cultural resources are one of the values 

for ACEC designation).

6 Closed to renewable energy facilities and renewable energy development

7 Livestock grazing will be controlled through terms and conditions on the grazing permit.

8 Evaluate fire potential and remove fuels where needed to protect resource values and meet the objectives of the ACEC. Types of treatments permitted: hand cutting and chainsaw use only.

9 Open to mineral material activities on a case-by-case basis and subject to controlled surface use, seasonal timing restrictions, restricted or no uses in avoidance areas (e.g. riparian areas, areas with special wildlife or 

plant features, areas of high cultural significance, and sensitive viewsheds), and additional NEPA analysis required. 

10 Treatments may include any combination of herbicide application, mechanical treatments, burning, grazing, and the use of insects or pathogens.

11 If geocache location/activity does not conflict with the resource values of the ACEC, this activity could be considered. BLM resource specialist (archaeologist) and BLM ORP must agree activity does not impact ACEC 

values.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-221

Table 2-12 Detailed Table of Alternatives: Special Designations

Pryor Foothills Research Natural Area (RNA) ACEC

Record# Management Activity Alternative A (No ACEC) Alternative B (958 acres) Alternative C (7,401 acres) Alternative D (2,606 acres)

Pryor Foothills Research Natural Area ACEC – Desired Outcomes (Goals and Objectives)

The Pryor Foothills Research Natural Area ACEC would be managed to protect unique vegetation (a large concentration of Bureau special status plant species and rare plant communities) and to 

protect significant historic and cultural values in the Gyp Springs area. 

The objectives of the BLM RNA program are: 1) to preserve examples of all significant natural ecosystems for comparison with those influenced by man; 2) to provide educational and research areas 

for ecological and environmental studies; and 3) to preserve gene pools of typical and endangered plants and animals. Research natural areas are intended to represent the full array of North 

American ecosystems with their biological communities, habitats, natural phenomena, and geological and hydrological formations.

Pryor Foothills Research Natural Area ACEC – Management Actions by Alternative

Land use authorization Allowed Exclusion Area Avoidance (1), subject to valid existing rights.

Land tenure Land adjustments subject to existing land 

tenure criteria.

Category I retention land: no land disposal would occur

Off-highway vehicles Limited to designated routes (refer to Pryors 

TMA)

Limited to designated routes (refer to 

Pryors TMA)

Limited to designated routes (refer to

Pryors TMA)

Limited to designated routes 

(refer to Pryors TMA)

BLM road maintenance Allowed Limited (4)

Visual resource 

management

Class III Class III 839 acres – Class II (overlap w/ 

LWC unit)

Class III - remaining portions 

of ACEC

Plant collecting Allowed Not allowed Allowed for scientific use or 

range/forestry studies. No collection 

of special status species without a 

permit.

Same as C

Fluid Mineral leasing Open Closed (NL) No surface occupancy (NSO) on 

known plant sites. Inventory prior to 

surface disturbing activities (CSU).

NSO - 1⁄4 mile buffer on known 

sensitive plant sites (acres). 

CSU - Inventory prior to 

surface disturbing activities.

(Note: All lands in this ACEC east 

of Crooked Creek Rd (839 acres)

are within a lands w/ wilderness 

characteristics unit and are No 

Lease)

Locatable minerals Open Recommend withdrawal from mineral 

entry and location under the Mining Law 

of 1872, as amended. Subject to valid 

existing rights.

Open - Inventory prior to surface 

disturbing activities (CSU).

Same as B

Solid leasable minerals Open Closed, subject to valid existing rights Open (5)- Inventory prior to surface 

disturbing activity CSU

Same as B

Mineral materials sales 

and permits

Allowed Not allowed Allowed (9) Same as B

Renewable energy No current management decision provided Closed (6) Open (5) Same as B

Geophysical exploration Allowed Not allowed Allowed (5) Same as B

Fire suppression Allowed Wildfire management (natural ignitions) 

for resource benefit. Full range of fire 

Full range of fire management 

activities would be used in ACEC. 

Same as B
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-222 Chapter 2: Resource Management Alternatives

Table 2-12 Detailed Table of Alternatives: Special Designations

Pryor Foothills Research Natural Area (RNA) ACEC

Record# Management Activity Alternative A (No ACEC) Alternative B (958 acres) Alternative C (7,401 acres) Alternative D (2,606 acres)

management activities would be used in 

ACEC in response to human-ignited fires. 

No heavy equipment use within ACEC.

Fuels management Allowed Allowed (8)

Fuel wood cutting/wood 

product sales

No current management decision provided Not allowed Allowed (5) periodically to protect resource values. 

Livestock grazing Permitted Available (7)

Range improvements Allowed No improvements would be allowed that 

would result in a net increase of livestock 

use in the ACEC (5)

Same as A Same as B

Noxious/Invasive weed 

treatments

Allowed Allowed (5) (10) to protect rare plant values

Herbicide applications would be by hand, not by boom or aerial in order to protect special status plants

Animal 

trapping/traplines

Allowed

Target shooting Allowed Not allowed Allowed

Cremains scattering No current management decision provided Not allowed

Special Recreation 

Permits and letters of 

authorization

Allowed Not allowed Allowed (5)

SRPs would initially be limited to existing SRPs. Additional (new) 

SRPs would be permitted only when determined not to result in 

impacts to the values for which the ACEC was designated.

Other permitted 

activities

Allowed Not allowed Allowed (5)

Transportation No current management decision provided No new road or trail development. No increase in road density. 

Geocaching Allowed Not allowed (11)

Other management 

activities

No current management decision provided Other management activities and/or uses would be considered in subsequent site-specific analysis, and would 

consider the values for which the ACEC is designated (5).

Notes: (Map 159 and 188, 189, 190)

1 Avoidance area; granting Rights-of-Way (surface, subsurface, aerial) within the area should be avoided, but rights-of-way may be granted if there is minimal or no conflict with identified resource values and impacts to ACEC resource 

values can be fully mitigated.

2 Off-highway vehicle, and bicycle, use would be limited to designated roads and trails only

3 Commercial collection of plant materials, including common species, authorized by permit only. Casual use allowed.

4 Road maintenance will be limited to the designated roadway; and only that necessary to ensure public safety and serviceability of the road.

5 The activity is allowed in the area on a case-by-case basis and only if there is minimal or no conflict with identified resources values and impacts to ACEC resource values can be fully mitigated. Additional NEPA analysis required. 

Cultural inventories will be required for surface disturbing activities. Native American coordination/consultation required on activities within ACEC (especially if cultural resources are one of the values for ACEC designation).

6 Closed to renewable energy facilities and renewable energy development

7 Livestock grazing will be controlled through terms and conditions on the grazing permit.

8 Evaluate fire potential and remove fuels where needed to protect resource values and meet objectives of the ACEC. Types of treatments permitted include: prescribed fire, hand-cutting, chainsaws, mechanical and non-surface 

disturbing treatments.

9 Open to mineral material activities on a case-by-case basis and subject to controlled surface use, seasonal timing restrictions, restricted or no uses in avoidance areas (e.g. riparian areas, areas with special wildlife or plant features, 

areas of high cultural significance, and sensitive viewsheds), and additional NEPA analysis required. 

10 Treatments may include any combination of herbicide application, mechanical treatments, burning, grazing, and the use of insects or pathogens.

11 If geocache location/activity does not conflict with the resource values of the ACEC, this activity could be considered. BLM resource specialists (botanist and archaeologist) and BLM ORP must agree activity does not impact ACEC 

values.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-223

Table 2-12 Detailed Table of Alternatives: Special Designations

Stark Site ACEC

Record# Management Activity Alternative A (799 acres) Alternative B (799 acres) Alternative C (799 acres) Alternative D (799 acres)

Stark Site ACEC – Desired Outcomes (Goals and Objectives)

The Stark Site ACEC would be managed to protect unique cultural values.

Stark Site ACEC – Management Actions by Alternative

Land use authorization Exclusion area Exclusion area Avoidance (1) Avoidance (1)

Land tenure No current management decision provided Category I retention land: no land disposal would occur

Off-highway vehicle use Limited to existing roads and trails Motorized travel limited to designated 

routes (refer to Horsethief TMA)

Motorized travel limited to 

designated routes (refer to 

Horsethief TMA)

Motorized travel limited to 

designated routes (refer to 

Horsethief TMA)

BLM road maintenance No current management decision provided Limited (4)

Visual resource 

management

Class III Class II

Plant collecting Allowed Allowed (3)

Fluid Mineral leasing NSO

Locatable minerals Open Recommend withdrawal from mineral 

entry and location under the Mining 

Law of 1872, as amended. Subject to 

valid existing rights.

Open Same as B

Solid leasable minerals No current management decision provided Closed Open (5) with NSO 

Mineral materials sales 

and permits

Not allowed Not allowed Allowed (9) Same as B

Renewable energy No current management decision provided Closed (6)

Geophysical exploration 

for oil and gas

Not allowed on the significant cultural 

resource sites, but allowed in other areas of 

ACEC (surface and vibroseis only)

Not allowed Same as A Same as B

Use of explosives for 

geophysical exploration 

for oil and gas

No current management decision provided Not allowed

Fire suppression Conditional fire suppression No heavy equipment use, no retardant or foam use.

Fuels management No current management decision provided Allowed (8)

Fuel wood cutting/wood

product sales

Not allowed

Livestock grazing Allowed Available (7)

Range improvements Allowed Not allowed Allowed if no conflicts with ACEC values (5)
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-224 Chapter 2: Resource Management Alternatives

Table 2-12 Detailed Table of Alternatives: Special Designations

Stark Site ACEC

Record# Management Activity Alternative A (799 acres) Alternative B (799 acres) Alternative C (799 acres) Alternative D (799 acres)

Noxious/Invasive weed 

treatments

No current management decision provided Allowed (5) (10)

Animal trapping/traplines No current management decision provided Not allowed Allowed

Target shooting No current management decision provided Not allowed Allowed Same as B

Cremains scattering No current management decision provided Not allowed

Special Recreation 

Permits and letters of 

authorization

Allowed(5) Not allowed Allowed (5) Allowed (5)

SRPs would initially be limited to 

existing SRPs. Additional (new) 

SRPs would be permitted only 

when determined not to result in 

impacts to the values for which 

the ACEC was designated.

Other permitted activities Allowed, case-by-case basis Not allowed Allowed (5)

Transportation Limited to existing roads and trails No new road or trail development. No increase in road density. 

Geocaching Allowed Not allowed (11)

Other management 

activities

No current management decision provided Other management activities and/or uses would be considered in subsequent site-specific analysis, and would 

consider the values for which the ACEC is designated (5).

Notes: (Map 159 and 191)

1 Avoidance area; granting Rights-of-Way (surface, subsurface, aerial) within the area should be avoided, but rights-of-way may be granted if there is minimal or no conflict with identified resource values and impacts to 

ACEC resource values can be fully mitigated.

2 Off-highway vehicles, and bicycles, use would be limited to designated routes only

3 Commercial collection of plant materials, including common species, authorized by permit only. Casual use allowed.

4 Road maintenance will be limited to the designated roadway; and only that necessary to ensure public safety and serviceability of the road.

5 The activity is allowed in the area on a case-by-case basis and only if there is minimal or no conflict with identified resources values and impacts to ACEC resource values can be fully mitigated. Additional NEPA 

analysis required. Cultural inventories will be required for surface disturbing activities. Native American coordination/consultation required on activities within ACEC (especially if cultural resources are one of the values 

for ACEC designation).

6 Closed to renewable energy facilities and renewable energy development

7 Livestock grazing will be controlled through terms and conditions on the grazing permit.

8 Evaluate fire potential and remove fuels where needed to protect resource values and meet the ACEC values. Types of treatments permitted: hand cutting & chainsaw use. Other types of treatment (mechanical or 

prescribed) would be allowed if treatment meets objectives of ACEC.

9 Open to mineral material activities on a case-by-case basis and subject to controlled surface use, seasonal timing restrictions, restricted or no uses in avoidance areas (e.g. riparian areas, areas with special wildlife or 

plant features, areas of high cultural significance, and sensitive viewsheds), and additional NEPA analysis required. 

10 Treatments may include any combination of herbicide application, mechanical treatments, burning, grazing, and the use of insects or pathogens.

11 If geocache location/activity does not conflict with the resource values of the ACEC, this activity could be considered. BLM resource specialist (archaeologist) and BLM ORP must agree activity does not impact ACEC 

values.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-225

Table 2-12 Detailed Table of Alternatives: Special Designations

Weatherman Draw ACEC

Record# Management Activity Alternative A (4,365 acres) Alternative B (4,986 acres) Alternative C (12,277 acres) Alternative D (12,277 acres)

Desired Outcomes (Goals and Objectives)

The Weatherman Draw ACEC would be managed to protect unique cultural values.

Management Actions by Alternative

Land use authorization Exclusion area, ROWs associated with valid 

existing oil or gas lease rights allowed with 

restrictions. 

Exclusion area, subject to valid 

existing rights.

ROW exclusion area, subject to valid 

existing rights (1) (4,986 acres)

Remainder of ACEC: Avoidance 

area (1) (7,291 acres)

Same as C

Land Tenure No current management decision provided Category I retention land: no land disposal would occur

Off-highway vehicle use Limited to authorized use only Limited to designated routes (refer to 

Weatherman Draw TMA)

Limited to designated routes (refer to 

Weatherman Draw TMA)

Limited to designated routes (refer 

to Weatherman Draw TMA)

BLM road maintenance No current management decision provided Limited (4)

Visual resource 

management

Class II Class II Class II: 4,986 acres

Class III: 7,291 acres

Class II

Plant collecting Open Not allowed Allowed (3)

Fluid Mineral leasing NSO (with no waiver, exception, or 

modification provisions)

Closed (NL) NSO (5) Closed (NL) (4,986 acres).

NSO (5) (7,291 acres) 

Locatable minerals 600 acres closed and withdrawn from mineral 

entry

600 acres closed and continue to 

recommend withdrawal from mineral 

entry

Recommend withdrawal from mineral 

entry and location under the Mining 

Law of 1872, as amended. Subject to 

valid existing rights. (4,386 acres)

600 acres closed and continue to 

recommend withdrawal from mineral 

entry 

Open (5) (11,677 acres)

600 acres withdrawn from mineral 

entry 

Recommend withdrawal from 

mineral entry and location under the 

Mining Law of 1872, as amended. 

Subject to valid existing rights. 

(4,386 acres)

Open (5) (7,291 acres)

Solid leasable minerals No current management decision provided Closed Open (5) with NSO Closed from mineral entry (4,986 

acres)

Open (5) with NSO (7,291 acres)

Mineral materials sales 

and permits

Not allowed Not allowed Not allowed (4,986 acres)

Allowed (7,291 acres) (9)

Same as C

Renewable energy No current management decision provided Closed (6)

Geophysical exploration 

for oil and gas

Not allowed

Fire suppression Conditional fire suppression Wildfire management (natural 

ignitions) for resource benefit. 

Full range of fire management 

activities would be used in ACEC in 

response to human-ignited fires. 

No heavy equipment, no retardant or 

foam use

Full range of fire management 

activities would be used in ACEC

Same as B
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-226 Chapter 2: Resource Management Alternatives

Table 2-12 Detailed Table of Alternatives: Special Designations

Stark Site ACEC

Record# Management Activity Alternative A (799 acres) Alternative B (799 acres) Alternative C (799 acres) Alternative D (799 acres)

Fuels management No current management decision provided Fuels removed where there would be threat or loss of resource (8)

Fuel wood cutting/wood 

product sales

Not allowed Not allowed: (4,986 acres)

Allowed by permit only (7,291 acres)

Livestock grazing Allowed Available (7) Same as B

Range improvements Allowed if no conflicts with ACEC values Not allowed Allowed if no conflicts with ACEC values (5)

Noxious/Invasive weed 

treatments

No current management decision provided Allowed (5) (10)

Animal 

trapping/traplines

No current management decision provided Not allowed Allowed Not allowed (4,986 acres)

Allowed: (7,291 acres)

Target shooting No current management decision provided Not allowed

Cremains scattering No current management decision provided Not allowed

Special Recreation 

Permits and letters of 

authorization

Open Not allowed Allowed (5) Allowed (5)

SRPs would initially be limited to 

existing SRPs. Additional (new) 

SRPs would be permitted only when 

determined not to result in impacts 

to the values for which the ACEC 

was designated.

Other permitted 

activities

Allowed Not allowed Allowed (5)

Transportation No current management decision provided No net increase in road density

Geocaching Allowed Not allowed (11)

Other management 

activities

No current management decision provided Other management activities and/or uses would be considered in subsequent site-specific analysis, and would 

consider the values for which the ACEC is designated (5).

Notes: (Map 159 and 192, 193, 194) 

1 Avoidance area; granting Rights-of-Way (surface, subsurface, aerial) within the area should be avoided, but rights-of-way may be granted if there is minimal or no conflict with identified resource values and impacts to ACEC resource values can be 

fully mitigated. 

2 Off-highway vehicles, and bicycles, use would be limited to designated routes only. 

3 Commercial collection of plant materials, including common species, authorized by permit only. Casual use allowed. 

4 Road maintenance will be limited to the designated roadway and only that necessary to ensure public safety and serviceability of the road. 

5 The activity is allowed in the area subject to specific environmental analysis upon individual permit applications and only if there is minimal or no conflict with identified resources values and impacts to ACEC resource values can be fully mitigated. 

Additional NEPA analysis required. Cultural inventories will be required for surface disturbing activities. Native American coordination/consultation required on activities within ACEC (especially if cultural resources are one of the values for ACEC 

designation). 

6 Closed to renewable energy facilities and renewable energy development 

7 Livestock grazing will be controlled through terms and conditions on the grazing permit. 

8 Evaluate fire potential and remove fuels where needed to protect resource values. Types of treatments permitted: hand cutting/chainsaw only around rock art sites. Mechanical thinning would be allowed on a case-by-case basis - must meet objectives 

of ACEC. 

9 Open to mineral material activities on a case-by-case basis and subject to controlled surface use, seasonal timing restrictions, restricted or no uses in avoidance areas (e.g. riparian areas, areas with special wildlife or plant features, areas of high 

cultural significance, and sensitive viewsheds), and additional NEPA analysis required. 

10 Treatments may include any combination of herbicide application, mechanical treatments, burning, grazing, and the use of insects or pathogens. 

11 If geocache location/activity does not conflict with the resource values of the ACEC, this activity could be considered. BLM resource specialist (archaeologist) and BLM ORP must agree activity does not impact ACEC values. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-227

Table 2-12 Detailed Table of Alternatives: Special Designations

Greater Sage-Grouse ACEC

Record# Management Activity Alternative A (0 acres) Alternative B (158,926 acres) Alternative C (0 acres) Alternative D (0 acres)

Desired Outcomes (Goals and Objectives)

The Greater Sage-Grouse ACEC would be managed to protect Greater Sage-Grouse priority habitat.

Management Actions by Alternative

Land use authorization Allowed Exclusion area, subject to valid 

existing rights.

Management for Greater Sage-Grouse Priority Habitat Management Areas 

(PHMAs) provided throughout alternative/document.

Land Tenure Land adjustments (acquisitions, exchanges, 

disposals) subject to existing land tenure 

criteria

Category I retention land: no land disposal would occur

Off-highway vehicle use Limited to existing roads and trails The BLM may close or restore unauthorized, user created roads and trails to prevent resource damage. 

TMAs in or partially in the ACEC would be managed to minimize impacts to Greater Sage-Grouse habitat or 

managed to protect Greater Sage-Grouse habitat

BLM road maintenance Allowed Allowed if no resource conflict Management for Greater Sage-Grouse Priority Habitat Areas (PHMAs) 

provided throughout alternative/document.

Visual resource 

management

Class II and Class III

Plant collecting Open Allowed (3) Management for Greater Sage-Grouse Priority Habitat Management Areas 

(PHMAs) provided throughout alternative/document.

Fluid Mineral leasing NSO (with no waiver, exception, or 

modification provisions)

Closed (NL) Management for Greater Sage-Grouse Priority Habitat Management Areas 

(PHMAs) provided throughout alternative/document.

Locatable minerals Open Closed and recommended for 

withdrawal

Management for Greater Sage-Grouse Priority Habitat Management Areas 

(PHMAs) provided throughout alternative/document.

Solid leasable minerals Allowed Allowed with lease stipulations Management for Greater Sage-Grouse Priority Habitat Management Areas 

(PHAs) provided throughout alternative/document.

Mineral materials sales 

and permits

Allowed Closed Management for Greater Sage-Grouse Priority Habitat Management Areas 

(PHMAs) provided throughout alternative/document.

Renewable energy Allowed Exclusion area (6) Management for Greater Sage-Grouse Priority Habitat Management Areas 

(PHMAs) provided throughout alternative/document.

Geophysical exploration 

for oil and gas

Open to oil and gas leasing and geophysical 

operations, subject to the following lease 

stipulations:

Surface occupancy and use would be 

prohibited within 0.25 miles of Greater SageGrouse leks (NSO).

Closed to future oil and gas leasing, 

exploration, and/or development and 

prohibit other surface disturbing and 

disruptive activities. 

Surface occupancy and use would be 

prohibited. 

Leases would not be renewed upon 

expiration.

Management for Greater Sage-Grouse Priority Habitat Management Areas 

(PHMAs) provided throughout alternative/document.

Fire suppression Conditional fire suppression Heavy equipment would not be used 

within 4 miles of lek sites (Greater 

Sage-Grouse nesting habitat).

Management for Greater Sage-Grouse Priority Habitat Management Areas 

(PHMAs) provided throughout alternative/document.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-228 Chapter 2: Resource Management Alternatives

Table 2-12 Detailed Table of Alternatives: Special Designations

Greater Sage-Grouse ACEC

Record# Management Activity Alternative A (0 acres) Alternative B (158,926 acres) Alternative C (0 acres) Alternative D (0 acres)

Fuels management Allowed Prescribed fire would not be allowed 

in ACEC.

Management for Greater Sage-Grouse Priority Habitat Management Areas 

(PHMAs) provided throughout alternative/document.

Fuel wood cutting/wood 

product sales

Allowed 

Livestock grazing Allowed Available (7) 

Designate those allotments within or 

containing portions of the Greater 

Sage-Grouse ACEC as management 

Category I (managed to improve 

Greater Sage-Grouse habitat and 

changes in grazing would be 

proposed should Greater SageGrouse habitat be impacted by 

grazing).

Allotments within or containing 

portions of the Greater Sage-Grouse 

ACEC would be priority Allotments for 

monitoring and evaluation.

Management for Greater Sage-Grouse Priority Habitat Management Areas 

(PHMAs) provided throughout alternative/document.

Range improvements Allowed Installation of structural range 

improvements would only be 

considered where grazing practices 

are unable to resolve the resource 

concern. Structural range 

improvements could be considered 

where necessary to facilitate the 

change in grazing management 

practices. 

Management for Greater Sage-Grouse Priority Habitat Management Areas 

(PHMAs) provided throughout alternative/document.

Noxious/Invasive weed 

treatments

Allowed Allowed (5) (10) Management for Greater Sage-Grouse Priority Habitat Management Areas 

(PHMAs) provided throughout alternative/document.

Animal 

trapping/traplines

Allowed 

Target shooting Allowed 

Cremains scattering Allowed 

Special Recreation 

Permits

Allowed SRPs would only be allowed in priority 

habitat if they are consistent with the 

goals and objectives for that habitat or 

species. 

Management for Greater Sage-Grouse Priority Habitat Management Areas 

(PHMAs) provided throughout alternative/document.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-229

Table 2-12 Detailed Table of Alternatives: Special Designations

Greater Sage-Grouse ACEC

Record# Management Activity Alternative A (0 acres) Alternative B (158,926 acres) Alternative C (0 acres) Alternative D (0 acres)

Other permitted 

activities

Allowed Not allowed Management for Greater Sage-Grouse Priority Habitat Management Areas 

(PHMAs) provided throughout alternative/document.

Transportation No current management decision provided The BLM may close or restore 

unauthorized, user created roads and 

trails to prevent resource damage. 

TMAs in or partially in the ACEC 

would be managed to minimize 

impacts to Greater Sage-Grouse

habitat

Management for Greater Sage-Grouse Priority Habitat Management Areas 

(PHMAs) provided throughout alternative/document.

Geocaching Allowed Not allowed (11) 

Other management 

activities

No current management decision provided Other management activities and/or 

uses would be considered in 

subsequent site-specific analysis, and 

would consider the values for which 

the ACEC is designated (5).

Management for Greater Sage-Grouse Priority Habitat Management Areas 

(PHMAs) provided throughout alternative/document.

Notes: (Map 159) 

1 Avoidance area; granting Rights-of-Way (surface, subsurface, aerial) within the area should be avoided, but rights-of-way may be granted if there is minimal or no conflict with identified resource values and impacts to 

ACEC resource values can be fully mitigated. 

2 Off-highway vehicles and bicycles, use would be limited to designated routes only. 

3 Commercial collection of plant materials, including common species, authorized by permit only. Casual use allowed. 

4 Road maintenance will be limited to the designated roadway and only that necessary to ensure public safety and serviceability of the road. 

5 The activity is allowed in the area subject to specific environmental analysis upon individual permit applications and only if there is minimal or no conflict with identified resources values and impacts to ACEC resource 

values can be fully mitigated. Additional NEPA analysis required. Cultural inventories will be required for surface disturbing activities. Native American coordination/consultation required on activities within ACEC 

(especially if cultural resources are one of the values for ACEC designation). 

6 Closed to renewable energy facilities and renewable energy development 

7 Livestock grazing will be controlled through terms and conditions on the grazing permit. 

8 Evaluate fire potential and remove fuels where needed to protect resource values. Types of treatments permitted: hand cutting/chainsaw only around rock art sites. Mechanical thinning would be allowed on a case-bycase basis - must meet objectives of ACEC. 

9 Open to mineral material activities on a case-by-case basis and subject to controlled surface use, seasonal timing restrictions, restricted or no uses in avoidance areas (e.g. riparian areas, areas with special wildlife or 

plant features, areas of high cultural significance, and sensitive viewsheds), and additional NEPA analysis required. 

10 Treatments may include any combination of herbicide application, mechanical treatments, burning, grazing, and the use of insects or pathogens. 

11 If geocache location/activity does not conflict with the resource values of the ACEC, this activity could be considered. BLM resource specialist (wildlife biologist) and BLM ORP must agree activity does not impact ACEC 

values. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-230 Chapter 2: Resource Management Alternatives

Table 2-12 Detailed Table of Alternatives: Special Designations

Wilderness Study Areas (WSAs)

Record#

Alternative A

(No Action) Alternative B Alternative C Alternative D(Proposed Alternative)

A wilderness study area (WSA) contains undeveloped United States federal land retaining its primeval character and influence, without permanent improvements or human habitation, and managed 

to preserve its natural conditions. WSAs are not included in the National Wilderness Preservation System until the United States Congress passes wilderness legislation. On BLM lands, a WSA is a 

road-less area that has been inventoried (but not designated by Congress) and found to have wilderness characteristics as described in Section 603 of the Federal Land Management Policy Act of 

1976 and Section 2(c) of the Wilderness Act of 1964. 

The Billings Field Office currently manages the Twin Coulee WSA in Musselshell County (Map 160) and the Burnt Timber Canyon, Big Horn Tack-On, and Pryor Mountain WSAs in Carbon County, 

Montana and Big Horn County, Wyoming (Map 161). Wilderness study areas within the planning area total approximately 28,631 acres. The Billings Field Office would manage wilderness study 

areas according to BLM Manual 6330 – Management of BLM Wilderness Study Areas, until such time as Congress makes a determination regarding wilderness designations.* 

(*Acreages for WSAs are taken from the 1991 Montana Statewide Wilderness Report and no not reflect GIS data acreages.)

Desired Outcomes (Goals and Objectives)

Manage Wilderness Study Areas (WSAs) following BLM Manual 6330 – Management of BLM Wilderness Study Areas - until such time as Congress acts upon the recommendations. The BLM is 

statutorily (FLPMA Section 603(c)) required to manage these areas to protect their suitability for Congressional designation into the National Wilderness Preservation System unless and until 

Congress either designates an area as wilderness or releases it from further consideration. 

Management Common to All Alternatives

Wilderness Study Areas would be managed according to BLM Manual 6330 – Management of BLM Wilderness Study Areas. he BLM is statutorily (FLPMA Section 603) required to 

manage these areas to protect their suitability for congressional designation to the National Wilderness Preservation System unless and until Congress either designates an area as 

wilderness or releases it from further consideration.

Conduct resource and activity monitoring to identify developments and disturbances and to timely address impacts to wilderness characteristics.

Competitive or commercial SRPS would not be allowed within WSAs, with the exception of outfitter and guide uses and existing permittees. 

Manage WSAs to protect, conserve, and enhance wilderness characteristics

Surface disturbing and disruptive activities would only be allowed if the activity does not impair the resource values and/or wilderness characteristics, except those actions specifically 

exempted from this standard by FLPMA (such as grandfathered uses). BLM will rehabilitate existing impacts during ESR/rehab operations of any human impacts which are destabilized 

by during a fire event.

Vegetation and fuels treatments, including prescribed fire, would be allowed, only if they enhance wilderness values.

Allow for habitat manipulations in WSAs on a case-by-case basis using methods which protect areas from weed infestations resulting from human influence and which specifically 

conform to guidance in BLM Manual 6330.

WSA lands would be closed to permitted commercial and personal use wood cutting, seed and plant collection. 

WSAs would be managed as VRM Class I.

WSAs would be managed as closed to all types of mechanical transport, including snowmobiles. Aircraft may not land in a WSA, nor may air deliveries be made, with the exception of 

law enforcement activities, emergencies, aerial surveys, the installation of temporary or removal of obsolete facilities, and the gathering of wild horses. New routes (those not found in 

the initial Wilderness inventory) may not be established or designated for mechanical use.

WSAs would be closed to oil and gas leasing and development, subject to valid existing rights. 

Mineral material sales would not be allowed in WSAs

WSAs would be managed as a ROW exclusion area. Existing ROWs may be renewed if still being used for their authorized purpose.

Conduct active restoration activities to remove unnatural features and rehabilitate unauthorized facilities, consistent with regulations. Closed vehicle routes will be rehabilitated or 

converted into non-mechanized trails.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-231

Table 2-12 Detailed Table of Alternatives: Special Designations

Wilderness Study Areas (WSAs)

Record#

Alternative A

(No Action) Alternative B Alternative C Alternative D(Proposed Alternative)

As a high priority, BLM will acquire lands within WSAs boundaries from willing sellers. BLM will rehabilitate existing impacts on any acquired lands

Public access to WSAs would be provided through public access easements across public lands where feasible and needed.

Fire activities and projects in WSAs will adhere to the direction of BLM Manual 6330. Minimum Impact Suppression Tactics (MIST) would be used for all suppression efforts. A 

Resource Advisor would be assigned to all fires which occur within a WSAs

Release of WSAs - Management Actions by Alternative

BLM Manages lands released from wilderness study area designation by Congress in the same manner as surrounding lands. In the event that lands released from wilderness study 

area designation are protected under some other special designation, those lands would retain those same protections identified in the Common to All (e.g., ACECs within a wilderness 

study area). WSA lands not retained under some other special designation would be released for other purposes and uses. These other special designations are not a substitute for 

wilderness designation but provide specific management prescriptions to protect important resources.

If Congress acts on designation, and Big Horn Tack-On, Burnt Timber Canyon and Pryor Mountain WSAs are not selected as wilderness, the area within the current boundaries of all 

WSAs would continue to be closed to motorized use including snowmobile use.

Portions of Big Horn Tack-On, Burnt 

Timber Canyon, and Pryor Mountain 

WSAs current WSA boundaries 

would be managed as an ACEC. 

If Congress acts on designation, and Big Horn Tack-On, Burnt 

Timber Canyon, and Pryor Mountain WSAs are not selected as 

wilderness, the land area within these current WSA boundaries 

would be managed as an ACEC. 

Same as B Same as B

By policy Lands within the WSAs are 

managed as VRM Class I

If Congress acts on designation and the lands within Big Horn 

Tack-On, Burnt Timber Canyon, Pryor Mountain, and Twin Coulee 

WSAs are released from further consideration; the land area within 

the current boundaries would be managed as VRM Class II.

Same as B Same as B

No similar action If Congress acts on designation, and Twin Coulee, Big Horn TackOn, Burnt Timber Canyon and Pryor Mountain WSAs are not 

selected as wilderness, the land area within these current WSA 

boundaries would continue to be closed and recommended for 

withdrawal from mineral entry. 

If Congress acts on the designation and Twin 

Coulee WSA is released from further 

consideration, the area would be open for 

mineral entry and leasing.

If Congress acts on designation, and Big Horn 

Tack-On, Burnt Timber Canyon and Pryor 

Mountain WSAs are not selected as wilderness, 

the land area within these current WSA 

boundaries would continue to be closed and 

recommended for withdrawal from mineral entry. 

Same as C

No current Wildland fire 

management decision provided

Wildfire management (natural ignitions) for resource benefit. 

Appropriate fire management in response to human-ignited fires. 

Appropriate fire management protection 

strategies.

Same as B
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-232 Chapter 2: Resource Management Alternatives

Table 2-12 Detailed Table of Alternatives: Special Designations

Wild and Scenic Rivers

Record#

Alternative A

(No Action) Alternative B Alternative C Alternative D(Proposed Alternative)

Agencies conduct eligibility and suitability recommendations for potential river segments through the planning process and submit their findings to Congress for action. Upon appropriate study and 

evaluation, rivers are classified as wild, scenic, or recreational, depending on the level of human impact. See Appendix R for the eligibility report for river segments in the Billings Field Office.

Wild and Scenic Rivers – Desired Outcomes (Goals and Objectives)

The Billings Field Office management strategy is to manage eligible river to protect and enhance the free-flowing character, water quality, and outstandingly remarkable values until suitability can be 

determined through the land use planning process, determine the suitability or non-suitability of eligible rivers for potential inclusion within the NWSR through the land use planning process, manage 

suitable rivers to protect and enhance the free-flowing character, water quality, and identified outstandingly remarkable values until congress designates the river as a component of the NWSRS or 

releases the river for other uses.

Wild and Scenic Rivers – Management Common to All Alternatives

Management would be conducted in a manner to protect and enhance the outstandingly remarkable values, the free flowing nature, and the water quality for each river segment.

Wild and Scenic Rivers – Management Actions by Alternative

Manage all of the eligible river segments 

(14.08 miles) (Map 162) to protect their 

outstandingly remarkable values, freeflowing nature, and tentative 

classification, as follows:

 Bad Canyon

 Bear Canyon

 Crooked Creek (upper) 

 Crooked Creek (lower) 

 Gyp Springs

 Piney Creek

 Yellowstone River/Pompeys Pillar 

Recommend all of the eligible river

segments (14.08 miles) (map 163) as 

suitable for inclusion in the National Wild and 

Scenic River System to protect their 

outstandingly remarkable values, freeflowing nature, and tentative classification, 

as follows:

 Bad Canyon

 Bear Canyon

 Crooked Creek (upper)

 Crooked Creek (lower)

 Gyp Springs

 Piney Creek

 Yellowstone River/Pompeys Pillar 

Manage none of the eligible river segments 

(14.08 miles) (Map 164) to protect their 

outstandingly remarkable values, free-flowing 

nature, and tentative classification, as follows:

 Bad Canyon

 Bear Canyon

 Crooked Creek (upper)

 Crooked Creek (lower)

 Gyp Springs

 Piney Creek

 Yellowstone River/Pompeys Pillar 

None of the eligible river segments would be 

recommended as suitable for inclusion in the 

National Wild and Scenic River system.

Manage the following river segments 

(3.15 miles) (Map 165) as suitable to 

protect their outstandingly remarkable 

values, free-flowing nature, and 

classification.

The following segments would be 

recommended as suitable for inclusion in 

the National Wild and Scenic River 

System:

 Crooked Creek (above fish barrier –

1.59 miles); tentative management

class would be Wild.

 Crooked Creek (below fish barrier –

1.56 miles); tentative management

class would be Scenic.

No current management decision 

provided

WSR-suitable segments would be closed to 

oil and gas leasing, exploration and 

development (NL).

NSO for oil and gas leasing, exploration and 

development within 1⁄4 mile of WSR- eligible 

(NSO).

NSO for oil and gas leasing, exploration 

and development within 1⁄2 mile of WSReligible and suitable segments (NSO).

No current management decision 

provided.

WSR-suitable and eligible segments would be exclusion areas for wind energy.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-233

Table 2-12 Detailed Table of Alternatives: Special Designations

Pryor Mountain Wild Horse Range

Record# Management Activity Alternative A

(No Action) Alternative B Alternative C Alternative D(Proposed Alternative)

The Pryor Mountain Wild Horse Range (PMWHR) is an administrative designation dictating a Herd Management Area (HMA) is to be managed principally, but not necessarily exclusively, for the 

benefit of wild horses within the authorities of the Wild Free-Roaming Horse and Burro Act of 1971, as amended. 

Pryor Mountain Wild Horse Range – Desired Outcomes (Goals and Objectives)

Management activities for other resources and programs within the PMWHR would be designed in a manner to minimize impacts to wild horses and their habitat. During the summer and fall 

seasons the PMWHR attracts many members of the public who enjoy viewing the wild horses and other recreational opportunities (e.g. camping, hiking, ATV riding, hunting, naturalizing, etc.). 

Management of the administrative designation area would be to enhance wild horse protection and habitat from congested recreational use, providing for public health, and safety of public land 

users.

Pryor Mountain Wild Horse Range – Management Actions by Alternative

Wild horse protection: public 

feeding

Allowed but discouraged Not allowed Allowed as long as no moving or 

chasing of horses

Only allowed for management 

purposes

Wild horse protection: Harassment Not allowed, but harassment of 

wild horses not locally defined

Interrupting their behavior or disruption 

of their daily activities, outside of 

management activities, such as 

moving animals to take photos or 

filming, feeding or touching or 

attempting to do these things would 

not be allowed.

Same as A Same as B

Wild Horse Protection: Seasonal 

Road Closures

Motorized travel limited to 

designated routes.

There would be no seasonal road 

closure during foaling season or 

for habitat protection.

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 Sykes 

horse trap to the USFS boundary 

would be closed to provide protection 

during the primary foaling season and 

protecting habitat when roads are not 

ready for travel due to moisture 

content in soils (March 1-June 30).

Motorized routes within the 

PMWHR would be designated 

according to the Pryor TMA.

There would be no seasonal road 

closure during foaling season or 

for habitat protection

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.

Wild Horse Protection: Fencing Exclusion fences for study, 

riparian protection or rehabilitation 

would be allowed.

No exclusion fences would be allowed 

within the HMA.

Same as A Exclusion fences for study, range 

improvements, riparian protection 

or rehabilitation would be allowed 

through site-specific analysis. 

Wild Horse Protection: Wild horse 

health

No current management decision 

provided

Domestic horse use would not be 

allowed except for special recreation 

permits or livestock trailing.

Domestic horse use would be 

allowed during overnight camping 

(16 day limit). 

Recreational domestic horse use 

would require proof of a free-use 

Domestic horse use would be 

limited to day use only.

Recreational domestic horse use 

would require a free-use permit to 

ensure animals have health 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-234 Chapter 2: Resource Management Alternatives

Table 2-12 Detailed Table of Alternatives: Special Designations

Pryor Mountain Wild Horse Range

Record# Management Activity Alternative A

(No Action) Alternative B Alternative C Alternative D(Proposed Alternative)

permit to ensure animals have 

health certifications to protect wild 

horses from disease 

transmission.

certifications to protect wild 

horses from disease 

transmission.

Wild Horse Habitat Enhancement Considered on a site specific 

basis.

No vegetation treatments would be 

conducted in wild horse habitat; only 

allow natural processes to occur.

Maximize the amount of acres for 

vegetation treatment and water 

developments that would 

increase forage availability for 

wild horses, to maximize and/or 

increase wild horse numbers 

within other multiple uses and 

restrictions.

Same as C

Public Health and Safety: Target 

shooting

No current management decision 

provided

Not allowed Allowed Not allowed on T8S R28E 

Memorial day weekend through 

Labor day weekend.

Allowed in remainder of PMWHR

Public Health and Safety: Speed 

limits for mechanized and 

motorized vehicles 

No current management decision 

provided

Not to exceed 15 miles per hour No limit Not to exceed 15 miles per hour 

within T8S R28E

Livestock grazing The PMWHR would be 

unavailable for livestock grazing, 

except for trailing through Bad 

Pass.

The PMWHR would be unavailable for 

livestock grazing.

Bad Pass Trail would be 

managed as a livestock grazing 

allotment for trailing use only. 

The remainder of the PMWHR 

would be closed to livestock 

grazing. 

Same as C

Special Recreation Permits and 

Letters of Authorization

Current levels of permitted use 

with approximately 1,200 visitor 

use days in the PMWHR would 

be managed per application, with 

no limit on commercial permits.

No commercial special recreation 

permits (SRPs) would be authorized in 

the PMWHR. Non-commercial, 

organized group events would be 

considered per application dependent 

on site specific analysis and 

monitoring.

An Outfitter Permit Area (OPA) 

would be established in the 

PMWHR in order to protect wild 

horses, resources within the 

range, and minimize conflicts 

based on site specific analysis 

and monitoring.

Visitor use days for both 

commercial and non-commercial 

permits would be analyzed 

through site-specific analysis and 

monitoring and would also 

consider other commercial 

permitted uses. 

SRPs would initially be limited to 

existing SRPs. Additional (new) 

SRPs would be permitted only 

when determined not to result in 

congestion, wild horse 

displacement or cause an 

adverse experience for members 

of the public viewing wild horses 

outside of an SRP experience 

through monitoring of existing 

SRPs and visitation.

Land use authorization Exclusion area Exclusion area, except valid existing 

rights.

Avoidance (1)
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-235

Table 2-12 Detailed Table of Alternatives: Special Designations

Pryor Mountain Wild Horse Range

Record# Management Activity Alternative A

(No Action) Alternative B Alternative C Alternative D(Proposed Alternative)

Land tenure No current management decision 

provided

Category I retention land: no land disposal would occur

Off-highway vehicle use (including 

snowmobiles (OSVs))

Limited to designated routes 

(refer to Table 2.11 Trails and 

Travel Management –

Management Actions by 

Alternative. Snowmobiles (OSVs)

Limited to designated routes (refer to 

Table 2.11 Trails and Travel 

Management – Management Actions 

by Alternative. Snowmobiles (OSVs)

Limited to designated routes 

(refer to Table 2.11 Trails and 

Travel Management –

Management Actions by 

Alternative. Snowmobiles (OSVs)

Limited to designated routes 

(refer to Table 2.11 Trails and 

Travel Management –

Management Actions by 

Alternative. Snowmobiles (OSVs)

BLM road maintenance No current management decision 

provided

Limited (4)

Plant collecting No current management decision 

provided

Allowed for scientific use or 

range/forestry studies. No collection of 

special status species without a 

permit.

Allowed for personal use as well 

as scientific use and 

range/forestry studies. No 

collection of special status 

species without a permit.

Allowed (3)

Fluid Mineral leasing Closed to oil and gas leasing and 

development (NL) 

Closed to oil and gas leasing and 

development (NL).

Closed to oil and gas leasing and 

development (NL).

Closed to oil and gas leasing and 

development (NL).

Locatable minerals Closed and recommended for 

withdrawal 

Close and recommend withdrawal 

from mineral entry, subject to valid 

existing rights.

Open Same as B

Solid leasable minerals No current management decision 

provided

Closed, subject to valid existing rights. Open (5) Same as B

Mineral materials sales and 

permits

Not allowed Not allowed Allowed (9)

Renewable energy No current management decision 

provided

Closed (6)

Geophysical exploration for oil and 

gas

Not allowed

Use of explosives for geophysical 

exploration for oil and gas

No current management decision 

provided

Not allowed

Fire suppression Conditional fire suppression Wildfire management (natural 

ignitions) for resource benefit. 

Appropriate fire management in 

response to human-ignited fires. 

Appropriate fire management 

protection strategies.

Same as B

Fuels management No current management decision 

provided

Allowed (8)

Fuel wood cutting/wood product 

sales

Not allowed Not allowed Casual collection of dead and down allowed for personal use during 

recreation activities.

Range improvements No current management decision 

provided

Allowed (5)

Noxious/Invasive weed treatments No current management decision 

provided

Allowed (5) (10)
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-236 Chapter 2: Resource Management Alternatives

Table 2-12 Detailed Table of Alternatives: Special Designations

Pryor Mountain Wild Horse Range

Record# Management Activity Alternative A

(No Action) Alternative B Alternative C Alternative D(Proposed Alternative)

Animal trapping/traplines No current management decision 

provided

Not allowed Allowed

Non-commercial collection of 

common invertebrate and plant 

fossils

Allowed

Other permitted activities No current management decision 

provided

No commercial film permits allowed Allowed (5) Commercial film permits would be 

limited to existing permits. 

Additional (new) commercial film 

permits would be permitted only 

when determined not to result in 

congestion, wild horse 

displacement or cause an 

adverse experience for members 

of the public viewing wild horses 

through monitoring of existing 

commercial film permits and 

visitation. (5)

Transportation No current management decision 

provided

No net increase in road density Routes for commercial or other 

BLM authorized activities may be 

considered if the route meets 

public access needs.

Same as C

Other management activities No current management decision 

provided

Other management activities and/or uses would be considered in subsequent site-specific analysis, and would 

consider the values for which the PMWHR is designated (5).

1 Avoidance area; granting Rights-of-Way (surface, subsurface, aerial) within the area should be avoided, but rights-of-way may be granted if there is minimal or no conflict with identified resource values and impacts to 

PMWHR resource values can be fully mitigated. 

2 Off-highway vehicles and bicycles, use would be limited to designated routes only. 

3 Commercial collection of plant materials, including common species, authorized by permit only. Casual use allowed. 

4 Road maintenance will be limited to the designated roadway and only that necessary to ensure public safety and serviceability of the road. 

5 The activity is allowed in the area subject to specific environmental analysis upon individual permit applications and only if there is minimal or no conflict with identified resources values and impacts to PMWHR resource 

values can be fully mitigated. Additional NEPA analysis required. Cultural inventories will be required for surface disturbing activities. 

6 Closed to renewable energy facilities and renewable energy development 

7 Livestock grazing will be controlled through terms and conditions on the grazing permit. 

8 Evaluate fire potential and remove fuels where needed to protect and/or enhance resource values. Must meet objectives of PMWHR HMAP. 

9 Open to mineral material activities on a case-by-case basis and subject to controlled surface use, seasonal timing restrictions, restricted or no uses in avoidance areas (e.g. riparian areas, areas with special wildlife or 

plant features, areas of high cultural significance, and sensitive viewsheds), and additional NEPA analysis required. 

10 Treatments may include any combination of herbicide application, mechanical treatments, burning, grazing, and the use of insects or pathogens. 

11 If geocache location/activity does not conflict with the resource values of the ACEC, this activity could be considered. BLM resource specialist (Wild Horse State Lead) and BLM ORP must agree activity does not impact 

PMWHR values. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-237

Table 2-12 Detailed Table of Alternatives: Special Designations

National Historic Trails

Record#

Alternative A

(No Action) Alternative B Alternative C Alternative D(Proposed Alternative)

National Historic Trails are extended trails that closely follow a historic trail or route of travel of national significance. Congressional designation identifies and protects historic routes, historic 

remnants, and artifacts for public use and enjoyment. The Billings Field Office manages portions of two designated National Historic Trails, the Lewis and Clark National Historic Trail and the Nez 

Perce National Historic Trail. Pompeys Pillar National Monument is a Lewis and Clark National Historic Trail-related site.

National Historic Trails – Desired Outcomes (Goals and Objectives)

The BLM’s intent is to protect National Historic Trails for long-term heritage and educational values and to enhance the public experiences of these unique trails through interpretation and support of 

heritage tourism while maintaining compatible recreational use with historic trail values. 

The BLM’s intent is to: 1) safeguard the nature and purposes; and conserve, protect, and restore the National Trail resources, qualities, values, and associated settings and the primary use or uses; 

2) Reduce the potential for uses that substantially interfere with the nature and purposes of the National Trails; and 3) Avoid activities that are incompatible with the purposes for which the National

Trail was established.

National Historic Trails – Management Common to All Alternatives

Implement the Interagency National Historic Trail Plans for the Lewis and Clark and Nez Perce National Historic Trails. Participate in the Interagency planning update efforts as needed. 

Identify and acquire from willing sellers easements and lands within the NHT corridors. See Realty, Cadastral Survey, and Lands Section for additional references

Retain public land within federal ownership

The Lewis and Clark NHT would be withdrawn from mineral actions. Once the actual Nez Perce NHT course is determined it would also be withdrawn

Minimize changes that would result in degradation of resource values or opportunities for sharing the experience of the original users of the NHTs.

Identify the Nez Perce NHT Corridor and establish management prescriptions through a land use plan amendment once the corridor has been determined

The Lewis and Clark NHT management corridor is identical to the Yellowstone River corridor.

Support partnerships and cooperative agreements with other agencies, local and state authorities, and NGOs to implement stewardship and educational goals for the NHTs. Support the 

Montana site stewardship program for monitoring and evaluation of significant trail resources. 

Manage the auto tours routes associated with the NHTs to include signage and appropriate facilities as set out in the NHT’s Comprehensive Management Plan.

Implement the Interagency National Historic Trail Plans and all revisions including sub plans such as interpretive plans.

Participate and follow the NHT’s Land Acquisition Management Plans.

Management Common to Action Alternatives

No current management decision provided The setting for the Lewis and Clark and Nez Perce NHT segments would be maintained where setting is an aspect of integrity by utilizing 

viewshed management tools.

No current management decision provided The management corridor for the Lewis and Clark and Nez Perce NHT segments is 1⁄2 mile either side of centerline

No current management decision provided Management actions would apply to the NHT management corridor

No current management decision provided An inventory and evaluation would be maintained for the trail segments and include this data in a trails management plan.

No current management decision provided. Manage NHTs as ROW avoidance areas.

No current management decision provided The NHTs would be managed as exclusion areas for Renewable Energy (wind and solar) ROW actions.

Management Actions by Alternative

No current management decision provided Surface disturbing activities would not be 

allowed within 1⁄2 mile of the L&C or NP NHTs

Surface disturbing activities would be subject to 

mitigation guidelines for surface disturbing 

Surface disturbing activities would be 

subject to mitigation guidelines. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-238 Chapter 2: Resource Management Alternatives

Table 2-12 Detailed Table of Alternatives: Special Designations

National Historic Trails

Record#

Alternative A

(No Action) Alternative B Alternative C Alternative D(Proposed Alternative)

management corridor. activities.

No current management decision provided No surface occupancy for oil and gas 

development and exploration within 1⁄2 mile of 

the L&C and NP NHTs management corridor

(NSO).

Oil and gas development and exploration would 

be allowed within 1⁄2 mile of the L&C and NP 

NHTs management corridor with stipulations 

(CSU). 

Same as B

Manage NHTs as Visual Resource Inventory 

(VRI) Class III.

Manage National Historic Trails as Visual 

Resource Inventory (VRI) Class III. 

Manage NHT trails as Visual Resource 

Management (VRM) Class II once specific 

trail course has been identified

Manage National Historic Trails as Visual 

Resource Inventory (VRI) Class III. 

Manage NHT trails as Visual Resource 

Management (VRM) Class III once specific trail 

course has been identified

Manage National Historic Trails as Visual 

Resource Inventory (VRI) Class III. 

Manage NHT trails as Visual Resource 

Management (VRM) Class II once specific 

trail course has been identified

Table 2.13 Detailed Table of Alternatives: Social and Economic Conditions 

Social and Economic Conditions and Environmental Justice

Record # Alternative A

(No Action) Alternative B Alternative C Alternative D(Proposed Alternative)

The goals and objectives for social and economic conditions and environmental justice would provide for a diverse array of opportunities that result in social and economic benefits for interested 

groups and individuals such as local residents, recreationists, permittees, etc. The use of lands and minerals managed by the BLM provide opportunities to contribute to local, state, and national

economic development and growth. Opportunities to use and develop these lands and minerals, as well as the costs and likelihood of these lands and minerals being used and developed given 

other resource management objectives and constraints, vary among the alternatives described and analyzed. The positive and negative social effects to the various groups and individuals are 

identified in the effects analysis. During social effects analysis, identity disproportionate negative effects to minority or low income populations per Executive Order 12898. If negative 

disproportionate effects are identified, remediate these effects to the extent possible by identifying mitigation to be added to the alternatives where the effects are found.

Desired Outcomes (Goals and Objectives)

 Provide opportunities for economic sustainability at the national, regional, and local level.

 Provide for a diverse array of opportunities that result in social benefits for local residents, businesses, recreationists, visitors, interested citizens and future generations, while minimizing the

negative social effects.

 Identify and remediate, to the extent possible, disproportionate negative effects to minority or low income populations per EO 12898.

 BLM would continue to notify and consult with appropriate American Indian Tribes and BLM authorized actions. Consultation and coordination would be conducted on a government-togovernment basis with federally recognized tribes with cultural affinity to the decision area. Management of public lands would accommodate the exercise of rights provided by treaties or law 

that are applicable to the planning area. BLM would coordinate with appropriate entities within tribal government on issues under its jurisdiction to determine appropriate protocols that provide

for treaty uses of public lands.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-239

2.7 Summary of Environmental Consequences by Alternative 

Table 2.14 (Summary Comparison of Impacts by Alternative) summarizes potential meaningful 

impacts anticipated from activities within the Billings Field Office decision area by alternative. 

Where applicable, potential impacts anticipated from the BLM actions are quantified. Table 

2.14 summarizes the difference of impacts to alternatives in acres and actions. For example, a 

greater acreage implies a greater impact (either beneficial or adverse). A more detailed 

comparison of impacts between alternatives is summarized in the conclusion for each resource 

section in Chapter 4. 

Table 2.15 (Summary Comparison of Impacts) summarizes potential meaningful impacts 

anticipated to economics from activities within the Billings Field Office decision area by 

alternative. 

The environmental consequences of alternatives are not anticipated to exceed known legal 

thresholds or standards over the life of the plan. Standard practices, best management practices, 

and guidelines for surface disturbing/disruptive activities are built into each alternative to avoid 

and minimize potential impacts. Mitigation of residual impacts will be considered during 

subsequent implementation decision plans and any associated environmental analyses 

conducted at that time. Reclamation will be applied to surface disturbance under all alternatives 

to reduce the amount of long-term impact. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-240 Chapter 2: Resource Management Alternatives

Table 2.14 Summary of Environmental Consequences by Alternative

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Air

The largest impacts to air resources would be caused by emissions from fire management, coal mining, and oil and gas activity. Additional activities that could affect emissions include the following 

resource programs: Soil Management, Vegetation Management, Forestry and Woodland Products, Realty, Cadastral Survey, and Lands, Livestock Grazing, Recreation and Visitor Services, Trails 

and Travel Management. Other programs were determined to have small emissions with little or no impact on air resources.

Alternative A emissions are summarized in 

Table 4-14 and detailed emission calculations 

are provided in Appendix Y. Fire management 

activities would cause the greatest CO, SO2, 

PM2.5, and HAP emissions, while oil and gas 

development and production would account 

for the largest NOx, and VOC emissions. 

Recreational visits would cause the greatest 

PM10 emissions. 

Alternative B emissions are summarized in 

Table 4-15. The largest Alternative B 

emissions of CO, NOx, PM2.5, SO2, VOCs, 

and HAPs would result from fire management 

activities. Recreational activities are expected 

to cause the greatest PM10 emissions. 

Alternative C emissions are summarized in 

Table 4-16. Total Alternative C emissions are 

nearly identical to those for Alternative B, but 

are greater than those for Alternative A.

Alternative D emissions are nearly identical to 

those for Alternatives B and C, but are greater 

than those for Alternative A. Alternative D 

emissions are summarized in Table 4-17. 

Climate

In terms of quantifiable changes in estimated 

GHG emissions, Alternative A would have 

slightly lower climate impacts than the other 

Alternatives. However, the quantifiable 

differences between the Alternatives’ GHG 

emissions could have less impact than net 

GHG differences that may occur due to 

carbon sequestration in vegetation and soils.

Based on estimated GHG emissions, 

Alternative B would lead to an approximate 

1% increase in emissions over Alternative A. 

Alternative B closes the most travel routes 

and imposes the greatest limits on some 

recreational and commercial uses (oil and 

gas, coal, and forest products) of public lands. 

Travel route and recreational closures and 

constraints on oil and gas surface occupancy 

would do little to reduce emitted GHGs since 

use would shift to open routes and surface 

occupancy areas and emissions would remain 

relatively unchanged. Alternative B would not 

allow any new federal coal leasing actions. 

However, if federal coal has already been 

leased, mining would continue to occur. 

Therefore, quantifiable GHG emissions are 

conservatively estimated to include continued 

coal mining. Increased prescribed fire would 

lead to a temporary increase in GHG 

emissions during these activities followed by a 

long-term decrease in net GHG emissions 

(Wiedinmyer 2010). As a result, forested and 

Alternative C offers the most open travel 

routes, recreational opportunities, and 

commercial use of resources, although 

increases in quantifiable GHG emissions over 

Alternatives B and D are negligible. More 

surface disturbance is allowed in Alternative C 

than in Alternative B, which could potentially 

allow more vegetation treatments designed to 

improve long-term vegetation health and 

reduce wildfire potential. Removing 

underbrush and small trees, which store less 

carbon, would allow faster growth of larger 

trees resulting in more long-term carbon 

sequestration. The increase in vegetation 

treatments would be driven by budget 

constraints, keeping treatments small and the 

increase in carbon uptake would be minor.

Based on estimated GHG emissions, climate 

impacts in Alternative D would be greater than 

those for Alternative A and similar to those for 

the other Alternatives. Alternative D provides 

balance between climate change emissions, 

recreation, commercial demand, healthy 

vegetation, and carbon sequestration. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-241

Table 2.14 Summary of Environmental Consequences by Alternative

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

grass/shrub lands would improve as carbon 

sinks and help reduce the net GHG emissions 

within the planning area

Mandatory monitoring and adherence to 

range standards, stream zone law, and use of 

BMPs allows adaptive management 

strategies that would successfully address 

impacts from climate change. The limitation 

on surface disturbance on slopes <30%, or in 

areas such as crucial winter range, would limit 

vegetation treatments designed to maintain 

and/or enhance vegetation and reduce the 

risk of wildfire. Hence the likelihood of large 

fires, releasing large amounts of carbon would 

increase and the net amount of carbon stored 

would decrease sharply and slowly return 

over 25–50 years. 

Soil

Impacts to soils resources would likely result from actions proposed under the following resource programs: Soil Resources, Water Resources, Vegetative Communities, Fish, Wildlife and Special 

Status Species, Wild Horses, Visual Resources, Fire Ecology and Management, Lands with wilderness characteristics, Energy and Minerals, Forest and Woodland Products, Realty, Cadastral 

Survey, and Lands, Livestock Management, Recreation and Visitor Services, Trails and Travel Management, Renewable Energy, Special Designations: Pompeys Pillar, Areas of Critical 

Environmental Concern, Wilderness Study Areas. Other programs were determined to have little or no impact to soils resources. 

While local impacts to soils would occur under all alternatives (primarily compaction and soil loss/erosion), overall improvements in soil conditions are expected to occur as we move towards the 

achievement of the land health standards.

Alternatives A and D also place restrictions to 

surface use authorizations. Restrictions are 

typically less than B but more than C, 

generally with more restrictions on Alternative 

D than A.

Alternative B would place more restrictions to 

surface use authorizations, therefore 

protecting the most soil resources compared 

to all other Alternatives.

Alternative C would have the fewest 

restrictions to surface use authorizations, 

therefore protecting the least soil resources of 

all Alternatives.

Alternatives A and D also place restrictions to 

surface use authorizations. Restrictions are 

typically less than B but more than C, generally 

with more restrictions on Alternative D than A.

Water

The management actions associated with the resources listed below may have impacts on riparian resources: Soil, Water, Vegetation, Wildlife and Special Status Species, Fisheries and Special 

Status Species, Wild Horses, Visual Resources, Fire Ecology and Management, Lands with wilderness characteristics, Energy and Mineral Resources, Forestry and Woodland Products, Livestock 

Grazing, Recreation and Visitor Services, Trails and Travel Management, Renewable Energy, Special Designations. Those not listed are believed to have negligible or unapparent impacts. 

Under all Alternatives, water resources would benefit from management in accordance with Rangeland Health Standards and applicable state and federal water-quality standards. Site-specific 

mitigation and BMPs for surface disturbing activities would further reduce impacts on water resources. Adherence to these standards would reduce many of the adverse impacts from future actions. 

In addition, existing and proposed stipulations designed to protect water resources would be beneficial by minimizing sediment and contaminant delivery potential by preventing or limiting surfacedisturbing activities in proximity to hydrologic features. Stipulations and limitations for other resources that prevent or limit surface disturbing activities would provide additional protection for water 

resources and thereby could be beneficial (e.g., fisheries, riparian). Furthermore, timing limitations could benefit water resources by limiting or preventing surface-disturbing activities during times of 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-242 Chapter 2: Resource Management Alternatives

Table 2.14 Summary of Environmental Consequences by Alternative

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

the year when saturated soil conditions exist or when precipitation and runoff are frequent (e.g., winter, spring). While local inputs of non-point source pollutants would occur (under all alternatives), 

overall improvements in water quality are expected to occur as these sources are reduced. These reductions would occur due to the proposed RMP restrictions, management actions that improve 

watershed function throughout the Field Office, and the implementation of state approved TMDLs. However, with the scattered distribution and sparse ownership of BLM administered lands in the 

planning area, stipulations and management actions to minimize impacts to water resources may not prevent impaired water quality on BLM waterways, as is the current situation in some areas.

Vegetation: Forests and Woodlands and Forestry and Woodland Products

Impacts to forest and woodlands/forestry and woodland products would likely result from actions proposed under the following resources and resource use programs: Air, Soil, Water, Vegetation, 

Wildlife Habitat and Special Status Species, Fisheries Habitat and Special Status Species, Cultural Resources, Paleontological Resources, Visual Resources, Fire Ecology and Management, Lands 

with wilderness characteristics, Realty, Cadastral Survey, and Lands, Livestock Grazing, Recreation and Visitor Services, Trails and Travel Management, Transportation and Facilities, and Special 

Designations. Other programs were determined to have little or no impact on Vegetative Communities – Forests and Woodlands/Forestry and Woodland Products.

Alternative A would provide an incidental low 

volume of commercial forest products and 

contribute to a decline in forest health, 

productivity, and resiliency. Under this 

Alternative, forest management activities 

requiring the use of wheeled or tracked 

logging equipment would be restricted to 

sustained slopes of 35% or less, allowing 

forest treatments on 68% of forested acres not 

restricted by WSAs or ACECs; thereby limiting 

or prohibiting some forest treatment activities. 

The impacts of these actions would increase 

total costs and alter management activities; 

including the size, scale, type, location, and 

timing (e.g., temporary skid and haul road 

layout, skidding distances, cutting unit design, 

harvest system requirements, transportation 

systems, season of operations, mitigation 

measures, and silvicultural prescriptions) of 

treatments designed to improve forest health. 

The availability of forest and woodland 

products, especially sawtimber, biomass, and 

post and pole material would be reduced due 

to the high cost of operations in areas where 

tracked and wheeled operations are not 

allowed. 

As a result, forests and woodlands would 

continue to depart from historic conditions, 

which would contribute to a decline in forest 

health, species composition changes, 

Alternative B would also provide an incidentallow volume of commercial forest products and 

contribute to a decline in forest health, 

productivity, and resiliency. Impacts would be 

similar to Alternative A; however, forest 

management activities requiring the use of 

wheeled or tracked logging equipment would 

be limited to sustained slopes of 30% or less. 

As a result, mechanical treatment and harvest 

would only be allowed on approximately 60% 

of coniferous forest acres not restricted by 

WSAs or ACECs. This would result in higher 

cost treatment acres and would further reduce 

the level of forest management treatments 

and timber harvest that would occur. 

Consequently, forest and woodland areas 

would be at risk for extensive resource 

damage or loss due to landscape-level insect 

outbreaks or severe or high intensity wildfires.

Alternative C would provide a moderate 

volume of commercial forest products and 

contribute to long-term forest health 

improvement. Under this Alternative, forest 

management activities requiring the use of 

wheeled or tracked logging equipment would 

be restricted to sustained slopes of 45% or 

less; thereby allowing forest treatment 

activities on 79% of forested acres not 

restricted by WSAs and ACECs. 

Implementation of silvicultural treatments in 

forests and woodlands would reduce the 

density of overstocked stands, which would 

subsequently reduce competitive stress for 

water, sunlight, and nutrients, and reduce the 

susceptibility of forests and woodlands to 

insect attacks, disease, and stand-replacing 

fire. Lower stand density levels and increased 

sunlight would promote tree growth and 

ponderosa pine and limber pine regeneration. 

Alternative C would contribute to the overall 

vigor, productivity, and resiliency of forest and 

woodland vegetation in the planning area and 

the restoration historic conditions.

Alternative D would provide a low-moderate 

volume of commercial forest products and 

contribute to long-term improvements in forest 

health. Under this alternative, slope restrictions 

would be reduced to 25%; however, actions 

would be allowed if an approved mitigation and 

reclamation plan (e.g., Water Quality Best 

Management Practices for Montana Forests) is 

developed prior to activities taking place. 

As a result, the number of forested acres that 

would receive silvicultural treatments designed 

to reduce the density of overstocked stands 

would increase; thereby reducing competitive 

stress for growing space (e.g., water, sunlight, 

nutrients, etc.) and the area’s susceptibility to 

insect attacks, disease, and stand-replacing 

wildfire. Alternative D would also contribute to 

the overall vigor, productivity, and resiliency of 

forest and woodland vegetation in the planning 

area and the restoration of historic conditions.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-243

Table 2.14 Summary of Environmental Consequences by Alternative

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

increased stand density levels and fuel 

loadings, and increased susceptibility of these 

areas to insect and disease epidemics. 

Competition for resources (e.g., sunlight, 

water, and nutrients) would increase stress to 

forest and woodland vegetation across the 

entire landscape, which would result in 

declining vigor, productivity, and resiliency to 

disturbances (e.g., wildfire, insects, and 

disease). 

Vegetation: Rangelands

Management actions for the following resource programs would result in specific minor to moderate adverse impacts, and substantial beneficial impacts to vegetation resources: Soil, Water, 

Vegetation, Wildlife and Fisheries Habitat and Special Status Species, Fire Ecology and Management, Energy and Mineral Development, Forestry and Woodland Products, Realty, Cadastral 

Survey, and Lands, Livestock Grazing, Recreation and Visitor Services, Trails and Travel Management, and Special Designations. Other programs were determined to have little or no impact on 

rangeland vegetation communities. 

Alternative A is the current acres planned for 

the treatment of sagebrush and crested 

wheatgrass stand within the planning area. 

Impacts to Greater Sage-Grouse habitat are 

not considered under this alternative. Instead, 

impacts to livestock forage are emphasized.

Alternative B would not allow any use of 

prescribed in sagebrush habitat, and require 

full suppression of any wildfires in this 

community type. Impacts from this alternative 

would limit the number and kind of tools 

available for improving sagebrush habitat. 

Under this alternative, a total of fifteen

percent of crested wheatgrass acres would be 

converted to native sagebrush/ grassland over 

the life of the plan. This is the highest number 

of treatment acres of all of the alternatives. 

Alternative C considers the use of prescribed 

fire and wildland fire as a treatment options in 

sagebrush habitat if the treatment would 

achieve a diversity of age classes in 

sagebrush communities “... if the treatment 

would achieve a diversity of age classes in 

sagebrush communities”. Under this 

alternative, a total of five percent of crested 

wheatgrass acres would be converted to 

native sagebrush/ grassland over the life of 

the plan. This is the lowest of number of acres 

under Alternatives B, C and D but higher that 

Alternative A.

Alternative D also considers the use of 

prescribed fire and wildland fire as a treatment 

options in sagebrush habitat if the treatment 

would achieve a diversity of age classes in 

sagebrush communities “... if the treatment 

would achieve a diversity of age classes in 

sagebrush communities”. Under this 

alternative, a total of eight percent of crested 

wheatgrass acres would be converted to 

native sagebrush/ grassland over the life of 

the plan. This number of acres is lower that 

Alternatives A and C but higher that 

Alternative B.

The impacts of Alternatives B, C and D would increase total costs and alter management activities including the size, scale, type, location, and 

timing of treatments designed to improve rangeland health and protect and improve sagebrush habitat. 

Preferred treatment areas are not considered 

under Alternative A. Priority treatment areas 

are also not considered under Alternative A.

Preferred treatment areas would be areas that are not currently being used in a grazing system to provide early spring grazing and reduce grazing 

pressure from other areas within a grazing allotment, and is consistent throughout Alternatives B, C and D. Priority treatment areas would be in 

Greater Sage-Grouse PHMAs, RAs and GHMAs and is also consistent throughout Alternatives B, C and D.

Vegetation: Riparian and Wetlands

The management actions associated with the resources listed below may have impacts on riparian resources: Soil, Water, Vegetation, Wildlife Habitat and Special Status Species, Fisheries Habitat 

and Special Status Species, Wild Horses, Visual Resources, Fire Ecology and Management

Lands with wilderness characteristics, Energy and Mineral Resources, Forestry and Woodland Products, Realty, Cadastral Survey, and Lands, Livestock Grazing, Recreation and Visitor Services, 

Trails and Travel Management, and Special Designations. Those not listed have negligible or unapparent impacts. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-244 Chapter 2: Resource Management Alternatives

Table 2.14 Summary of Environmental Consequences by Alternative

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Under all Alternatives, riparian resources would benefit from management in accordance with Rangeland Health Standards. Site-specific mitigation and BMPs for surface disturbing activities would 

further reduce impacts on riparian resources. Adherence to these standards would reduce many of the adverse impacts from future actions. In addition, existing and proposed stipulations designed 

to protect riparian resources would be beneficial by minimizing sediment and contaminant delivery potential by preventing or limiting surface-disturbing activities in proximity to hydrologic features. 

Stipulations and limitations for other resources that prevent or limit surface disturbing activities would provide additional protection for riparian resources and thereby could be beneficial (e.g., 

fisheries, water, wildlife, lands w/ wilderness characteristics, etc.). Furthermore, timing limitations could benefit riparian resources by limiting or preventing surface-disturbing activities during times of 

the year when saturated soil conditions exist or when precipitation and runoff are frequent (e.g., winter, spring). While local impacts to riparian resources would occur (primarily bank disturbance and 

altered vegetation), under all alternatives, overall improvements are expected to occur as we move towards the achievement of the land health standards.

However, with the scattered distribution and sparse ownership of BLM administered lands in the planning area, stipulations and management actions to minimize impacts to riparian resources may 

not prevent impaired water quality on BLM administered lands, as is the current situation in some areas.

Alternative A represents how impacts have 

affected riparian resources under current 

management. Currently, the primary sources 

of riparian impairment are livestock grazing 

and invasive species infestations. At this time, 

approximately 40% of riparian areas are in 

Properly Functioning Condition (PFC), while 

46% are rated as Functioning at Risk (FAR) 

and 6% Non-Functioning (NF). 8% are 

unknown/unsurveyed. Current management 

requires riparian areas to be meeting PFC, or 

if FAR, moving toward PFC. Rangeland and 

riparian specialists would adjust grazing 

practices to attain these ratings where 

possible (if livestock grazing is identified as 

the causal factor or impairment). Other 

resource uses have negligible impacts on 

riparian resources under this alternative.

Under Alternative B management, riparian 

resources would have the most protection and 

should attain the highest state of functionality 

compared to any other alternative. 

Management actions for all resources and 

resource uses have the most restrictions to 

surface disturbing activities and potential 

invasive species infestation under this 

alternative. Increased buffer distances for oil 

and gas development, other surface 

disturbing activities and livestock exclusion 

from fish bearing streams are examples of 

restrictions made to conserve or improve 

riparian resources. Establishing 78 miles of 

“priority riparian habitat” will ensure increased 

monitoring and management action to attain 

PFC conditions on perennial streams.

Impacts to riparian resources would be similar 

to impacts from Alternative A. There are still 

appropriate measures taken to protect 

riparian areas from erosion, sedimentation 

and invasive species infestation, however, 

being less restrictive that alternative B and D 

actions, there is a higher potential for 

degradation. Livestock grazing and weed 

infestation would still be the primary source of 

impairment for riparian areas and would be 

managed using the standards and guidelines 

for livestock grazing. These methods, as 

described under alternative A impacts, require 

managers to change grazing practices to 

move riparian status towards PFC or maintain 

PFC when already meeting.

Compared to Alternative A, Alternative D 

provides a higher level of protection to riparian 

resources from impacts associated with surface 

disturbance by applying a CSU that ensures 

activities will be designed to promote riparian 

health and water quality.

Vegetation: Invasive Species and Noxious Weeds

Impacts to noxious and invasive species would likely result from actions proposed under the following resource and resource uses programs: Soil, Water, Vegetation, Wildlife Habitat, Fisheries 

Habitat and Special Status Species, Wild Horses, Cultural Resources, Visual Resources, Fire Ecology and Management, Lands with wilderness characteristics, Energy and Mineral Resources, 

Forestry and Woodland Products, Realty, Cadastral Survey, and Lands, Livestock Grazing, Recreation, Visitor Services, and Trails, Travel Management, Renewable Energy, and Special 

Designations. Other programs were determined to have little or no impact on noxious and invasive species. 

Across all Alternatives, the BLM would continue to monitor and treat new and existing populations of noxious and invasive weeds and would continue to work with partners from local, state, and 

federal agencies to control weeds on a broad scale. The BiFO would continue implementation of integrated weed management while adhering to federal, state, and county laws and regulations

The BLM would continue to monitor and treat 

new and existing populations of noxious and 

invasive weeds

The cumulative surface disturbance acreage 

across the BiFO is anticipated to be the least 

under Alternative B. Because weed invasion 

and spread is directly related to the amount of 

The cumulative surface disturbance acreage 

across the BiFO is anticipated to be the most 

under Alternative C. Because weed invasion 

and spread is directly related to the amount of 

Alternative D would have slightly more surface 

disturbance than under Alternative B but 

substantially less than under Alternative C.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-245

Table 2.14 Summary of Environmental Consequences by Alternative

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

surface disturbance, Alternative B would have 

the least risk of weed spread.

surface disturbance, Alternative C would have 

the most risk of weed spread.

Vegetation: Special Status Plants

Impacts to special status plants would likely result from actions proposed under the following resource programs: Soils, Vegetative Communities, Wildlife and Fisheries Habitat and Special Status 

Species, Wild Horses and Burro Management, Fire Ecology and Management, Cave and Karst Resources, Energy and Minerals Management, Livestock Grazing Management, Recreation and 

Visitor Services Management, Trails and Travel Management, Forestry and Woodland Products, Realty, Cadastral Survey, and Lands, Renewable Energy, and Special Designations. Other 

programs were determined to have little or no impact on special status plants.

The principle adverse impacts to BLM special status plant species result from management that increases surface disturbance and habitat fragmentation; the principle beneficial impacts include 

management that increases restrictions in known or potential BLM special status plant species habitat. Based on the acreage of surface disturbance, the potential for habitat fragmentation, and 

proactive management actions and special designations to protect BLM special status plant species, Alternatives with the least to most potential adverse impacts to BLM special status plant species 

are Alternatives B, D, A, and C. Alternative B would result in the least surface disturbance and habitat fragmentation, followed by Alternatives A, D, and C respectively. Alternative D contains 

management actions to minimize habitat fragmentation. Alternative B includes the most provisions to protect sensitive soils and riparian areas for the benefit of BLM special status plants. 

Restrictions on motorized vehicle use, especially restricting motorized cross-country travel, would reduce adverse impacts to BLM special status plant species in all Alternatives.

Wildlife Habitat and Special Status Species

Impacts to wildlife and special status species would likely result from actions proposed under the following resource programs: Soil Resources, Water Resources, Vegetative Communities, Wildlife 

Habitat and Special Status Species (Wildlife), Fisheries Including Habitat and Special Status Species (Fisheries), Wild Horses, Visual Resources, Fire Ecology and Management, Lands with 

wilderness characteristics, Cave and Karst Resources, Energy and Mineral Resources, Livestock Grazing, Recreation and Visitor Services, Trails and Travel Management, Forest and Wood 

Products, Realty, Cadastral Survey, and Lands, Transportation/Facilities Access, Renewable Energy, and Special Designations. Other programs were determined to have little or no impact on 

wildlife and special status species.

Because this area is mixed ownership with scattered public lands and BLM lands may have more restrictions for oil and gas leasing, oil and gas development companies would develop adjacent 

private and other lands rather than lease public lands. Wildlife management opportunities for the BLM are very limited in scattered land ownership areas due to the influence of developments on 

adjacent private lands. Mobile wildlife species, such as big game and birds, may be directly affected by management of habitat on surrounding ownerships. 

Actions that remove, degrade, or fragment wildlife habitat are considered adverse. Beneficial impacts include actions that conserve or improve habitats, such as big game crucial winter range, nest 

sites, or leks. Habitats can be lost and fragmented by activities such as vegetation treatments; fire and fuels management. Indirect impacts to wildlife can occur by changing habitat characteristics or 

quality. Habitat quality can be impacted by various surface-disturbing activities and other actions that remove vegetation and disturb soil. Indirect impacts to wildlife habitats also could occur when 

specific actions change the habitats in a way that would make it unsuitable for future habitation. The allowable uses and management actions for resources and resource uses are anticipated to 

result in a mix of beneficial and adverse impacts relative to wildfire management. The numbers of acres potentially impacted are identified in Table 4-24 “Average Treatment Acreage by Alternative.”

Alternative A would provide incidental impacts 

from management activities that have the 

potential to adversely affect wildlife and 

special status species (surface disturbance, 

disruptive activities, and direct habitat 

alteration/loss). However, fire management 

resulting in habitat manipulations could benefit 

wildlife and special status species over the 

long-term by improving vegetative conditions 

Alternative B, fire suppression activities would 

be limited to urban and industrial interface 

and developed recreational and electronics 

areas, reducing impacts to big game and 

Greater Sage-Grouse. Within these areas, 

any heavy equipment needed for suppression 

operations would be restricted to existing 

roads and trails or immediately adjacent to 

them, therefore avoiding adverse impacts 

Alternative C, suppression operations, 

including the use of heavy equipment would 

have fewer restrictions, which could degrade 

wildlife and special status species habitat. 

Impacts from wildfire management would 

have the same impacts as listed under 

Alternative B, except there would be no use of 

naturally ignited fires to benefit wildlife and 

associated habitat resources. This could limit 

Alternative D fire suppression activities would 

be limited to urban and industrial interface and 

developed recreational and electronics areas, 

reducing impacts to big game and Greater 

Sage-Grouse. Within these areas, any heavy 

equipment needed for suppression operations 

would be restricted to existing roads and trails 

or immediately adjacent to them, therefore 

avoiding adverse impacts within sensitive 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-246 Chapter 2: Resource Management Alternatives

Table 2.14 Summary of Environmental Consequences by Alternative

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

that are linked to forage and cover. within sensitive wildlife and special status 

species habitats. 

possible restoration through fire, necessary in 

certain habitats. In addition, prescribed fires 

would be allowed, including Greater SageGrouse habitat, if the activity is determined to 

benefit the sagebrush community or meet 

other resource objectives. This action would 

have short-term adverse impacts to species 

dependent on sage brush communities, but 

long-term beneficial impacts would be 

expected.

wildlife and special status species habitats. 

Exceptions would be permitted for protection of 

human life, property and/or to protect resource 

values from further loss due to

unwanted/unplanned natural or human caused 

wildland fires. Prescribed fires would be 

allowed, including Greater Sage-Grouse

habitat, if the activity is determined to benefit 

the sagebrush community or meet other 

resource objectives. This action would have

short-term adverse impacts to species 

dependent on sage brush communities, but 

long-term beneficial impacts would be 

expected.

This alternative would allow greater impacts to 

wildlife and SSS to occur and less beneficial 

wildlife habitat treatments would be developed 

than Alternatives, B, C, and D. Actions not 

addressed in this alternative, are travel 

management or road densities within 

important wildlife habitats, guidelines for 

stipulations to be applied to the operation and 

maintenance of production facilities or other 

projects, or restrictions for oil and gas leasing, 

development, and exploration within 

designated State Wildlife Management Areas. 

As a result, impacts to wildlife and associated 

habitat could include short-term and long-term 

adverse habitat loss and fragmentation, 

species displacement due to disturbance, and 

degradation of habitat quality.

Alternative B has additional protection for 

wildlife resources, including updated and 

larger scale stipulations for development 

versus Alternatives A and C. Alternative B 

would provide more protection than other 

Alternatives to wildlife and special status 

species from surface disturbance and 

disruptive activities, including travel 

management and road densities. This 

Alternative Closes or limits to administrative 

access more route miles than all Alternatives. 

Alternative A designates 83% of route miles 

as open, Alternative C designates 90% of 

route miles as open, and Alternative D 

designates 62% of route miles as open.

Generally, the impacts to wildlife and SSS 

would be greater than those described under 

Alternatives B and D, with less protection to 

wildlife resources due to smaller buffers and 

fewer avoidance areas for ROWs and other 

potential development. There would be less 

impact to wildlife than Alternative A with 

greater restrictions and areas closed to travel, 

and other development. 

The impacts to wildlife and SSS would be the 

same as those described under Alternative B

but with less protection to wildlife resources 

due to smaller buffers and fewer exclusion 

areas for potential development. Management 

actions would be less beneficial to wildlife and 

special status species than actions provided 

under Alternative B, creating the potential for 

more adverse impacts from human disturbance 

and habitat loss from surface disturbing 

activities, although protections would be 

greater than Alternatives A and C. Under 

Alternative D, there would be 614 miles of open 

routes (62% of all route miles). Alternative A 

designates 83% of route miles as open, 

Alternative B designates 35% of route miles as 

open and Alternative C designates 90% of 

route miles as open.

Particularly for Greater Sage-Grouse, recent 

research findings, have provided updated and 

more accurate seasonal timing restrictions 

and expanded protection distances. 

Research has demonstrated that both the 

0.25 mile and 2 mile buffer distances are not 

adequate for the protection of Greater SageGrouse populations. Leks with at least one oil 

This Alternative, including Alternatives C and 

D, designates Greater Sage-Grouse habitat 

areas (PHMAs, RAs, and GHMAs) versus 

Alternative A that does not recognize any 

special designation for Greater Sage-Grouse

habitat. PHMAs would be closed to future oil 

and gas leasing, exploration, and 

development, and grazing allotments would 

This alternative provides less protection for 

Greater Sage-Grouse and Greater SageGrouse habitat than Alternatives B and D and 

more protection than Alternative A. This is 

due to decreased protection distances and 

less restrictions than Alternatives B and D. 

Within Greater Sage-Grouse PHMAs, oil and 

gas leasing, development, and geophysical 

activities, as well as surface disturbance and 

disruptive activities would be similar to 

Alternative B. However, Alternative B is Closed 

to oil and gas leasing and Alternative D is an 

NSO. Grazing allotments would be designated 

management Category I allotments. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-247

Table 2.14 Summary of Environmental Consequences by Alternative

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

and gas well within a 0.4 km (0.25 miles) 

radius had 35-91% fewer attending males 

than leks with no well within this radius (Harju 

et al. 2010). A study in Musselshell and 

Golden Valley counties found that 98% of nest 

locations were within 3 miles of an active lek 

(Sika 2006). With regard to existing 

stipulations applied by the BLM (Walker et al. 

2007a) research has demonstrated that the 

0.4 km (0.25 mile) NSO stipulation is 

insufficient to conserve breeding Greater 

Sage-Grouse populations in fully developed 

gas fields because this buffer distance leaves 

98% of the landscape with 3.2 km. (2 miles) 

open to full-scale development. Full-field 

development of 98% of the landscape with 3.2 

km. (2 miles) of leks in a typical landscape in 

the Powder River Basin reduced the average 

probability of lek persistence from 87% to 5% 

(Walker et al. 2007a). Holloran (2005) shows 

that lek counts decreased with distance to the 

nearest active drilling rig, producing well, or 

main haul road, and that development 

influence counts of displaying males to a 

distance of between 4.7 and 6.2 km (2.9 and 

3.9 miles). Models with development at 6.4 km 

(4 miles) had considerably less support, but 

the regression coefficient indicated that 

impacts were still apparent out to 6.4 km (4 

miles) (Walker et al. 2007a).

be designated management Category I 

allotments. This alternative provides the 

greatest protection for the management of 

Greater Sage-Grouse and Greater SageGrouse habitat.

Only Alternative B establishes the Greater

Sage-Grouse Habitat ACEC on BLMadministered surface of Greater Sage-Grouse

PHMAs (158,926 acres)

Fisheries Habitat and Special Status Species

The management actions associated with the resources listed below may have impacts on water, riparian vegetation, fisheries, and special status fish species resources: Soil, Water, Vegetation

Communities, Wildlife Habitat and Special Status Species, Fisheries Habitat and Special Status Species, Wild Horses, Visual Resources, Fire Ecology and Management, Lands with wilderness 

characteristics, Energy and Mineral Resources, Forestry and Woodland Products, Livestock Grazing, Recreation and Visitor Services, Trails and Travel Management, and Special Designations. 

Those not listed have negligible or unapparent impacts

Under all Alternatives, fisheries resources would benefit from management in accordance with Rangeland Health Standards and applicable state and federal water-quality standards. Site-specific 

mitigation and BMPs for surface disturbing activities would further reduce impacts on fisheries resources. Adherence to these standards would reduce many of the adverse impacts from future 

actions. In addition, existing and proposed stipulations designed to protect water, riparian and fisheries resources would be beneficial by minimizing sediment and contaminant delivery potential by 

preventing or limiting surface-disturbing activities in proximity to hydrologic features. Stipulations and limitations for other resources that prevent or limit surface disturbing activities would provide 

additional protection for fisheries resources and thereby could be beneficial (e.g., fisheries, riparian). Furthermore, timing limitations could benefit fisheries resources by limiting or preventing 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-248 Chapter 2: Resource Management Alternatives

Table 2.14 Summary of Environmental Consequences by Alternative

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

surface-disturbing activities during times of the year when saturated soil conditions exist or when precipitation and runoff are frequent (e.g., winter, spring). However, with the scattered distribution 

and sparse ownership of BLM administered lands in the planning area, stipulations and management actions to minimize impacts to fisheries resources may not prevent poor conditions on BLM 

waterways, as is the current situation in some areas. 

Under Alternative A actions, impacts to 

fisheries resources primarily occur from 

erosion, sedimentation and degradation of 

riparian resources. Currently, priority fishery 

resources are not being impacted from BLM 

authorized activities. Other fisheries resources 

are impacted from sediment delivery and 

degraded water quality. The source of these 

impacts is hard to identify, as the Billings Field 

Office has a scattered land pattern (for 

example, in many cases only a 1⁄4 or 1⁄2 mile of 

stream may be managed by the BLM, while 

the remaining 10 miles is under private 

ownership). Where riparian conditions are 

degraded, alternative A requires management 

actions to move the area towards PFC. BLM 

authorized surface disturbing activities have 

negligible impacts to fisheries resources in all 

alternatives, however, proposed development 

would restrict activities that degrade water 

quality or riparian functionality (hence, 

protecting fisheries habitat and water quality) 

under this alternative.

Actions under Alternative B provide the 

highest level of protection to fisheries 

resources. Larger buffers and more 

restrictions for surface disturbing activities 

would be implemented to conserve fish 

habitat. Perennial and fish bearing streams 

would be classified a “priority” for monitoring 

and improvement.

Impacts would be the same as described in 

Alternative A.

Compared to Alternative A, Alternative D 

conserves GSG habitat by converting custodial 

allotments to category I and restricting surface 

disturbing activities with an NSO stipulation for 

oil and gas and similar management for other 

uses.

Compared to Alternative A, Alternative D would 

be beneficial to fisheries resources by applying 

measures and stipulations that restrict surface 

disturbing activities within 300 feet of water 

bodies and riparian areas, minimizing potential 

adverse impacts from those activities to water 

quality and aquatic habitat.

Wild Horses 

The following resources or resource uses have been determined to have little or no impacts to wild horses or the Pryor Mountain Wild Horse Range from BLM authorized uses and management:

Air, Climate, Geology, Cave and Karst Resources, Energy and Mineral Materials, Forestry and Woodland Products, Renewable Energy, National Historic Trails, Transportation and Facilities, Wild 

and Scenic River, Fisheries Habitat and Special Status Species, Wildlife Habitat and Special Status Species. 

Under Alternative A, management of the 

PMWHR and wild horses would remain the 

same as is currently occurring. 

Under Alternative B the PMWHR would be 

limited to within the 1968 and 1969 

Secretarial Orders only. The maximum 

amount of protection would be allowed for the 

wild horses and the rangeland resources. 

The wild horse population would initially be 

managed for 90 wild horses due to a 

reduction from the current size and limited 

water sources. 

Under Alternative C the PMWHR would be 

managed within the entire Herd Area. This 

Alternative would result in extensive fencing 

of private property owners and re-routing of 

county roads. The length of time to implement 

this could be very long. Wild horses would 

abut to private property owners and domestic 

horses. 

The boundary fence on the south end of the 

Under Alternative D the PMWHR would be 

managed to include a majority of the Herd 

Area. The administrative pastures would be reopened and a buffer between private property 

and the wild horse range would be in place to 

reduce conflict and protection of wild horses. 

Within the confines of meeting other multipleuse mandates (i.e. WSA, ACEC, SSS 

protections) habitat and range improvement 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-249

Table 2.14 Summary of Environmental Consequences by Alternative

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

All range improvements would be removed 

(i.e. water tanks, guzzlers, reservoirs), access 

would be limited and natural processes would 

be primary to other resources. 

Greater potential for loss of genetic diversity 

(if no animals are introduced) would happen. 

Greater wild horse removals and other 

population control methods would occur under 

this management scenario.

PMWHR would be the private property fence 

line. 

Within the confines of meeting other multipleuse mandates (i.e. WSA, ACEC, SSS 

protections) habitat and range improvement 

work would be maximized. 

Very little management of recreational and 

visitor activities would occur. 

The conflict between people and wild horses 

would increase. Impacts to wild horse habitat 

would increase from visitation and recreation 

under this Alternative. 

work would be maximized.

Area-wide restrictions would be implemented 

to enhance protections for wild horses, habitat, 

and public safety. 

More intensive management of recreational 

uses and visitor activities would occur. Conflict 

between users in and around wild horses would 

be reduced.

Cultural/Heritage Resources

Impacts to cultural and heritage resources would likely result from actions proposed under the following resource programs: Water, Vegetation, Wildlife Habitat and Special Status Species, 

Fisheries Habitat and Special Status Species, Wild Horses, Cultural and Heritage Resources, Fire Ecology and Management, Visual Resources, Lands with wilderness characteristics, Energy and 

Mineral Resources, Forestry and Woodland Products, Realty, Cadastral Survey, and Lands, Livestock Grazing, Recreation and Visitor Services, Trails and Travel Management, Renewable Energy, 

and Special Designations. Other programs were determined to have little or no impact on cultural and heritage resources

Impacts to cultural resources in the Pryor Mountains would continue to occur as an indirect result of permits issues through the Recreation program (SRPs) and the Realty, Cadastral Survey, and 

Lands program (commercial film permits). This impact remains the same across all alternatives. 

Under Alternative B, C, and D, authorized surface disturbances would be minimized (see glossary for definition of surface disturbing activities). 

This would protect cultural and heritage resources from being impacted by the proposed activity. However, as a cultural inventory is required for all 

surface disturbing activities, the knowledge gained by each inventory adds to the database of known and recorded sites, which enables the BLM to 

better manage the resources and activities occurring in a specific location.

Under Alternative A, only specific 

identified/recorded sites would be allocated to 

conservation or socio-cultural use. 

Under Alternative B the majority of National 

Register eligible sites would be allocated and 

managed by site type for Conservation, 

Traditional and/or Scientific Use. No 

interpretative sites would be considered or 

developed.

Under Alternative C the majority of National 

Register eligible sites would be allocated and 

managed by site type for Conservation, 

Scientific, Public and/or Traditional Use (as 

appropriate). Interpretative sites could be 

developed. 

Under Alternative D the majority of National 

Register eligible site types would be allocated 

and managed by site type for Conservation, 

Scientific, Traditional, and/or Public Use. 

Interpretative sites would be considered and 

developed as appropriate for the resource.

Paleontological Resources

Impacts to paleontological resources would result from actions proposed under the following resource management programs: Soil, Water, Vegetation, Wildlife Habitat and Special Status Species, 

Fisheries Habitat and Special Status Species, Cultural Resources, Paleontological Resources, Fire Ecology and Management, Lands with wilderness characteristics, Energy and Mineral 

Resources, Forestry and Woodland Products, Realty, Cadastral Survey, and Lands, Livestock Grazing, Recreation and Visitor Services, Trails and Travel Management, Renewable Energy, and 

Special Designations. For all Alternatives, Paleontological Resources would not be impacted by Air, Climate Change, Geology, Wild Horses, Visual Resources, Cave and Karst Resources, or 

Transportation and Facilities.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-250 Chapter 2: Resource Management Alternatives

Table 2.14 Summary of Environmental Consequences by Alternative

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Impacts on paleontological resources occur from natural weathering and erosion and from surface disturbing activities, excavation, and theft or vandalism. In general, impacts on paleontological 

resources include the physical destruction or damage of fossil-bearing geological formations resulting in the loss of vertebrate fossils or other scientifically significant fossil resources and their 

geologic content. Without removing some rock surrounding fossils, the fossils would remain largely undetected; therefore, management actions that result in erosion do not necessarily result in 

damage to paleontological resources. Excessive erosion, especially from other surface disturbance, could damage fossils at the surface.

Impacts on paleontological resources would result from management actions that could cause surface disturbance. Because of their widespread occurrence and generally unsupervised nature, 

casual recreation and OHV use would likely have the greatest impact on paleontological resources. Unlike permitted activities (e.g. oil and gas development or ROW development) that are subject 

to site-specific evaluations and monitoring, recreation and OHV activity are not under much scrutiny. Realty, Cadastral Survey, and Lands actions could also remove or add land subject to federal 

protections for paleontological resources. To a lesser extent, effects on paleontological resources could occur from actions that open or close land to minor surface disturbances, allow potentially 

incompatible uses, and actions that could affect natural processes such as erosion.

The impacts to paleontological resources do not vary by Alternative, the intensity of impacts may vary, but the impacts are the same regardless of the Alternative. Management actions with the most 

potential to impact paleontological resources include minerals and energy development, fire suppression, vandalism, dispersed recreation, and unauthorized collection of paleontological resources. 

The intensity of impacts would be greatest under Alternative A, followed by Alternatives C, D, and B. 

Paleontological Resources are mitigated on a 

case by case basis. No inventory is required.

Costs would increase for the proponents as a result of requiring an assessment, inventory and/or mitigation of paleontological resources if the 

activity is located in a PFYC Class 3 or higher area. 

No inventory required for surface disturbing 

activities occurring in PFYC 3 or higher areas.

Costs would increase for the proponent and the BLM as a result of assessment, inventory and/or mitigation of paleontological resources if the 

activity is located in a PFYC Class 3 or higher area. 

Visual Resources

Impacts to Visual Resources would result from actions proposed under the following resource management programs: Vegetation, Wildlife habitat and Special Status Species, Fisheries habitat and 

special status species, Cultural Resources, Visual Resources, Wildland Fire Ecology and Management, Energy and Mineral resources, Forestry and Woodland Products, Realty, Cadastral Survey, 

and Lands, Livestock Grazing, Recreation, Trails and Travel Management, Renewable Energy, and Special Designations. Other programs were determined to have little or no impact on visual 

resources.

The potential cumulative impacts of this 

RMP/EIS Alternative A, combined with past, 

present, and reasonably foreseeable future 

actions on visual resources could adversely 

affect visual resources and scenic quality from 

increasing minerals and recreation-related 

surface disturbances and from wildfires. 

However, mitigation would likely limit the 

impacts in viewsheds with high scenic quality 

in the BiFO.

Past and present management, and reasonably foreseeable future actions, combined with the proposed action Alternatives (the RMP/EIS 

Alternatives B, C, and D), would reduce the potential for cumulative impacts on visual resources, and preserve scenic quality. The risks of wildfire 

would be reduced within the BiFO and on adjacent national forests through increased vegetation treatments to reduce fuel loads; recreation 

activities and off-road travel would be managed to limit surface disturbances by greatly reducing the potential for illegal or unrestricted OHV use, so 

that areas inventoried as having high scenic quality would be preserved. Mineral exploration, development, and extraction, including oil and natural 

gas well drilling, are expected to increase over the next 15 years to 20 years, but visual resource management and associated mitigation would 

likely limit the impacts in view sheds with high scenic quality and in the adjacent national parks and national forests. Visual resource management 

would include conformance of minerals exploration and development activities with VRM class objectives, which would preserve scenic quality in 

the long term in areas that the plan has designated for scenic quality protection.

Fire Ecology and Management

Impacts to fire and fuels management would result from actions proposed under the following resource management programs: Air Quality, Vegetation, Special Status Species, Fish and Wildlife, 

Cultural Resources, Visual Resources, Fire and Fuels Management, Forestry and Woodland Products, Livestock Grazing, Recreation, Travel Management, Minerals and Energy, and Special 

Designations. Other programs were determined to have little or no impact on fire and fuels management.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-251

Table 2.14 Summary of Environmental Consequences by Alternative

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Actions limiting fire suppression tactics, thereby resulting in larger burn areas or more intense fire, are considered adverse impacts. Conversely, actions contributing to a decrease in the incidence 

of resource damaging wildfires, including restoring natural Fire Regime Condition Classes are beneficial impacts

Wilderness Characteristics

The types of impacts are described as being categorized based on the wilderness qualities of naturalness, undeveloped character, opportunities for solitude, or primitive and unconfined recreation 

and untrammeled quality. Impacts to non-WSA lands with wilderness characteristics would likely result from actions proposed under the following resource management programs: Vegetation, 

Wildlife Special Status Species, Fish Special Status Species, Wild Horses, Cultural Resources, Visual Resources, Wildland Fire Ecology and Management, Wilderness Characteristics, Minerals and 

Energy, Realty, Cadastral Survey, and Lands, Livestock Grazing, Recreation and Visitor Services, Travel Management, and Special Designations. Other programs were determined to have little or 

no impact on non-WSA lands with wilderness characteristics. 

Under Alternative A, management actions 

would protect, preserve, and maintain the 

wilderness characteristics on 1,925 acres.

Alternative B management actions would 

protect, preserve, and maintain the wilderness 

characteristics on 33,077 acres.

Alternative C management actions would 

protect, preserve, and maintain the wilderness 

characteristics on 3,379 acres

Alternative D management actions would 

protect, preserve, and maintain the wilderness 

characteristics on 13,653 acres. 

Cave and Karsts

Impacts to cave and karst management would likely result from actions proposed under the following resource programs: Wildlife habitat and Special Status Species, Cave and Karst Resources, 

Recreation, and Energy and Mineral Resources. Other programs were determined to have little or no impact on cave and karst resources. 

Cave and Karsts are managed as mandated by the Federal Cave Resources Protection Act as well as other Acts such as the Endangered Species 

Act. Management actions in the RMP are in conformance with these prescriptions and protect the unique, nonrenewable, and fragile biological, 

geological, hydrological, cultural, paleontological, scientific, and recreational values. The management actions would result in significant 

restrictions of casual use of Caves and Karsts but also provide more directed and focused responses due to the mandate for development of a 

specific Cave and karsts Management Plan. 

Resource Uses

Energy and Mineral Resources: Solid Leasable Minerals, including Coal

Implementing management actions under the Alternatives may result in direct impacts that open, limit, or deny access to solid mineral (leasable, locatable, and salable) development in the 

planning area. 

Coal development could occur under Alternatives A, C, and D. However, under Alternative B, future coal leasing actions would be prohibited. Most of the areas closed to coal development in 

Alternatives A, C, and D occur in areas where the coal development potential is extremely low, or does not exist.

Alternative A contains the lowest number of 

acres unavailable to coal leasing.

Alternative B contains the highest number of 

acres unavailable to coal leasing. 

Alternative C contains more acres unavailable 

to coal leasing than Alternative A, but less 

than Alternative B and D.

Alternative D contains more acres unavailable 

to coal leasing than Alternatives A and C, but 

less acres than Alternative B. 

Energy and Mineral Resources: Fluid Minerals

Total Projected New Oil and Gas Wells per 

year - 2 to 4

Total Projected New Oil and Gas Wells per 

year – 2 to 4

Total Projected New Oil and Gas Wells per 

year - 2 to 4

All federal mineral leases would be subject to standard lease terms. The impacts to fluid minerals would vary depending in the number of acres available for leasing with standard lease terms and 

the number of acres available for leasing with major and moderate constraints. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-252 Chapter 2: Resource Management Alternatives

Table 2.14 Summary of Environmental Consequences by Alternative

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Continuation of current management would 

result in the availability of approximately 

633,582 acres for fluid mineral leasing across 

the entire decision area. Approximately 

61,100 acres of BLM subsurface ownership 

would be unavailable (4.9% of the total BLM 

oil and gas estate; Table 4-29), including four 

WSAs: The remainder of federal mineral 

estate lands would be available for leasing, 

subject to the stipulations specified in Chapter 

2 or under Standard Lease Terms. 

Table 4-30 displays areas affected by no 

surface occupancy, timing limitations, and 

controlled surface use oil and gas stipulations.

Approximately 421,852acres would be 

available for fluid mineral leasing under 

Alternative B. Approximately 302,713 acres of 

BLM-administered federal mineral estate 

lands would not be available for oil and gas 

leasing (34.3% of the total BLM oil and gas 

estate; Table 4-32) including four WSAs: The 

remainder of federal mineral estate lands in 

the Planning Area would be available for 

leasing, subject to the stipulations specified in 

Chapter 2 or to Standard Lease Terms.

Under Alternative C, 65,891 acres of the 

Decision Area would not be available for oil 

and gas leasing (5.2% of the total BLM oil and 

gas estate; Table 4-34) including four WSAs: 

This includes the Wilderness Study Areas 

identified in Alternative B plus discretionary no 

lease areas. The remainder of mineral estate 

in the Planning Area (610,151 acres) would 

be available for leasing, subject to the 

stipulations specified in Chapter 2 or to 

Standard Lease Terms.

Under Alternative D approximately 606,096 

acres would be available for fluid mineral 

leasing. A total of 60,359 acres of federal 

mineral estate lands would not be available for 

oil and gas leasing (approximately 7% of the 

total BLM oil and gas estate) including the 

Wilderness Study Areas.

Effects would be similar to Alternative A with 

respect to overall acres of BLM administered 

land available for leasing and not available for 

leasing (compare Tables 4-31, 4-34, 4-37, and 

4-40). However, Alternative D would apply 

stipulations to different acres. For example, 

there are fewer acres of land under No Surface 

Occupancy and Controlled Surface Use 

stipulations and a much larger number of acres 

under Timing Limitations and Standard Lease 

Terms stipulations under Alternative A, than 

Alternative D (Tables 4-31, 4-34, 4-37, and 4-

40). As a result Alternative D includes more 

area with No Surface Occupancy and would be 

more stringent in the application of stipulations 

for leasing of essentially the same amount of 

land as Alternative A.

Energy and Mineral Resources: Locatable Minerals

Implementation of the Alternatives would result in some public lands being opened or withdrawn from locatable mineral entry under the mining laws. Such actions could affect the ability of potential 

mining claimants and/or exploration and mining companies to explore and develop locatable minerals in the planning area. Management actions that restrict access are long term in nature and the 

withdrawals are for 20-year periods from the operation of the mining laws, subject to valid existing rights. In these instances, only valid, existing mining claims can be developed. Subject to such 

valid existing rights, exploration, staking of new mining claims, development, or mining on withdrawn federal mineral estate is prohibited.

Under the existing Billings Resource Area RMP (BLM, 1984), the entire planning area is open to locatable mineral entry except for 1,855 acres which are currently withdrawn. Areas recommended 

for withdrawal from locatable mineral entry in the planning area range from 39,700 acres (Alternative A) to 270,977 acres (Alternative B). In cases involving valid mining claims, exploration for 

locatable minerals would occur under all Alternatives. The impact of the locatable mineral withdrawals would be minimal because bentonite is the only locatable mineral located within the decision 

area and while there are a great number of acres, the potential is low throughout the majority of the decision area, with the exception of Carbon County. 

Energy and Mineral Resources: Mineral Materials

Implementing management actions under the alternatives may result in direct impacts that open, limit or deny access to the disposition of mineral materials from public lands in the planning area. 

Adverse impacts to mineral materials disposal can result from management actions that restrict or limit disposals of mineral materials, or that place specific stipulations or mitigation requirements on 

development activity. Beneficial impacts to mineral materials disposal can result from management actions that encourage disposal or opens areas to disposal.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-253

Table 2.14 Summary of Environmental Consequences by Alternative

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Indirect impacts result from actions that place or remove restrictions, or place additional requirements on the exploration and development activities for mineral materials. For example, actions taken 

to preserve Greater Sage-Grouse habitat could either prevent or constrain the exploration and development of mineral materials. 

Short-term impacts may include such seasonal restrictions to accessing mineral material resources to protect Greater Sage-Grouse, or delays caused by requiring the completion of resource 

surveys (such as cultural resources) before commencing mining operations. Long-term impacts may include transferring federal mineral estate, including the mineral materials therein, to private 

ownership, thereby potentially removing the resource from public access, as allowed by 43 CFR 2720 and FLPMA Section 209(b)(1).

Under the existing Billings Resource Area 

RMP (BLM, 1984), the entire planning area is 

open for the development of mineral materials 

except for 44,583 acres which are currently 

closed to disposal.

Areas recommended for closure to mineral materials disposal in the planning area range from 44,583 acres (Alternative A) to 343,745 acres 

(Alternative B). Although there is a wide variance between Alternatives, the plan would provide land-use opportunities for the development of 

mineral materials. It would provide economic benefits and meet local infrastructure needs while protecting or minimizing adverse impacts to other 

resources and their uses.

Realty, Cadastral Survey, and Lands: Land Tenure Adjustment and Access, Rights-of-Way/Leases/Permits, and Withdrawals

Impacts to land tenure, ROWs/Leases/Permits, and withdrawals would likely result from actions proposed under the following resource programs: Soils, Water, Vegetation, Wildlife Habitat and 

Special Status Species, Fisheries Habitat and Special Status Species, Cultural Resources, Paleontological Resources, Visual Resources, Wildfire Ecology & Management, Lands with wilderness 

characteristics, Cave and Karst Resources, Energy and Mineral Resources, Realty, Cadastral Survey, and Lands, Recreation and Visitor Services, Trails and Travel Management, Renewable 

Energy, Transportation and Facilities, and Special Designations. Other programs were determined to have little or no impact on Realty, Cadastral Survey, and Lands.

The designation of ROW avoidance and exclusion areas on BLM lands, along with similar restrictions on ROW development on adjacent lands, would have a cumulative impact of reducing overall 

routing options for ROW facilities such as utilities and roads. Restrictions on ROWs in the decision area, combined with restrictions form other management plans in the planning area, would have 

an incremental effect by limiting the location of the ROW. Alternatives B and D have the most avoidance and exclusion areas; and the fewest ROW avoidance and exclusion areas identified in 

Alternative A.

The increased number of acres of ROW exclusion and avoidance areas located on BLM lands could increase development costs for the applicants.

Livestock Grazing

Impacts to livestock grazing would likely result from actions proposed under the following resource management programs: Soil, Water, Vegetation, Wildlife and Fisheries Habitat and Special 

Status Species, Fire Ecology and Management, Cultural / Paleontological / Historic Resources, Energy and Mineral Development, Realty, Cadastral Survey, and Lands, Livestock Grazing, 

Recreation, Travel Management, and Special Designations. Other programs were determined to have little or no impact on livestock grazing. 

The types of impacts projected to occur to livestock grazing management because of each Alternative are similar and include changes in AUM allocations and rangeland health. The factors causing 

these impacts primarily include surface-disturbing activities, restrictions protecting resource values, fire and fuels management, invasive species and noxious weeds, and proactive management 

actions. Changes in AUM allocations and rangeland health, and the associated causative factors of these changes, are described below as impacts common to all Alternatives. How the intensity of 

these impacts varies by Alternative is described under individual Alternatives.

Alternative A would maintain the status quo for 

allotment categorization (I: Improve, M: 

Maintain and C: Custodial). Under this 

alternative, allotments with high priority 

resource issues are categorized as I and 

receive the highest priority for improvement 

(mainly staff, planning and funding) and 

Alternative B re-categorizes all allotments 

within the PHMA boundaries to the I category. 

Under this alternative, all allotments within the 

boundary of the PHMA would receive priority 

for protection, maintenance, improvement and 

monitoring. Impacts to staff and funding levels 

with creation of the newly re-categorized 

Impacts under Alternative C are the same as 

Alternative A for both monitoring and allotment 

categorization.

Alternative D is essentially the same as 

Alternative B, with the exception that 

Alternative D includes the continued priority 

for monitoring of existing allotment 

management plans that are currently in place.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-254 Chapter 2: Resource Management Alternatives

Table 2.14 Summary of Environmental Consequences by Alternative

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

monitoring. As I allotments improve to a level 

where they are meeting the standards for 

rangeland health (or making significant 

progress towards meeting the standards) the 

category can be lowered to the M category so 

that staff and funding can be put towards other 

allotments that require improvement. Category 

C allotments are typically small (less than 320 

acres), isolated and unfenced parcels with 

little or no management potential (other than 

season of use), and are managed under the 

custodial oversight of the grazing permittee. 

There are currently 35 I category allotments, 

111 M category allotments and 253 C 

category allotments.

Impacts under this alternative would be 

minimal to staff and funding. The flexibility to 

change categorization based on improving 

resource conditions is maximized. 

allotments would be low to moderate and 

dependent on existing resource conditions 

and the degree of departure from the 

standards for rangeland health, if any. 

Existing I allotments outside PHMAs would 

continue to be treated the same as under 

Alternative A.

Recreation and Visitor Services

Impacts to recreation would likely result from actions proposed under the following resource programs: Air, Vegetation, Wildlife habitat and Special Status Species, Fish Habitat and Special Status 

Species, Wild Horses, Cultural Resources, Paleontological Resources, Visual Resources, Wildfire Ecology and Management, Lands with wilderness characteristics, Cave and Karsts Resources, 

Minerals and Energy, Realty, Cadastral Survey, and Lands, Livestock Grazing, Forestry and Woodland Resources, Recreation, Travel Management, Renewable Energy, and Special Designations. 

Other programs were determined to have little or no impact on recreation. 

Various past, present, and reasonably foreseeable future BLM actions have affected and would continue to affect recreational opportunities within the planning area, including mineral development, 

wildfire suppression and fuels treatments, OHV travel, utility corridor development, grazing and recreational activities in riparian areas, and management within existing SRMAs and the ERMA. The 

increase in vehicle-based recreation and urban development and associated population growth all contribute to increased demand for recreational opportunities in the region. As a result, the 

planning area could experience increased recreational visitors over the life of the plan, which could degrade certain recreational settings, resulting in diminished recreational opportunities and 

experiences, or increase user conflicts associated with dispersed unconfined recreational opportunities. Similarly, increasing development or utilities within or near the BiFO could degrade certain 

recreational settings. The increase in recreational activities is minimally a result of BLM actions. There would be a minor incremental impact to recreational opportunities and experiences from the 

Proposed RMP management actions. The issuance of SRPs would not be affected by the change of management emphasis between Alternatives. 

Trails and Travel Management

Impacts to travel management would likely result from actions proposed under the following resource programs: Wildlife habitat and Special Status Species, Non-WSA Lands with wilderness 

characteristics, Realty, Cadastral Survey, and Lands, Recreation, Travel Management, Renewable Energy, and Special Designations. Other programs were determined to have little or no impact 

on travel management.

The Proposed RMP management actions for closing 99% of the decision area to cross-country OHV travel in combination with similar management actions of adjacent field offices and agencies 

would incrementally reduce opportunities for cross-country OHV travel.

There is no comprehensive FO-wide In contrast, the Proposed RMP and Alternatives B, C, and D management actions designate individual non-motorized trails and entire non-motorized trail 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-255

Table 2.14 Summary of Environmental Consequences by Alternative

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

non-motorized trail system, just an 

assortment of trails developed on an 

ad-hoc basis.

systems in chosen locations throughout the FO. Recreational opportunities and experiences are identified through the BLM design process specified in the 

relevant Manuals and Guidance documents are implemented and the user experiences are enhanced.

Areas protected from development 

have guided in the past, and would 

continue to guide, the location and 

development of many highways and 

roads near and within the BiFO. 

In contrast, the Proposed RMP and Alternatives B, C, and D management actions restrict travel within the BiFO mostly to designated routes and very few, if 

any, additional routes would be developed. As a result, there could be increased concentrations of vehicles within certain areas of the BiFO, that is, 

restricting the miles of roads open for motorized travel would be expected to increase vehicle concentrations more in the BiFO than in surrounding areas that 

do not impose travel restrictions.

Renewable Energy

Impacts to wind energy would likely result from actions/restrictions proposed under the following resource programs: Wild Horse Management, Wildlife Habitat and Special Status Species, Cultural 

and Heritage Resources, Renewable Energy, Realty, Cadastral Survey, and Lands, Special Designations, and Visual Resource Management. Other programs were determined to have little or no 

impact on renewable energy. 

Managing 47,496 acres as renewable energy 

exclusion areas (closed) would remove 11% 

of BLM-administered land in the planning area 

from wind development, of which 12,372 

acres are high and 6,350 acres are moderate 

development potential. Table 4-41 shows the 

impact allocations in this Alternative have on 

the availability of land for wind energy 

development.

Opportunity for development is provided to the 

greatest degree by this Alternative, especially 

on the 50,135 acres of high potential land that 

would be managed as open (see Map 153) 

as long as resource issues could be resolved 

and important values protected with BMPs 

and standard stipulations. 

Managing 345,491 acres as renewable 

energy exclusion areas (closed) would 

remove 80% of BLM-administered land in the 

planning area from wind development, of 

which 53,537 acres are high and 111,742

acres are moderate in development potential. 

Table 4-42 shows the impact of allocations in 

this Alternative on the availability of land for 

wind energy development.

Maximizing restrictions under this Alternative 

would remove the greatest number of acres 

exhibiting high wind resources of any 

Alternative, severely impacting opportunities 

for development. This would be the most 

restrictive of any of the Alternatives for wind 

development with no areas considered “open” 

(see Map 154). However, exclusion of 

renewable energy development from lands 

with wilderness characteristics would affect 

only low potential wind areas. Should 

technologies be developed in the future to 

take advantage of winds in lower potential 

areas, as well as to better mitigate impacts, 

this Alternative would have detrimental longterm impacts on industry and renewable 

energy development in the BiFO. 

Managing 82,019 acres as renewable energy 

exclusion areas (closed) would remove 19% 

of BLM-administered land in the planning area 

from wind development, of which 19,960 

acres are high and 15,358 acres are 

moderate in development potential. Table 4-

43 shows the impact of allocations in this 

Alternative on the availability of land for wind 

energy development.

Application of special design features, timing 

limitations, and other restrictions would 

increase costs and processing time, and in 

some instances, result in applications being 

withdrawn by industry as described under 

Impacts from Management Common to All 

Alternatives. Allowing wind energy 

development in the Pryor Foothills ACEC and 

in Greater Sage-Grouse PHMAs and RAs if 

Greater Sage-Grouse habitat suitability would 

be maintained would potentially increase the 

amount of acreage available for wind 

development in comparison to Alternative B, 

where development in Greater Sage-Grouse

areas is excluded. Managing VRM Class III as 

open rather than as avoidance areas could 

result in additional development flexibility, 

Managing 231,775 acres as renewable energy

exclusion areas (closed) would remove 53% of 

BLM-administered land in the planning area 

from wind development, of which 38,558 acres 

are high in development potential. Table 4-44

shows the impact of allocations in this 

Alternative on the availability of land for wind 

energy development. 

Impacts are similar to Alternative C, though 

different timing limitation and distances would 

be applied for some resources. Areas such as 

the Pryor Foothills ACEC and slopes over 30% 

would be managed for avoidance rather than 

exclusion, which provides additional flexibility 

for development on about 2,500 additional high 

wind potential acres. Under Alternative D, the 

1,512 acres of open BLM-administered land, 

including 360 acres with High wind potential 

and 502 acres with Moderate wind potential 

would provide opportunities similar to 

Alternative C for generation of renewable 

energy to meet agency goals and potentially 

assist in reducing reliance on other energy 

sources and in turn, reduce emissions from 

other generating sources. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-256 Chapter 2: Resource Management Alternatives

Table 2.14 Summary of Environmental Consequences by Alternative

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

though VRM objectives must still be met. 

Special Designations

Pompeys Pillar National Monument and ACEC

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.

The ACEC would be available for oil and gas leasing, subject to a No Surface Occupancy (NSO) stipulation. The 432 acres within the ACEC have low mineral development potential; therefore, 

while the NSO stipulation protects the values of concern within the ACEC, there would be minimal adverse impacts to oil and gas leasing. Pompeys Pillar National Monument (51 acres) which is 

included in a portion of the ACEC, would be managed to protect the historical and cultural objects for which is was nominated, and would be withdrawn from all forms of entry, location, selection, 

sale or disposition, subject to valid existing rights.

The National Historic Landmark (NHL 6 acres) which includes the rock feature itself, would be managed as a VRM Class II to protect the values associated with the landform. The remainder of the 

ACEC would be managed as VRM Class III. This would allow for interpretive and educational programming, facilities and access to and within the site, while ensuring the visual quality and visual 

obtrusions are minimized or mitigated to protect the scenic values of the area.

Areas of Critical Environmental Concern

Nine ACECs would be retained for a total of

37,896 acres. 

Wind Energy development could occur in 

ACECs under this alternative. 

Target shooting is allowed in the cultural 

ACECs.

Nine ACECs would be retained and three

ACECs proposed for a total of 185,861 acres. 

Under this action alternative the management 

of the ACECs is the most restrictive. 

Nine ACECs would be retained and two 

ACECs proposed for a total of 67,079 acres. 

Under this alternative the management of the 

ACECs is the least restrictive.

Nine ACECs would be retained and two 

ACECs proposed for a total of 38,786 acres. 

Under this alternative, the total acreage for all 

11 ACECs is between Alternatives B and C and 

the management would protect the values of 

each ACEC.

Wild and Scenic Rivers

Manage all of the eligible river segments 

(14.08 miles) to protect their outstandingly 

remarkable values, free-flowing nature, and 

tentative classification, as follows:

• Bad Canyon

• Bear Canyon

• Crooked Creek (upper)

• Crooked Creek (lower)

• Gyp Springs

• Piney Creek

• Yellowstone River/Pompeys Pillar

Recommend all of the eligible river segments 

(14.08 miles) as suitable for inclusion in the 

National Wild and Scenic River System to 

protect their outstandingly remarkable values, 

free-flowing nature, and tentative 

classification, as follows:

• Bad Canyon

• Bear Canyon

• Crooked Creek (upper)

• Crooked Creek (lower)

• Gyp Springs

• Piney Creek

• Yellowstone River/Pompeys Pillar

Manage none of the eligible river segments 

(14.08 miles) to protect their outstandingly 

remarkable values, free-flowing nature, and 

tentative classification, as follows:

• Bad Canyon

• Bear Canyon

• Crooked Creek (upper)

• Crooked Creek (lower)

• Gyp Springs

• Piney Creek

• Yellowstone River/Pompeys Pillar

None of the eligible river segments would be 

recommended as suitable for inclusion in the 

National Wild and Scenic River system.

Manage the following river segments (3.15 

miles) as suitable to protect their outstandingly 

remarkable values, free-flowing nature, and 

classification.

The following segments would be 

recommended as suitable for inclusion in the 

National Wild and Scenic River System:

• Crooked Creek (above fish barrier – 1.59 

miles); tentative management class would be 

Wild.

• Crooked Creek (below fish barrier – 1.56 

miles); tentative management class would be 

Scenic.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-257

Notes: 

Based upon the programmatic and strategic nature of the RMP alternatives, this table reflects the potential for environmental consequences. 

Closed to leasing means deferred for the life of the plan. 

1 These impacts are anticipated to occur outside of the planning area 

ACEC Area of Critical Environmental Concern AUM animal unit month 

BLM Bureau of Land Management MAAQS Montana Ambient Air Quality Standards 

N/A not applicable NAAQS National Ambient Air Quality Standards 

NHT National Historic Trail OHV off-highway vehicle 

ROW Right-of-Way SRMA Special Recreation Management Area 

TMA Travel Management Area VRM Visual Resource Management 

WH Wild Horses WSA Wilderness Study Area 

WSR Wild and Scenic River
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-258 Chapter 2: Resource Management Alternatives

Table 2.15 Summary Comparison of Impacts

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Social

Continuation of current management would 

maintain the quality of life of permittees, 

those who favor resource use including 

some residents of small communities. 

Those who favor resource protection would 

not feel resources such as wildlife and plant 

habitat would receive adequate protection. 

Issue between motorized and nonmotorized recreation would not be 

addressed.

Alternative B would enhance the quality of life 

of those who favor resource protection and 

non-motorized recreation use. Those who 

favor resource use including some residents 

of small communities may feel that their 

interests are not adequately protected. Some 

of the issues between motorized and nonmotorized use would be addressed but at the 

expense of motorized users.

Alterative C would maintain or enhance the 

quality of life of permittees, those who favor 

resource use and residents of small 

communities. Those who favor resource 

protection would not feel resources such as 

wildlife and plant habitat would receive 

adequate protection. Some of the issues 

between motorized and non-motorized use 

would be addressed but at the expense of 

non-motorized users.

Alternative D offers a balance between 

resource use and resource protection which 

would meet many of the needs of the groups 

and individuals interested in public lands. Both 

motorized and non-motorized recreation use 

would be enhanced and many of the issues 

that currently exist on these public lands would 

be addressed.

Economics

Air 

Economic costs or benefits from air resource management (cost of emission reduction techniques and revenue from emission capture or reduction) associated with resource uses are unknown.

Climate Change

Economic costs or benefits from GHG emission reduction (cost of emission reduction techniques and revenue from emission capture or reduction) associated with resource uses are unknown. 

Agricultural and Livestock Use (Common)

BLM would continue to provide about 1% of the total livestock forage needs in the local economy where economic dependency of livestock producers on BLM forage would remain unchanged. 

About 310 operators would continue to have grazing leases. The amount of authorized use would remain unchanged; dependency on BLM forage would remain relatively unchanged; and BLM 

forage would continue to provide a critical element of some livestock producers’ complement of grazing, forage, and hay production. An annual average of 42,931 AUMs of authorized livestock 

grazing would support approximately 73 total full and part-time jobs and $954,000 in labor and proprietor’s income. Annual federal revenues from livestock grazing fees would be about $58,000 

annually, of which about $10,000 would be distributed to the counties. 

Minerals Development (common)

Most of the oil and gas activity and production would continue to occur in Carbon County. An estimated 264,000 short tons of bentonite, 100 tons of building stone, and 6,500 tons of mineral 

materials would be produced from federal minerals annually. Over a 13-year period, rent would be paid on an estimated 2,680 acres of federal coal that would be leased. Annual federal coal 

production would average 2.8 million tons. 

Minerals Development

An estimated 247,805 acres of federal 

minerals would be leased for oil/gas 

exploration, development, and production. 

Average annual production of 236,700 

MCF of natural gas, 459,200 bbl of oil, 2.8 

million tons of coal, 264,000 short tons of 

bentonite, 100 tons of building stone, and 

6,500 tons of mineral materials would 

support about 239 local jobs and $11.3

million in wage and proprietors’ income. 

Total annual federal revenues from leases, 

An estimated 178,560 acres of federal 

minerals would be leased for oil/gas 

exploration, development, and production. 

Average annual production of 170,500 MCF 

of natural gas, 330,900 bbl of oil, 2.8 million 

tons of coal, 264,000 short tons of bentonite, 

100 tons of building stone, and 6,500 tons of 

mineral materials would support about 215

local jobs and $10.1 million in wage and 

proprietors’ income. Total annual federal 

revenues from leases, rents, production 

An estimated 248,033 acres of federal 

minerals would be leased for oil/gas 

exploration, development, and production. 

Average annual production of 236,900 MCF 

of natural gas, 459,700 bbl of oil, 2.8 million 

tons of coal, 264,000 short tons of bentonite, 

100 tons of building stone, and 6,500 tons of 

mineral materials would support about 239

local jobs and $11.3 million in wage and 

proprietors’ income. Total annual federal 

revenues from leases, rents, production 

An estimated 246,910 acres of federal minerals 

would be leased for oil/gas exploration, 

development, and production. Average annual 

production of 235,800 MCF of natural gas,

457,600 bbl of oil, 2.8 million tons of coal, 

264,000 short tons of bentonite, 110 tons of 

building stone, and 6,500 tons of mineral 

materials would support about 239 local jobs 

and $11.3 million in wage and proprietors’ 

income. Total annual federal revenues from 

leases, rents, production royalties, and sales 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-259

Table 2.15 Summary Comparison of Impacts

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

rents, production royalties, and sales would 

be about $9.3 million; of which about $3.6 

million would be distributed to the counties 

of production. 

royalties, and sales would be about $7.6 

million; of which about $3.3 million would be 

distributed to the counties of production.

royalties, and sales would be about $9.4 

million; of which about $3.6 million would be 

distributed to the counties of production.

would be about $9.3 million; of which about 

$3.6 million would be distributed to the counties 

of production.

Recreation (common)

An annual average of 261,000 recreation visits would support about 136 full and part time jobs and $3.7 million in labor income. The willingness to pay for recreation opportunities would 

represent an estimated annual consumer surplus of $13.4 million to the recreation visitors. Annual revenues from recreation use permits, campground receipts, and outfitter/guide receipts would 

be about $47,000. None of these revenues would be distributed to the local counties.

Timber

Harvesting an estimated average 160 CCF 

of sawtimber, 131 CCF of pulp wood, 2 

CCF of post and poles, 960 CCF of 

biomass, 1 CCF of fuelwood, and 1,102 lbs 

of juniper would support less than one local 

job and about $23,000 in local income. 

Timber management would generate about 

$7,000 in federal revenues and less than 

$300 in state revenue.

Same as Alternative A. Harvesting an estimated average 570 CCF of 

sawtimber, 131 CCF of pulp wood, 2 CCF of 

post and poles, 960 CCF of biomass, 1 CCF 

of fuelwood, and 1,102 lbs of juniper would 

support one or two local jobs and about 

$55,000 in local income. Timber management 

would generate about $22,000 in federal 

revenues and less than $900 in state 

revenue.

Harvesting an estimated average 285 CCF of 

sawtimber, 131 CCF of pulp wood, 2 CCF of 

post and poles, 960 CCF of biomass, 1 CCF of 

fuelwood, and 1,102 lbs of juniper would 

support one local job and about $33,000 in 

local income. Timber management would 

generate about $11,000 in federal revenues 

and less than $500 in state revenue.

Realty, Cadastral Survey, and Lands (Common)

Existing use authorizations (e.g. rights-of-way, permits, and lease rentals) would continue to generate an estimated annual average $22,000 of revenue to the federal government. The 

development of renewable wind energy on public lands would stimulate economic activity from the construction and operation of the towers and related infrastructure. After construction, annual 

employment and income contributions associated with maintenance and operation of wind energy developments would be about 20 jobs and $600,000 respectively. Wind energy development 

would generate an additional $270,000 annually in federal revenues. None of the rights-of-way rents would be disbursed to state or local governments. 

Payments to Counties (Common)

Payments in Lieu of Taxes (PILT) from the federal government to 8 counties would continue to be approximately $620,000. A portion of coal lease bonuses, rent, and royalty payments to 

Musselshell county would average $2.3 million per year over a 13-year period. An estimated $308,700 from the MT Bentonite Production Tax would be distributed to Carbon County. An annual 

average of $30,000 would be distributed to counties from the BLM budget under partnership agreements to treat weeds. An estimated average of $224,000 would be provided to local 

governments and entities through community assistance agreements to reduce the risk of wildland fire to communities.

Payments to Counties

Including payments listed above, total 

revenues disbursed to the 8 Montana 

counties would average about $4.5 million 

per year. This would contribute about 72

jobs and $3.0 million of income annually to 

the local economy.

Including payments listed above, total 

revenues disbursed to the 8 Montana 

counties would average about $4.2 million per 

year. This would contribute about 68 jobs and 

$2.9 million of income annually to the local 

economy.

Including payments listed above, total 

revenues disbursed to the 8 Montana 

counties would average about $4.5 million per 

year. This would contribute about 73 jobs and 

$3.0 million of income annually to the local 

economy.

Including payments listed above, total revenues 

disbursed to the 8 Montana counties would 

average about $4.5 million per year. This would 

contribute about 72 jobs and $3.0 million

income annually to the local economy.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

2-260 Chapter 2: Resource Management Alternatives

Table 2.15 Summary Comparison of Impacts

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

Government (Common)

Average annual BLM labor and non-labor expenditures ($6.4 million) would support an estimated 103 full and part time jobs and about $6.9 million in wage and proprietor’s income. The influence 

of BLM labor and operations contributions would be most apparent in Billings (Yellowstone County) where the BLM Field Office is located. Employment and income effects of mechanical 

treatments, prescribed burning, invasive species treatments, and timber management (fuels treatments) would be included in government operations. Treating hazardous fuels would tend to 

reduce the threat to life and property nearby. 

Combined Effects

The combined effect of Alternative A would 

contribute an average annual 640 local full 

and part-time jobs and $26.55 million in 

wage and proprietors’ income. This would 

be less than 0.3% of current local 

employment and income. Annual revenues 

to the federal government would be about 

$9.7 million; payments to counties would be 

about $4.49 million, most of which would be 

related to mineral leasing, rents, and 

production royalties. Local employment 

would increase by about 106jobs; income 

would increase by about $4.92 million; 

federal revenues would increase by about 

$8.41 million; and local revenues would 

increase by about $2.71 million compared 

to current average annual levels. The local 

population would increase by an estimated 

159 people and the number of households 

would increase by an estimated 70. 

Population and households would increase 

by approximately 0.05% relative to current 

levels.

The combined effect of Alternative B would 

contribute an average annual 612 local full 

and part-time jobs and $24.15 million in wage 

and proprietors’ income. This would be less 

than 0.3% of current local employment and 

income. Annual revenues to the federal 

government would be about $8.0 million; 

payments to counties would be about $4.21 

million, most of which would be related to 

mineral leasing, rents, and production 

royalties. Local employment would increase 

by about 78 jobs; income would increase by 

about $2.52 million; federal revenues would 

increase by about $6.66 million; and local 

revenues would increase by about $2.43 

million compared to current average annual 

levels. The local population would increase by 

an estimated 117 people and the number of 

households would increase by an estimated 

51. Population and households would 

increase by approximately 0.05% relative to

current levels.

The combined effect of Alternative C would 

contribute an average annual 641 local full 

and part-time jobs and $26.59 million in wage 

and proprietors’ income. This would be less 

than 0.3% of current local employment and 

income. Annual revenues to the federal 

government would be about $9.8 million; 

payments to counties would be about $4.50 

million, most of which would be related to 

mineral leasing, rents, and production 

royalties. Local employment would increase 

by about 107 jobs; income would increase by 

about $4.96 million; federal revenues would 

increase by about $8.48 million; and local 

revenues would increase by about $2.72 

million compared to current average annual 

levels. The local population would increase by 

an estimated 161 people and the number of 

households would increase by an estimated 

71. Population and households would 

increase by approximately 0.05% relative to

current levels.

The combined effect of Alternative D would 

contribute an average annual 640 local full and 

part-time jobs and $26.54 million in wage and 

proprietors’ income. This would be less than 

0.3% of current local employment and income. 

Annual revenues to the federal government 

would be about $9.7 million; payments to 

counties would be about $4.49 million, most of 

which would be related to mineral leasing, 

rents, and production royalties. Local 

employment would increase by about 106 jobs; 

income would increase by about $4.91 million; 

federal revenues would increase by about 

$8.40 million; and local revenues would 

increase by about $2.70 million compared to 

current average annual levels. The local 

population would increase by an estimated 159

people and the number of households would 

increase by an estimated 70. Population and 

households would increase by approximately

0.05% relative to current levels.

Other Combined Effects (Common)

The employment, income, and revenue effects of BLM resource management would be spread unequally among the counties and communities within the Planning Area and the 10 counties that 

make up the local economy. Most of BLM land and minerals base and land/mineral uses are in Carbon and Musselshell counties. Much of the economic impacts would also occur in those 

counties. The influence of resource management on BLM-administered lands would not change local economic diversity (as indicated by the number of economic sectors), dependency (i.e. 

where one or a few industries dominate the economy), or stability (as indicated by seasonal unemployment, sporadic population changes, and fluctuating income rates). The population density 

and average income per household would continue to be about the same as current levels.

Soil and Water (Common)

Economic benefits or costs from soil and water management (e.g., change in life of dams and reservoirs, change in quantity and quality of water that would change the cost of water for 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 2: Resource Management Alternatives 2-261

Table 2.15 Summary Comparison of Impacts

Alternative A

(No Action Alternative) Alternative B Alternative C Alternative D(Proposed Alternative)

agricultural, industrial, municipal, recreational purposes, and change in soil productivity) associated with resource uses are unknown.

Cumulative Effects (Common)

The demographic and economic trends that are described in Chapter 3 to provide context for impacts would be expected to continue. The description of the Affected Environment found in 

Chapter 3 summarizes the past and present activities that influenced cumulative economic conditions. The economic impacts summarized above for each alternative would be combined with 

those demographic and economic trends to provide an idea of the cumulative economic effects. In addition, construction of wind energy developments with towers on BLM lands would be 

anticipated. 
CHAPTER 3:

AFFECTED 

ENVIRONMENT

CHAPTER 3:

AFFECTED 

ENVIRONMENT

Pryor Mountain Wild Horse Range
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-1 

3 Affected Environment

3.1 Introduction 

Chapter 3 provides information on the current condition of resources, resource uses, and 

programs in the Billings Field Office (BiFO) decision area that could be affected by the revised 

RMP alternatives described in Chapter 2. This chapter is organized into Resources, Resource 

Uses, Special Area Designations, and Social and Economic. Each of these sections is further 

divided into resources or program areas. This is the organization prescribed in the BLM 

guidance (USDI-BLM 2005). Existing conditions described herein are used as the baseline 

against which impacts of the different alternatives are analyzed and compared in Chapter 4. 

Management of resources and resource uses on public lands administered by the BLM is 

directed by a variety of laws, regulations, policies, and other requirements as summarized in 

Chapter 1. The BiFO operates under these requirements and guidance and also considers Best 

Management Practices (BMPs) in the management of resources and resource uses in the 

decision area. 

Throughout this document, the term “planning area” refers to all lands in the BiFO 

administrative boundary, regardless of ownership or jurisdiction. The term “decision area”

refers to lands in the planning area where the BLM has authority to make land use and 

management decisions; this includes split estate lands where the federal government has 

retained subsurface minerals. 

3.2 Physical, Biological, and Heritage Resources 

Section 3.2 provides information on the current condition of resources that could be affected by 

the revised RMP alternatives described in Chapter 2. Resources discussed in this RMP include: 

 Air 

 Climate change 

 Geology 

 Soil 

 Water 

 Vegetation 

► Forests and woodlands 

► Rangelands 

► Riparian and wetlands 

► Invasive species and noxious weeds 

► Special status plants 

 Wildlife habitat and special status species 

 Fisheries habitat and special status species 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

3-2 Chapter 3: Affected Environment

 Wild horses 

 Cultural/heritage resources 

 Paleontological resources 

 Visual resources 

 Fire ecology and management 

 Wilderness characteristics 

 Cave and karst resources 

3.2.1 Air

Regional air resources are influenced by the interaction of several factors, including weather, 

climate, the magnitude and spatial distribution of local and regional air pollutant sources, and 

the chemical properties of emitted air pollutants. Air resources include air quality and air 

quality related values (AQRVs), which include visibility and acid deposition to soils and lakes. 

3.2.1.1 Regional Winds

Wind is a critical component of ambient air quality because it disperses pollutants and 

transports them away from the point of origin. The prevailing wind direction for Billings, 

Montana is out of the southwest, with the exception of May to July, when wind typically comes 

from the north (see Table 3-1). Average wind speeds range from 9 to 13 miles per hour (mph), 

which is generally considered a “gentle breeze” where “leaves and small twigs can be in 

constant motion and where the wind can extend a light flag” (Lutgens and Tarbuck 1989). 

Winter conditions may produce moderate winds with individual days generating strong winds. 

Table 3-1 Prevailing Wind Directions and Average Speeds (mph) for Billings 

Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Annual

SW SW SW SW N N N SW SW SW SW SW SW

13 12 11 11 10 10 09 09 10 10 12 13 11

Note: 

Source: http://www.wrcc.dri.edu/htmlfiles/westwinddir.html (data from 1992-2002), accessed August 23, 2011. 

 http://www.wrcc.dri.edu/htmlfiles/westwind.final.html (data from 1996-2006), accessed August 23, 2011. 

Wind varies considerably from one location to another. A wind rose for the Pryor Mountain 

Remote Automated Weather Station (RAWS) in the southern portion of the BiFO indicates 

more westerly winds at this location. The 16 arms in Figure 3-1indicate the frequency of wind 

blowing from the indicated direction. Longer arms indicate that the wind more frequently 

originates from the illustrated direction. Colored bands within each arm indicate the proportion 

of time that the wind blows with a given speed. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-3 

Figure 3-1 Wind Rose for Pryor Mountain, Montana (data from 2006-2010) 

Note: 

Source: http://www.raws.dri.edu 

3.2.1.2 Criteria Air Pollutants

Criteria air pollutants are substances for which the US Environmental Protection Agency 

(USEPA) established national health-based concentration standards under the National 

Ambient Air Quality Standards (NAAQS) program. Criteria air pollutants include carbon 

monoxide (CO), lead (Pb), nitrogen dioxide (NO2), ozone (O3), particulate matter with a 

diameter greater than or equal to 10 micrometers (PM10), particulate matter with a diameter 

greater than or equal to 2.5 micrometers (PM2.5), and sulfur dioxide (SO2). Criteria air pollutant 

concentrations are compared to NAAQS (USEPA 2010c) and Montana Ambient Air Quality 

Standards (MAAQS). The NAAQS include both primary and secondary standards, as shown in 

Table 3-2. Primary standards protect public health, including the health of sensitive populations 

such as asthmatics, children, and the elderly. Secondary standards protect public welfare by 

preventing damage to buildings, infrastructure, and vegetation. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

3-4 Chapter 3: Affected Environment

Table 3-2 Federal and State Ambient Air Quality Standards 

Pollutant

Federal NAAQS1 State MAAQS2

Averaging Time Level Standard Type Level

Carbon Monoxide (CO)

8-hour 9 ppm3 Primary 9 ppm12

1-hour 35 ppm3 Primary 23 ppm12

Fluoride in Forage

Monthly N/A N/A 50 μg/g

Grazing Season N/A N/A 35 μg/g

Lead (Pb)

3-month (rolling) 0.15 μg/m3 5 Primary, Secondary N/A

90-day N/A N/A 1.5 μg/g5

Nitrogen Dioxide (NO2)

Annual 0.053 ppm5 Primary, Secondary 0.05 ppm13

1-hour 0.100 ppm10 Primary 0.30 ppm12

Fine Particulate Matter 

(PM2.5)

Annual 12.0 μg/m3 11 Primary N/A

Annual 15.0 μg/m3 11 Secondary N/A

24 hour 35 μg/m3 7 Primary, Secondary N/A

Particulate Matter 

(PM10)

Annual N/A N/A 50 μg/m3 4

24-hour 150 μg/m3 8 Primary, Secondary 150 μg/m3

Settleable Particulate 30-day N/A N/A 10 g/m2

Ozone (O3) 8-hour 0.075 ppm6 Primary, Secondary 0.10 ppm12

Sulfur Dioxide (SO2)

Annual 0.030 ppm5 Primary 0.02 ppm13

24-hour 0.14 ppm3 Primary 0.10 ppm12

3-hour 0.5 ppm3 Secondary N/A

1-hour 0.075 ppm9 Primary 0.50 ppm14

Visibility Annual N/A N/A 3 x 10-5/m15

Note: 

1 NAAQS are codified in Title 40 of the Code of Federal Regulations (CFR), Part 50. 

2 MAAQS are codified in Title 17, Chapter 8, Subchapter 2 of the Ambient Air Quality regulations in the Administrative Rules 

of Montana (ARM). 

3 Not to be exceeded more than once per calendar year.

4 Not to be exceeded more than once per year on average over 3 years. 

5 Not to be exceeded. 

6 Not to be exceeded based on the 3-year average of the fourth-highest daily maximum 8-hour concentrations per calendar 

year. On January 19, 2010, USEPA proposed to revise the 8-hour standard to a level between 0.060 to 0.070 ppm (EPA 

2010q). 

7 Not to be exceeded based on the 98th percentile of 24-hour concentrations at each population-oriented monitor. 

8 Not to be exceeded more than once per calendar year, based on a 3-year average of maximum 24-hour values. 

9 Not to be exceeded based on a 3-year average of the 99th percentile of the daily maximum concentrations. 

10 Not to be exceeded based on a 3-year average of the 98th percentile of the daily maximum concentrations. 

11 Not to be exceeded based on a 3-year average of the weighted annual mean from one or more community monitors. 

12 Not to be exceeded more than once over any 12 consecutive months. 

13 Arithmetic average not to be exceeded more than once over any 4 consecutive quarters. 

14 Not to be exceeded more than 18 times in any 12 consecutive months. 

15 This standard applies only in certain Class I areas (Table 3-7). 

Areas that do not meet federal standards are designated as nonattainment areas (Map 4). Within 

the BiFO, the only nonattainment area is an SO2 nonattainment area located in a small area in 

Laurel, Montana in Yellowstone County (USEPA 2010a, 2010b). The Sundance Lodge 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-5 

Recreation area lies within the Laurel nonattainment area. Although not designated as an SO2

nonattainment area, the Billings area has been identified as an area of concern for SO2 by the 

Montana Department of Environmental Quality (MDEQ). 

To the east of the BiFO, the community of Lame Deer within Rosebud County is the only 

nonattainment area near the planning area. Lame Deer is designated nonattainment due to high 

PM10 concentrations. 

3.2.1.3 Air Quality Monitoring

The MDEQ performs regulatory monitoring of NO2, ozone, SO2, PM10, and PM2.5 in order to 

determine compliance with NAAQS and MAAQS. Air pollutant concentration monitoring 

networks in Montana include the State and Local Air Monitoring Stations (SLAMS), a National 

Core (NCore) monitoring site, Tribal monitoring networks, and the Clean Air Status and 

Trends Network (CASTNet). SLAMS are usually located in urban areas and measure criteria 

pollutants. The MDEQ operates the SLAMS network to determine compliance with regulatory 

concentration standards. CASTNet stations are located in remote areas and measure 

concentrations of compounds that are of interest to ecosystem health. Air pollutant 

concentrations are usually reported on a volume basis as parts per million (ppm) or parts per 

billion (ppb) for gaseous substances and on a mass basis as micrograms per cubic meter 

(μg/m3) for solid substances such as PM10 and PM2.5. 

Monitors that provide information on AQRVs include the National Acid Deposition Program 

(NADP) network and the Interagency Monitoring of Protected Visual Environments 

(IMPROVE) network. A list of monitoring stations in or near the planning area is provided in 

Table 3-3. 

Table 3-3 Air Quality Monitoring Stations in the BiFO or Vicinity

Monitoring 

System

Station 

Identifier

Pollutant or 

AQRV Location Latitude Longitude

SLAMS

30-111-0066 SO2 Billings – Coburn Road 45.7883 -108.4595

30-111-0085 PM2.5 Billings – St. Luke’s 45.7822 -108.5115

30-087-0001 NO, NO2, NOx, O3, 

PM10, PM2.5

Birney – Tongue River 45.3662 -106.4894

30-031-0019 PM2.5 Bozeman – High School 45.7262 -111.0681

CASTNET YEL408 O3, SO2, 

Deposition

Yellowstone National Park 

(Wyoming) 44.5597 -110.4006

NADP

MT00 Wet Deposition Little Bighorn Battlefield National 

Monument 45.5686 -107.4375

WY08 Wet Deposition Yellowstone National Park –

Tower Falls (Wyoming) 44.9166 -110.4203

IMPROVE

NOCH1 Visibility Northern Cheyenne Indian 

Reservation 45.6493 -106.557

ULBE1 Visibility UL Bend 47.5823 -108.72

NOAB1 Visibility North Absaroka (Wyoming) 44.7448 -109.3816
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3-6 Chapter 3: Affected Environment

Table 3-3 Air Quality Monitoring Stations in the BiFO or Vicinity

Monitoring 

System

Station 

Identifier

Pollutant or 

AQRV Location Latitude Longitude

YELL2 Visibility Yellowstone NP (Wyoming) 44.5653 -110.4002

CLPE1 Visibility Cloud Peak (Wyoming) 44.3335 -106.9565

Sources: MDEQ 2013, USEPA 2012.

The sources and effects of each criteria pollutant are explained below. Recent ambient air 

quality monitoring data are shown as the percentage of the monitored concentration compared 

to the NAAQS in Figure 3-2– Ambient Air Quality Concentrations in the BiFO Planning Area. 

Values shown in Figure 3-2 are based on the format of the NAAQS. For example, when a 

NAAQS allows one exceedance of a standard per year, the second highest monitored value is 

reported for comparison to the NAAQS. Due to the geographic distribution of Montana 

monitors, some of the monitoring sites considered to be representative of the planning area are 

located outside the planning area. 

3.2.1.4 Carbon Monoxide 

CO can have significant effects on human health because it combines readily with hemoglobin 

and consequently reduces the amount of oxygen transported in the bloodstream. Effects on 

humans from exposure to high CO concentrations can include slight headaches, nausea, or 

death. 

Motor vehicles and other internal combustion engines are the dominant source of CO emissions 

in most areas. High CO levels develop primarily during winter when periods of light winds 

combine with ground-level temperature inversions (typically from the evening through early 

morning). These conditions result in reduced dispersion of vehicle emissions. CO is also 

created during refuse, agricultural, and wood-stove burning and through some industrial 

processes. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-7 

Figure 3-2: Ambient Air Quality Concentrations in the BiFO Planning Area (2010-2012) 

Source: MDEQ 2013 

Notes: 

NO2 1 hour: 3 year average of 8th highest daily maximum (2010-2012) 

O3 3-year average of 4th highest daily maximum 8-hour average (2010-2012) 

PM2.5 24-hour: 3-year average of 98th percentile (2010-2012) 

 Annual: 3-year average weighted mean (2010-2012) 

PM10 3 year average of second maximum (2010-2012,) 

SO2 3-year average of the 99th percentile (2010-2012) 

8%

75%

34%

41%

13%

104%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

110%

NO2 1-hr O3 8-hr PM2.5 24-hr PM2.5 annual PM10 24-hr SO2 1-hr

Criteria Pollutant Concentration 

(% NAAQS)

NO2, O3, PM2.5, PM10 Birney (Station 30-087-001)

SO2 Billings (Station 30-111-0066)
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3-8 Chapter 3: Affected Environment

3.2.1.5 Lead

The primary historical sources of lead emissions have been certain types of industrial sources 

and lead in gasoline and diesel fuel. However, since lead in fuels has decreased substantially, 

processing of metals containing trace amounts of lead is now the primary source of lead 

emissions. The highest levels of lead in air are generally found near lead smelters. Other 

stationary sources include waste incinerators, utilities, and lead-acid battery manufacturing 

plants. The effects of lead exposure include brain and other nervous system damage; children 

exposed to lead are particularly at risk. Due to the lack of large lead emission sources, lead 

levels in the planning area are expected to be well below the NAAQS and MAAQS. No data 

are available to determine the trend in lead concentrations. However, decreasing lead levels in 

gasoline and diesel fuel indicate a likely decrease in lead levels within the planning area. 

3.2.1.6 Nitrogen Dioxide 

Nitrogen oxides (NOx), including nitric oxide (NO) and NO2, are formed when naturally 

occurring atmospheric nitrogen and oxygen are combusted with fuel in automobiles, power 

plants, industrial processes, and home and office heating. At high exposures, NO2 causes 

respiratory system damage of various types, including bronchial damage. Its effects are 

exhibited by increased susceptibility to respiratory infection and changes in lung function. 

Within the atmosphere, NO2 contributes to visibility impacts and may be visible as reddishbrown haze. NO2 and other forms of NOx form nitric acid (HNO3), a component of atmospheric 

deposition (e.g., acid rain.). 

Hourly NO2 concentrations at the Birney monitor in nearby Rosebud County were 8 percent of 

the NAAQS during 2010-2012. 

3.2.1.7 Ozone 

Ozone is not emitted directly into the atmosphere. Instead, it is formed by a photochemical 

reaction of precursor air pollutants, including volatile organic compounds (VOCs) and NOx. 

These precursors are emitted by mobile sources, stationary combustion equipment, and other 

industrial sources. Ozone is produced year-round, but due to greater sunlight and air 

temperatures, urban ozone concentrations are generally greatest during the summer. Elevated 

ozone concentrations may also occur during winter in snow-covered rural areas. 

Ozone is a severe eye, nose, and throat irritant. A potent oxidant, it increases susceptibility to 

respiratory infections and may cause substantial damage to vegetation (leaf discoloration and 

cell damage) and other materials (attacking synthetic rubber, textiles, paints, and other 

substances). 

The 3-year average of the fourth highest 8-hour ozone concentration was 0.056 ppm at the 

Birney monitor, as estimated using data from 2010-2012. This measured concentration is 75

percent of the 8-hour 2008 primary and secondary NAAQS of 0.075 ppm. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-9 

3.2.1.8 Particulate Matter

Particulate matter includes PM10 and PM2.5. PM10 impacts include health effects (because PM10

is small enough to reach the lungs when inhaled), deposition on plants and surfaces (including 

soiling of snow which can contribute to climate change), localized reductions in visibility, and 

potential corrosion. PM10 emissions are generated by a variety of sources including agricultural 

activities, industrial emissions, and road dust re-suspended by vehicle traffic. Within the 

planning area, primary sources of PM10 include smoke from wildland fire, residential wood 

burning, street sand, physically disturbed soils, and dust from unpaved roads. 

PM2.5 poses greater health concerns than PM10 because it can pass through the nose and throat 

and be trapped deep in the lungs. Fine particulate also contributes to reduced visibility in 

nationally important areas such as national parks and wilderness areas. PM2.5 emissions are 

primarily generated by internal combustion diesel engines, soils with high silt and clay content, 

and secondary aerosols formed by chemical reactions in the atmosphere.

The second highest 24-hour PM10 concentration near the planning area was 19.6 μg/m3or 13

percent of the corresponding primary and secondary NAAQS at the Birney monitor (Rosebud 

County), as estimated using data from 2010-2012. The 3-year average 98th percentile 24-hour 

PM2.5 concentration at the same location and year was 12 μg/m3, which was 34 percent of the 

corresponding primary and secondary NAAQS. The 3-year average weighted mean PM2.5

annual concentrations at the same location was 4.9 μg/m3

, or 41 percent of the corresponding 

primary and secondary NAAQS. 

3.2.1.9 Sulfur Dioxide

SO2 is a colorless gas with a pungent odor. Prolonged exposure to high levels of SO2 can lead 

to respiratory failure, and SO2 plays an important role in the aggravation of chronic respiratory 

illnesses such as asthma. SO2 is emitted primarily from stationary sources that burn fossil fuels 

(i.e., coal and oil) containing trace amounts of elemental sulfur. Other human-caused sources of 

SO2 include metal smelters and petroleum refineries. In the atmosphere, SO2 converts to 

sulfuric acid, a component of atmospheric deposition (acid rain), and forms secondary aerosols, 

subsequently contributing to visibility impacts in nationally important areas. 

The 3-year average 99th percentile 1-hour SO2 concentration was 78 ppb in Billings 

(Yellowstone County) in 2010-2012. This concentration was 104 percent of the corresponding 

primary NAAQS, as calculated using data from USEPA’s Air Quality Statistics Report website 

(http://www.epa.gov/airquality/airdata/ad_rep_con.html).

The 1-hour SO2 NAAQS is a relatively new standard and EPA has not yet determined 

attainment/nonattainment area designations for this standard. On May 27, 2011, the MDEQ 

submitted a letter to the USEPA requesting that all counties in Montana should be designated 

attainment or unclassifiable based on data from 2008 through 2010 (MDEQ 2011). The 

MDEQ letter reported that high monitored 1-hour SO2 concentrations measured during 2010 

were due to events that are not likely to be repeated in future years. 
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3-10 Chapter 3: Affected Environment

3.2.1.10 Air Quality Index

The USEPA air quality index (AQI) shows that the BiFO has good air quality that poses little 

health risk to the general public (Table 3-4). The AQI is an index used for reporting daily air 

quality indicating how clean or polluted an area’s air is and whether associated health effects 

may be a concern. The AQI focuses on potential health effects a person may experience in a 

few hours or days after breathing ambient air. 

The USEPA calculates the AQI for five criteria air pollutants: ground-level ozone, particulate 

matter, CO, CO2, and NO2. For each of these pollutants, USEPA established NAAQS to protect 

public health. An AQI value of 100 generally corresponds to the national air quality standard 

for the pollutant, which is the level the USEPA has set to protect public health. The following 

terms define AQI information: 

 Good – The AQI value is between 0 and 50. Air quality is considered 

satisfactory and air pollution poses little or no risk. 

 Moderate – The AQI is between 51 and 100. Air quality is acceptable; 

however, for some pollutants there may be a moderate health concern for a small 

number of people. For example, people who are unusually sensitive to ozone 

may experience respiratory symptoms. 

 Unhealthy for Sensitive Groups – When AQI values are between 101 and 150, 

members of “sensitive groups” may experience health effects. These groups are 

likely to be affected at lower levels than the general public. For example, people 

with lung disease are at greater risk from exposure to ozone, while people with 

either lung disease or heart disease are at greater risk from exposure to 

particulate pollution. The general public is not likely to be affected when the 

AQI is in this range. 

 Unhealthy – Everyone may begin to experience health effects when AQI values 

are between 151 and 200, and members of sensitive groups may experience 

more serious health effects. 

The AQI data summarized below show that air quality in Yellowstone County poses little risk 

to the general public. Over a recent 3-year period from 2010-2012, 84 percent of the days with 

data were rated “good” with 14 percent being “moderate.” While health risk occurrences have 

been documented in Yellowstone County, occurrences of unhealthy days for sensitive 

populations are rare (approximately 2 percent); no days were unhealthy or very unhealthy. 

Pollutants responsible for the highest AQIs were PM2.5 and SO2

Table 3-4 Air Quality Index Report 

AirData Air Quality Index Report – Field Office Summary 

County Data Years

Number of Days

Percentage 

of Days 

Rated Good

Average. 

90th

Percentile 

AQI

With 

Data

Rated 

Good

Rated 

Moderate

Rated Unhealthy 

for Sensitive 

Groups

Rated 

Unhealthy

Yellowstone 2010-2012 1,096 1,924 157 15 0 84% 59
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Chapter 3: Affected Environment 3-11

Note: 

Source: USEPA 

3.2.1.11 VOCs

VOCs include a variety of chemicals, some of which have adverse health effects. 

Concentrations of many VOCs are consistently higher indoors than outdoors. VOCs are emitted 

from equipment such as organic liquid storage tanks, leaking equipment, and from engines and 

other combustion equipment. In addition, thousands of products emit VOCs, including paints, 

cleaning supplies, pesticides, building materials, office equipment, glues, and permanent 

markers (USEPA 2010d). VOCs are not subject to a NAAQS. However, since they react with 

NOx to form ground-level ozone, VOCs are a precursor to ozone and VOC emissions are 

regulated by USEPA. 

3.2.1.12 Hazardous Air Pollutants 

Hazardous air pollutants (HAPs) are pollutants that are known or suspected to cause cancer or 

other serious health problems, which include chronic respiratory disease, reproductive 

disorders, or birth defects. Of the 187 regulated HAPs, several are commonly emitted from 

planning area engines and other sources. Engine-emitted HAPs include formaldehyde, benzene, 

toluene, ethyl benzene, xylenes, and hexane (i.e., n-hexane). Potential concentrations of HAPs 

are compared to health-based thresholds to estimate the risk of health effects. 

3.2.1.13 Other Pollutants

Other air pollutants of interest include nitrogen and sulfur compounds because they contribute 

to acid deposition and regional haze. Nitrogen compounds include particulate nitrate (NO3

–

), 

nitric acid, and ammonium (NH4

+

), while sulfur compounds include particulate sulfate (SO4

–2

) 

and SO2. Concentrations of HNO3, SO2, NH4

+

, NO3

–

, and SO4

–2

are low in Montana relative to 

concentrations across the United States (NADP 2010c, 2010d, 2010e). 

3.2.1.14 Criteria Pollutant Emissions

Current air quality reflects the impacts of emissions from existing sources of air pollution.

Table 3-5 provides an estimate of recent emissions within the BiFO based on a USEPA 

estimate of recent emissions based on the 2011 National Emissions Inventory (NEI). Emissions 

of HAPs and greenhouse gases (GHGs) are not included in Table 3-5. Due to recent 

implementation of a new federal air quality rule, many facilities within the planning area will 

began reporting GHG emissions to USEPA in 2011.

Table 3-5 BiFO Criteria Pollutant Emissions by County 

County

Emissions (tons/year)

CO NOX PM10 PM2.5 VOC SO2

Big Horn 12,539 4,506 16,440 2,920 3,695 474

Carbon 8,072 890 5,903 1,135 2,077 49

Golden Valley 2,659 198 1,241 330 673 13
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Musselshell 3,276 338 2,963 532 931 16

Stillwater 4,801 1,262 6,888 1,032 850 24

Sweet Grass 7,871 1,073 3,138 795 1,669 39

Wheatland 1,306 285 1,623 278 269 5

Yellowstone 29,768 8,761 18,082 3,347 7,876 7,473

Total 70,292 17,313 56,278 10,369 18,040 8,093

Biogenic emissions 25,425 6,272 --- --- 150,644 ---

Wildfire emissions 55,143 546 5,426 4,598 12,952 351

Total 2 150,860 24,131 61,704 14,967 181,636 8,444

Note: 

Source: USEPA 2013d.

1 Reported values exclude emissions from biogenic sources and wildfires. 

2 Total emissions. 

3.2.1.15 Emission Sources

Emission sources include rural and urban sources and the largest sources vary by pollutant. The 

largest three source categories for each criteria air pollutant are provided in Table 3-6. When 

emissions from all counties within the BiFO are aggregated, mobile on-road vehicles are the 

largest sources of CO, NOx, and VOCs based on data from USEPA’s 2008 National Emission 

Inventory. PM10 and PM2.5 emissions are emitted primarily by fugitive dust sources. PM2.5 is 

also emitted by electricity generation and wood combustion. SO2 is emitted primarily by 

industrial sources. Lead is not included in Table 3-6 because it is emitted in small quantities. 

Table 3-6 Largest 2008 Emission Sources by Pollutant 

Pollutant / Sector Emissions (tons/year) Emission Percentage (%)

CO

Mobile on-road vehicles 28,378 40%

Prescribed Fires 21,865 31%

Mobile non-road vehicles 9,963 14%

Other sources 10,085 14%

Total 70,291 100%

NOx

Mobile on-road vehicles 5,559 32%

Locomotives 3,862 22%

Electricity 2,009 12%

Other sources 5,883 34%

Total 17,313 100%

PM10

Unpaved road fugitive dust 26,760 48%

Mining 12,050 21%

Agriculture: Crops and 

Livestock 8,786 16%
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Chapter 3: Affected Environment 3-13

Pollutant / Sector Emissions (tons/year) Emission Percentage (%)

Other sources 8,862 15%

Total 56,278 100%

PM2.5

Unpaved road fugitive dust 2,668 26%

Mining 1,531 15%

Prescribed Fires 1,821 18%

Other sources 4,350 42%

Total 10,370 100%

SO2

Electricity 4,643 57%

Chemical 1,988 25%

Petroleum 962 12%

Other sources 500 6%

Total 8,093 100%

VOC

Prescribed fires 5,135 28%

Oil and Gas 2,563 14%

Petroleum 1,857 10%

Other sources 8,484 47%

Total 18,039 100%

Note: 

Source: Derived from USEPA 2013d. 

3.2.1.16 Air Quality Related Values

AQRVs include visibility or a specific scenic, cultural, physical, biological, ecological, or 

recreational resource identified for a particular area. Air pollution can impact AQRVs through 

ambient exposure to elevated atmospheric concentrations, such as ozone effects to vegetation, 

through impairment of scenic views by pollution particles in the atmosphere, and through 

deposition of air pollutants, such as sulfur and nitrogen compounds, on the earth’s surface 

through precipitation or dry deposition. AQRVs on federal lands are identified and managed 

within the respective jurisdictions of several land management agencies, including the US 

Forest Service (USFS), National Park Service (NPS), and US Fish and Wildlife Service 

(USFWS), and the BLM. Class I areas are afforded specific AQRV protection under the Clean 

Air Act. Class II areas may be analyzed to assess AQRV impacts if they are identified as 

sensitive Class II areas. 

No Class I areas are located within the BiFO. However, the Northern Cheyenne Indian 

Reservation is adjacent to the eastern boundary of the BiFO, and other Class I areas are located 

nearby as shown in Table 3-7. Sensitive Class II areas include the Crow Indian Reservation,

the Bighorn Canyon National Recreation Area, Little Bighorn Battlefield National Monument, 

and several National Wildlife Refuges (NWR). 
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3-14 Chapter 3: Affected Environment

Table 3-7 Class I and Sensitive Class II Areas in or near the BiFO 

Area name Acres Jurisdictional Agency

Class I Areas

North Absaroka Wilderness 351,104 USFS

Northern Cheyenne Indian Reservation 444,000 Tribal

U. L. Bend Wilderness Area 20,890 USFWS

Wind Cave National Park 28,060 NPS

Yellowstone National Park 2,020,625 NPS

Sensitive Class II Areas

Bighorn Canyon National Recreation Area 120,296 NPS

Crow Indian Reservation 2,282,000 Tribal

Halfbreed Lake NWR 4,318 FWS

Hailstone NWR 920 FWS

Lake Mason NWR 1,250 FWS

Little Bighorn Battlefield National Monument 765 NPS

Note: 

Source: USEPA 2010c. 

NWR = National Wildlife Refuge 

3.2.1.17 Deposition 

Atmospheric deposition refers to the processes by which air pollutants are removed from the 

atmosphere and deposited on terrestrial and aquatic ecosystems. Deposition is reported as the 

mass of material deposited on an area in a given period (e.g., kilogram per hectare per year 

[kg/ha-yr]). Wet deposition refers to air pollutants deposited by precipitation, such as rain and 

snow. One expression of wet deposition is precipitation pH, a measure of the acidity or 

alkalinity of the precipitation. Dry deposition refers to gravitational settling of particles and 

adherence of gaseous pollutants to soil, water, and vegetation. Total deposition refers to the 

sum of airborne material transferred to the Earth’s surface by both wet and dry deposition. 

Total nitrogen deposition is calculated by summing the nitrogen portion of wet and dry 

deposition of nitrogen compounds, and total sulfur deposition is calculated by summing the 

sulfur portion of wet and dry deposition of sulfur compounds. 

The normal range of precipitation pH is 5.0–5.6 (Seinfeld 1986). At Little Bighorn Battlefield 

National Monument, 2010 annual average precipitation pH was approximately 5.4 (NADP 

2011). The planning area has low nitrate, sulfate, and ammonium deposition compared to the 

rest of the United States. 

Atmospheric deposition can cause acidification of lakes and streams. One expression of lake 

acidification is the change in acid neutralizing capacity, the lake’s capacity to resist 

acidification from atmospheric deposition. Acid neutralizing capacity is expressed in units of 

micro-equivalents per liter (μeq/L). Lakes with acid neutralizing capacity values of between 25 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-15

to 100 μeq/L are considered to be sensitive to atmospheric deposition, lakes with acid 

neutralizing capacity values of between 10 to 25 μeq/L are considered to be very sensitive, and 

lakes with acid neutralizing capacity values of less than 10 are considered to be extremely 

sensitive (Fox et al. 1989). 

3.2.1.18 Visibility

Visibility is a measure of how far and how well an observer can see a distant and varied scene. 

Pollutant particles in the atmosphere can impair scenic views, degrading the contrast, colors, 

and distance an observer is able to see. Light extinction is used as a measure of visibility and is 

calculated from the monitored components of fine particle mass (aerosols) and relative 

humidity. Light extinction is expressed in terms of deciviews, a measure for describing 

perceived changes in visibility. One deciview is defined as a change in visibility that is just 

perceptible to an average person, which is approximately a 10-percent change in light 

extinction. To estimate potential visibility impairment, monitored aerosol concentrations are 

used to estimate visibility conditions for each monitored day. Aerosol species affecting visual 

range include ammonium sulfate, ammonium nitrate, organic mass, elemental carbon, soil 

elements, and coarse mass. 

Daily visibility values are ranked from clearest to haziest and divided into three categories to 

indicate the mean visibility for all days (average), the 20 percent of days with the clearest 

visibility (20 percent clearest), and the 20 percent of days with the worst visibility (20 percent 

haziest). Visibility can also be defined by standard visual range (SVR), which is the farthest 

distance at which an observer can see a black object viewed against the sky above the horizon; 

the larger the SVR, the cleaner the air. Since 1980, the Interagency Monitoring of Protected 

Visual Environments (IMPROVE) network has measured visibility in national parks and 

wilderness areas. 

The average standard visible range at the Northern Cheyenne Indian reservation IMPROVE 

monitor was 58 miles during the average haziest 20 percent of days and 171 miles during the 

clearest 20 percent of days. Similar standard visual range data are 76 and 182 miles at 

Yellowstone National Park, and 57 and 168 miles at the UL Bend National Wildlife Refuge. 

Visibility has remained relatively constant over recent years in the planning area and nearby 

areas. Standard visual range trends at Class I areas near the BiFO are shown in Figure 3-3 and

Figure 3-4 Visibility Trends During the 20 Percent Worst and 20 Percent Best Days. From 

2005 through 2009, visibility on the 20 percent worst visibility days improved slightly near the 

planning area. When the 20 percent best visibility days are considered, visibility improved 

throughout central Montana and northwestern Wyoming. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

3-16 Chapter 3: Affected Environment

Figure 3-3 Visibility Trends on the Best and Worst Visibility Days (2005-2009) 

Figure 3-4 Visibility Trends on the Best and Worst Visibility Days (2005-2009) 

Note: 

Source: IMPROVE 2011 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-17

3.2.1.19 Smoke Management 

Smoke contains large quantities of CO and particulate matter. The MDEQ regulates prescribed 

fire activity under the authority of the Montana Open Burning Regulations (ARM Title 17, 

Section 8, Subchapter 6). The MDEQ issues open burn permits and, along with several 

counties, operates a Major and Minor Open Burning Smoke Management Program under the 

authority of MDEQ’s Open Burning Regulations. In cooperation with the MDEQ, smoke 

management for prescribed fire activity is managed by the Montana/Idaho Airshed Group. 

Prescribed burns would be completed in a manner that is consistent with procedures established 

by the Montana/Idaho Airshed Group and the associated permit conditions of the Major Open 

Burning Permit and the rules addressing Minor Open Burning pursuant to the MDEQ Open 

Burning Regulations. 

3.2.2 Climate 

The topography of the state plays an important role in Montana’s climate and creates a variable 

climate in the BiFO planning area. The Continental Divide exerts a marked influence on the 

climate of adjacent areas. West of the Divide the climate might be termed a modified northern 

Pacific coast type, while to the east, climatic characteristics are decidedly continental. The 

continental climate of eastern Montana is characterized by light precipitation totals, abundant 

sunshine, low relative humidity, and a relatively large annual and diurnal temperature range. A 

climate summary for Billings, Montana is presented in Table 3-8. 

Table 3-8 Monthly Climate Summary for Billings, Montana 

Period of Record: 7/1/1948 to 8/31/2009

Jan Feb Mar Apr May Jun July Aug Sept Oct Nov Dec Annual

Average Max. 

Temperature (F) 32.8 39.1 46.0 56.8 67.1 76.8 86.7 85.1 72.6 60.3 45.1 35.9 58.7

Average Min. 

Temperature (F) 14.3 19.6 25.0 34.0 43.4 51.7 58.4 56.8 47.0 37.3 26.1 18.1 36.0

Average Total 

Precipitation (in.) 0.73 0.59 1.06 1.77 2.27 2.04 1.10 0.84 1.31 1.18 0.71 0.65 14.26

Average Total 

Snowfall (in.) 10.2 7.4 10.4 8.7 1.7 0.0 0.0 0.0 1.1 4.2 6.6 8.7 58.9

Average Snow 

Depth (in.) 2 2 1 0 0 0 0 0 0 0 1 2 1 

Note: 

Source: Western Regional Climate Center 2009. 

3.2.2.1 Temperature 

Winters in the planning area, while usually cold, have few extended cold spells. Between cold 

waves there are periods, sometimes longer than 10 days, of mild but often windy weather. 

These warm, windy winter periods occur almost entirely along the eastern slopes of the Divide 

and are known as chinooks. The so-called chinook belt extends from the Browning-Shelby area 

southeastward to the Yellowstone Valley above Billings. Through this belt, chinook winds 

frequently reach speeds of 25 to 50 mph or more and can persist, with few interruptions, for 
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3-18 Chapter 3: Affected Environment

several days. In January, the coldest month, temperature averages range from 11 Fahrenheit 

(F) for the Northeastern Division to 22F for the South Central (upper Yellowstone Valley) 

Division. In some areas east of the Continental Divide, January or February can average zero or 

below, however such occurrences range from infrequent to approximately once in 10 to 15 

years in the coldest spots. 

January is also the coldest month for Billings, with average day time high temperatures in the 

low 30s, and average night time low temperatures in the teens. Overnight lows below zero are 

fairly common during winter, and record low temperatures for all six of the cooler season 

months from October through March are below 0F. However, nearly as common as these 

coldest temperatures, the region also experiences warm down slope winds fairly frequently 

during the winter. This is clear in the high temperatures recorded in Billings, where the daily 

maximum record is nearly at or above 70F for each of these six colder months. The coldest 

temperature on record at Billings was -32F on Christmas Eve, 1983, while the warmest high 

temperature in January is 68F recorded on January 11, 1953. 

Most Montana lakes freeze over every winter. All rivers carry floating ice during the late winter 

or early spring. Few streams freeze solid; water generally continues to flow beneath the ice. 

During the coldest winters, anchor ice, which builds from the bottom of shallow streams, may 

on rare occasions create flooding. 

During the summer, hot weather occurs fairly often in the planning area. In Billings, July and 

August are the warmest months with average daytime highs in the upper mid 80s. This 

midsummer warmth is fairly steady, seldom severe, and is tempered by normal night time 

temperatures in the 50s and 60s. Generally, adequate moisture permits rapid plant and crop 

development during most growing seasons. The hottest temperature recorded at the Billings 

station was 108F occurring on July 14, 2002. Figure-3-5 - Montana Average Daily Maximum 

Temperature shows state wide average daily maximum temperature. 
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Chapter 3: Affected Environment 3-19

Figure-3-5 Montana Average Daily Maximum Temperature 

Note: 

Source: NRIS 2011a. 

3.2.2.2 Precipitation

Precipitation varies widely and seasonally, and over the mountainous areas depends largely on 

topographic influences. Areas on the windward side of mountain ranges are generally the 

wettest. On the eastern plains, as seen in the Billings records, there are two peaks in the average 

monthly rainfall, the primary one in May and a second less pronounced peak in September. 

Most annual precipitation comes as rain, and daily total precipitation seldom exceeds one inch. 

During the spring, precipitation events are associated with larger scale weather systems that 

bring widespread snow and rain to the eastern plains. Summer rains fall almost entirely during 

brief, but frequently intense thunderstorms. 

Within the planning area, an area surrounding Clarks Fork of the Yellowstone River in Carbon 

County is one of the driest portions of Montana. In this area, 8 miles south-southwest of Belfry, 

the average precipitation for a 16-year period was 6.59 inches. 

Annual snowfall varies from 300 inches in mountain areas in the western half of the state, to 

around 20 inches at some stations in the two northern Divisions east of the Continental Divide. 

Most snow falls during November to March, with heavy snowstorms that can occur as early as 

mid-September or as late as May 1 in the higher southwestern half of the state. In eastern 

sections, early or late season snows are not common. Figure 3-6 - Montana Average Annual 

Precipitation depicts the state wide average annual precipitation. 

The greatest volume of flow of Montana’s rivers occurs during the spring and early summer 

months with the winter snowpack melt. Heavy rains falling during the spring thaw constitute a 
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3-20 Chapter 3: Affected Environment

serious flood threat. Ice jams may occur during the spring breakup, usually in March, and cause 

backwater flooding. Flash floods, although restricted in scope, are probably the most numerous 

and result from locally heavy rainstorms in the spring and summer. Damaging floods in 

Montana have occurred in 1952, 1953, 1964, and 2011. 

Figure 3-6 Montana Average Annual Precipitation 

Note: 

Source: NRIS 2011a. 

3.2.2.3 Other Climatic Features

Severe storms of various types occur in the planning area; however the most troublesome are 

hailstorms that cause crop and property damage of approximately $5 million on an average 

annual basis. This amount is not unusually large for an area of 146,316 square miles, and hail 

storm occurrence is limited mainly to July and August, infrequently in June and September. 

Tornadoes develop infrequently (approximately two per year) and occur almost entirely east of 

the Divide, mostly in the eastern third of the state. Local but severe windstorms can occur east 

of the Divide, from a few to several times a year. Drought in its most severe form is not 

common, but dry years do occur. All parts of the state rarely suffer from dryness at the same 

time. 

In spite of figures that indicate cold winters, growing seasons (freeze-free periods) are four 

months or more in much of the agricultural area. In parts of the middle Yellowstone Valley, in 

fact, the freeze-free period runs as long as the 150 day average at Miles City. Much of the state 
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Chapter 3: Affected Environment 3-21

has average freeze-free periods longer than 130 days, allowing plenty of time for growing a 

wide variety of crops. 

3.2.2.4 Climate Change

Climate is the combination of temperature, humidity, atmospheric pressure, wind, rainfall, 

sunshine, cloudiness, and other meteorological characteristics in a given region over a long 

period of time. Climate differs from weather, which is the present condition of these 

characteristics and their variations over shorter periods. Climate change involves long-term 

trends indicating a noticeable shift in climate. 

Primary climate indicators that can be monitored include ambient air temperature, atmospheric 

pressure, wind, relative humidity, precipitation amounts and timing, annual snow pack levels, 

stream flow volume and timing, and solar radiation. 

The Intergovernmental Panel on Climate Change (IPCC) concluded “warming of the climate 

system is unequivocal” and “most of the observed increase in globally average temperatures 

since the mid-20th century is very likely due to the observed increase in anthropogenic 

greenhouse gas concentrations.” Chapter 9 of Working Group I of the 2007 IPCC Report 

(IPCC 2007) addressed the causes of climate change. Some of the conclusions included: 1) 

human-induced warming of the climate system is widespread, 2) “it is likely” that there has 

been a substantial anthropogenic contribution to surface temperature increases since the mid20th century, and 3) surface temperature extremes have “likely” been affected by anthropogenic 

forcing. As with any field of scientific study, there are uncertainties associated with the science 

of climate change. This does not imply that scientists do not have confidence in many aspects 

of climate change science. Some aspects of the science are known with virtual certainty 

because they are based on well-known physical laws and document trends (USEPA 2008). 

The temperature of the planet’s atmosphere is determined by the amount of solar radiation 

absorbed by the earth and its atmosphere. GHGs (primarily carbon dioxide [CO2], methane, and 

nitrous oxide [N2O]) increase the earth’s temperature by reducing the amount of solar energy 

that re-radiates back into space. In other words, more heat is trapped in the earth’s atmosphere 

when atmospheric concentrations of GHGs are greater. While GHGs have occurred naturally 

for millennia and are necessary for life on earth, increased atmospheric concentrations of GHGs 

as well as land use changes are contributing to an increase in average global temperature 

(USEPA 2007). This warming is associated with climatic variability that exceeds the historic 

norm and is known as climate change. Extensive explanations of climate change causes and 

effects are provided in the Climate Change Supplementary Information Report: Montana, 

North Dakota, and South Dakota Bureau of Land Management (BLM 2010a), IPCC Fourth 

Assessment (IPCC 2007), Climate Change Indicators in the United States (USEPA 2010e), and 

Global Climate Change Impacts in the United States (USGCRP 2009). 

Annual GHG emissions for Montana, the United States, and the world are summarized in Table 

3-9. Annual emissions of GHGs are usually quantified in units of metric tons (mt). A metric ton 

is equivalent to approximately 2,005 pounds (1.102 short tons). The combined effect of 

emissions of multiple GHGs is reported in terms of carbon dioxide equivalent (CO2e), which is 

calculated by multiplying emissions by a global warming potential (GWP) number that takes 

into account each gas’ atmospheric longevity and its heat-trapping capability. The GWP of CO2
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3-22 Chapter 3: Affected Environment

is set at 1. The USEPA determined other GHGs’ relative climate change potentials over a 100-

year time period. In USEPA regulations effective as of November 1, 2013, global warming 

potentials for methane and nitrous oxide are 21 and 310, respectively. The USEPA proposed to 

revised these global warming potentials to 25 (methane) and 298 (nitrous oxide). CO2e 

emissions given in this document are based on global warming potential values of 21 and 310 

because data referenced for comparison purposes are based on these values. 

Other organizations, such as the IPCC, have set different GWPs and these vary depending on 

the time frame being analyzed. For example, estimates of methane’s global warming potential 

over a 20-year period range from 72 to 105. The BLM uses the methane global warming 

potentials that are specified in EPA regulations and are used for GHG emission reporting under 

40 Code of Federal Regulations Part 98 as of November 1, 2013. This approach allows for 

consistent comparisons with state and national GHG emission inventories. The BLM also 

provides estimated methane and nitrous oxide emission quantities in Chapter 4, which allow the 

public to use other global warming potentials to calculate CO2e, if desired. 

Planning area GHG emission sources include combustion equipment such as heaters and 

engines, oil and gas development and production, coal mining, fire events, motorized vehicle 

use (construction equipment, cars and trucks, and off-highway vehicles), livestock grazing, 

facilities development, and other equipment exhaust and fugitive emissions. Contributions to 

climate change also result from land use changes (conversion of land to less reflective surfaces 

that absorb heat, such as concrete or pavement), changes in vegetation, and soil erosion (which 

can reduce snow’s solar reflectivity and contribute to faster snowmelt). Emission controls on 

some sources can reduce GHG emissions. 

Table 3-9 Estimated Annual GHG Emissions 

Entity Data Year

CO2e Emissions 

(106 mt)1

Montana2 2007 50.4

United States3 2011 6,702

Global4 2004 49,000

Note: 

1

 Emissions exclude GHG emissions and sequestration due to land use and land use changes. 

2 World Resources Institute Climate Analysis Tool (WRI 2011).

3 Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2011 (USEPA 2013a).

4 Climate Change 2007: Synthesis Report (IPCC 2007). 

Global atmospheric concentrations of GHGs are determined by the quantity of GHGs emitted 

to and removed from the atmosphere. Global concentrations of CO2, methane, and N2O in 2009 

were 387 parts per million (ppm), 1,744 parts per billion (ppb), and 323 ppb, respectively 

(USEPA 2011a). More recently, the CO2 concentration monitored at the Mauna Loa 

Observatory in Hawaii surpassed 400 ppm for the first time in May 2013. Atmospheric 

concentrations of CO2 can be reduced by carbon storage in forests, woodlands, and rangelands, 

as well as in underground carbon sequestration projects. Vegetation management can provide a 

source of CO2 (e.g., prescribed burns) or it can provide a sink of CO2 through vegetation 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-23

growth. The net storage or loss of carbon on rangelands and grasslands in the planning area is 

generally small and difficult to estimate or measure. Most soils within the planning area contain 

relatively little organic matter compared to forest soils, and forests and woodlands make up 

approximately 7 percent of the total acres on public lands in the planning area. 

3.2.2.4.1 Climate Change Trends 

Climate change trends include two types of trends: historic and predicted. Historic trends 

describe climate changes that have already been observed. Predicted climate change indicates 

modeled future changes based on assumptions of future global GHG emission and resulting 

environmental effects. Climate change will continue into the future even if GHG emissions 

remain at current levels or decrease. Long lag times are associated with the massive thermal 

energy stored in oceans, which can take decades, or even centuries, to adjust to climate changes 

(USEPA 2010e). In addition, the long lifetimes of many GHGs contribute to committed climate 

change. For example, CO2 typically remains in the atmosphere for 50–200 years, depending on 

how long it takes CO2 molecules to be absorbed by plants, land, or the ocean. N2O is also longlived; it remains in the atmosphere for approximately 120 years. In contrast, methane has a 

shorter lifetime and remains in the atmosphere for approximately 12 years (USEPA 2010e). 

Additional types of GHGs also contribute to climate change, but their impact is substantially 

less due to their relatively small concentrations in the atmosphere. 

3.2.2.4.2 Temperature and Precipitation 

Historical global mean surface temperatures have increased nearly 1.3°F from 1906 through 

2008 (GISS and Sato 2010). Northern latitudes (above 23.6 through 90.0° N) have exhibited 

greater temperature increases of nearly 2.1°F since 1900, with nearly a 1.8 °F increase since 

1970 alone (GISS and Sato 2010). In the planning area, data from 1941 through 2005 indicate a 

long-term temperature increase between 0.40 to 0.80 °F per decade since 1976, as shown in 

Figure 3-7 – Long-Term Historical Temperature and Precipitation Trends. Over a recent 

32-year period, planning area observed winter temperatures increased up to 7°F (USGCRP 

2009). With regard to precipitation, data from 1931 through 2005 indicate little change in total 

annual precipitation in eastern Montana since 1976. However, the timing of precipitation may 

have changed. 
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3-24 Chapter 3: Affected Environment

Figure 3-7 Long-Term Historical Temperature and Precipitation Trends 

Note: 

Source: NOAA 2010a 

Predictions of future temperature changes compared to a 1961–1979 baseline indicate that 

temperatures in the planning area may increase 2–3°F by 2010–2029, as shown in Figure 3-8 –

Near-Term Predicted Temperature Increases. Temperatures are predicted to continue increasing 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-25

through the century by 3–5°F by the mid-twenty-first century and increase by 5–9°F by the end 

of the century, compared to the 1961–1979 baseline (USGCRP 2009). The lower end of these 

ranges is based on a lower future GHG emission scenario, while the upper end of the ranges is 

based on a higher GHG emission scenario. Along with generally increasing temperatures, many 

more days are predicted to have maximum temperatures greater than 100°F (USGCRP 2009). 

In 2001, the IPCC indicated that by the year 2100, global average surface temperatures would 

increase 2.5 to 10.4°F above 1990 levels (IPCC 2001). Computer model predictions indicate 

that increases in temperature will not be equally distributed, but are likely to be accentuated at 

higher latitudes. Warming during the winter months is expected to be greater than during the 

summer, and increases in daily minimum temperatures is more likely than increases in daily 

maximum temperatures. Rising temperatures would increase water vapor in the atmosphere, 

and reduce soil moisture, increasing generalized drought conditions, while at the same time 

enhancing heavy storm events. 

Figure 3-8 Near-Term Predicted Temperature Increases 

Note: 

Source: USGCRP 2009. 

Prediction of future precipitation changes from the recent past to 2080–2099 indicate that 

precipitation in the planning area will increase 15–20 percent in winter and spring and will 

decrease no more than 5 percent in summer. During fall, precipitation in the northern part of the 

planning area will increase by up to 5 percent while the southern portion of the planning will 

experience a 0–5 percent decrease (USGCRP 2009). 

In addition to temperature and total precipitation changes, predicted climate changes include 

changes in precipitation timing by season and an increase extreme rainfall events and other 

extreme weather events. Due to warming temperatures melting glaciers and thermal expansion 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

3-26 Chapter 3: Affected Environment

within the seawater, ocean levels are expected to rise. These changes will affect a broad array 

of ecosystems and affect food supplies and human health. 

3.2.2.4.3 Climate Change Effects on Resources 

Climate change affects nearly all resources at local, regional, and global levels. The effects of 

climate change are so widespread that they cannot all be described in this RMP. To illustrate 

the effects of global temperature change, Figure 3-9 – Examples of Resource Impacts Due to 

Climate Change provides broad examples of climate change impacts. As global temperatures 

increase, effects on resources become more significant. 

Figure 3-9 Examples of Resource Impacts Due to Climate Change 

Temperature and precipitation changes could directly affect air quality. Air quality would be 

improved if increased precipitation reduces wind-blown dust, but would be degraded if dry 

periods cause increased particulate emissions. Ground-level ozone may also be affected. High 

temperatures are a contributing factor in ground-level ozone formation, which is highly 

dependent on NOx and VOC concentrations. End-of-century ozone concentrations in the 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-27

planning area are predicted to decrease during the months of June through August based on a 

lower GHG emission scenario and increase based on a higher emission scenario (USGCRP 

2009). 

Climate change will affect water quality in the planning area. Increasing temperatures in the 

planning area are likely to contribute to increased evaporation, drought frequencies, and 

declining water quantity. The warming of lakes and rivers will adversely affect the thermal 

structure and water quality of hydrological systems, which will add additional stress to water 

resources in the region (IPCC 2007). The planning area depends on temperature-sensitive 

springtime snowpack to meet demand for water from municipal, industrial, agricultural, 

recreational uses and BLM authorized activities. The USGS notes that mountain ecosystems in 

the western United States are particularly sensitive to climate change. Higher elevations, where 

much of the snowpack occurs, have experienced three times the global average temperature 

increase over the past century (USGS 2010). Higher temperatures are causing more winter 

precipitation to fall as rain rather than snow, which contributes to earlier snowmelt. Additional 

declines in snowmelt associated with climate change are projected, which would reduce the 

amount of water available during summer (USGCRP 2009). Rapid spring snowmelt due to 

sudden and unseasonal temperature increases can also lead to greater erosive events and 

unstable soil conditions. 

Increases in average summer temperatures and earlier spring snowmelt in the planning area are 

expected to increase the risk of wildfires by increasing summer moisture deficits (USGCRP 

2009). Studies have shown that earlier snowmelts can lead to a longer dry season, which 

increases the incidence of catastrophic fire (Westerling 2006). Together with historic changes 

in land use, climate change is anticipated to increase the occurrence of wildfire throughout the 

western United States. Predicted climate change impacts to wildfires show large increases in 

the annual average acreage burned. Based on modeling that assumed a 1°C (1.8°F) increase in 

global average temperature, a 393 percent increase in acreage burned in wildfires is predicted in 

the planning area (USGCRP 2009). Air quality, ecosystem, and economic impacts from 

wildfires are extensive. Wildfires also release large quantities of CO2 that would increase 

atmospheric GHG concentrations. 

There is evidence that recent warming is affecting terrestrial and aquatic biological systems 

(IPCC 2007). Warming temperatures are leading to earlier timing of spring events such as leaf 

unfolding, bird migration, and egg-laying (IPCC 2007). The range of many plant and animal 

species has shifted poleward and to higher elevation, as the climate of these species’ traditional 

habitat changes. As future changes in climate are predicted to be even greater past changes, 

there will likely be even larger range shifts in the coming decades (Lawler 2009). Warming 

temperatures are also linked to earlier vegetation growth in the spring and longer thermal 

growing seasons (IPCC 2007). In aquatic habitats, increases in algal abundance in high-altitude 

lakes have been linked to warmer temperatures, while range changes and earlier fish migrations 

in rivers have also been observed (IPCC 2007). Climate change is likely to combine with other 

human-induced stress to further increase the vulnerability of ecosystems to additional pests, 

additional invasive species, and loss of native species. Climate change is likely to affect 

breeding patterns, water and food supply, and habitat availability to some degree. Sensitive 

species in the planning area, such as the sage grouse, which are already stressed by declining 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

3-28 Chapter 3: Affected Environment

habitat, increased development, and other factors, could experience additional pressures 

because of climate change. 

More frequent flooding events, erosion, wildfires, and hotter temperatures pose increased 

threats to cultural and paleontological sites and artifacts. Heat from wildfires, suppression 

activities, and equipment, as well as greater ambient daytime heat can damage sensitive cultural 

resources. Similarly, flooding and erosion can wash away artifacts and damage cultural and 

paleontological sites. However, these same events may also uncover and lead to discoveries of 

new cultural and paleontological localities. 

Climate change also poses challenges for many resource uses on BLM-administered land. 

Increased temperatures, drought, and evaporation may reduce seasonal water supplies for 

livestock and could impact forage availability. However, in non-drought years, longer growing 

seasons resulting from thermal increases may increase forage availability throughout the year. 

Shifts in wildlife habitat due to climate change may influence hunting and fishing activities, 

and early snowmelt may affect winter and water-based recreational activities. Drought and 

resulting stress on vegetation is likely to increase the frequency and intensity of mountain bark 

beetle and other insect infestations, which further increases the risk of fire and reduces the 

potential for sale of forest products on BLM-administered lands. 

3.2.2.4.4 National Actions to Reduce GHGs 

U.S. GHG emissions are expected to decline due to USEPA’s listing of GHGs as a regulated air 

pollutant and implementation of several recent GHG regulatory programs. Facilities with large 

emissions of GHGs must report these emissions to USEPA and new facilities with large 

expected GHG emissions must obtain air quality permits and potentially control GHG 

emissions. 

With regard to oil and gas activities, USEPA regulations in 40 Code of Federal Regulations 

(CFR) Part 60, Subpart OOOO require emission controls or reductions on hydraulically 

fractured gas wells, oil and condensate storage tanks, gas venting, and equipment leaks that are 

predicted to reduce national methane emissions by 1 million tons per year. These regulations 

became effective on October 15, 2012. 

The USEPA also requires facilities that emit more than 25,000 metric tons per year (mtpy) of 

CO2e to report emissions on an annual basis. Regulations for this reporting program were 

promulgated under the Greenhouse Gas Mandatory Reporting Rule in 40 CFR Part 98. While 

most types of sources began reporting emissions for calendar year 2010, onshore oil and gas 

sources began reporting emissions for calendar year 2012. The USEPA’s Facility Level 

Information on GreenHouse Gases Tool (FLIGHT) website provides public access to the data 

and became operational in April 2013 (USEPA 2013b). The BLM obtained data in December 

2013 and assessed emissions and emission sources for calendar year 2012. 

No coal mines on BLM surface or mineral estate within the planning area reported GHG 

emissions under the EPA Mandatory Reporting Rule (USEPA 2013b). Because only 

underground mines are required to report, it is possible that some surface mines could have had 

emissions exceeding 25,000 mtpy CO2e and were not required to report. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-29

No oil and gas production companies reported activities within the planning area that 

contributed to emissions exceeding the 25,000 mtpy reporting threshold (USEPA 2013b). 

USEPA regulations require that onshore oil and gas facilities report total GHG emissions for 

each oil and gas basin in which they operate. Based on USEPA’s FLIGHT map, the northern 

portion of the Big Horn Basin includes portions of Carbon and Big Horn counties within the 

planning area, as well as the Bighorn, Hot Springs, Park, and Washakie counties of northern 

Wyoming. Two companies reported GHG emissions from oil and gas production facilities in 

the northern Wyoming portion of the Big Horn Basin. Due to the close geographic proximity of 

facilities in this area of Wyoming, USEPA GHG emission data for the Big Horn Basin is 

considered to be representative of the planning area portion of the basin and is reported in the 

following discussion. 

Within the Big Horn Basin, CO2 from oil and gas production facilities accounted for 36 percent 

of CO2e emissions, while methane accounted for 64 percent of CO2e emissions. Table 3-10

provides a summary of the largest source types for CO2 and methane emissions. 

Table 3-10 Oil and Gas Greenhouse Gas Emission Sources Within the Big Horn Basin

Source: Derived from GHG emissions reported for calendar year 2012 under the EPA GHG Mandatory Reporting Rule for the entire Williston Basin. (EPA 

2013b). 

The following types of oil and gas methane emission sources accounted for less than 2 percent 

of CO2e emissions based on Big Horn Basin FLIGHT data (EPA 2013b). 

 Acid gas removal (zero methane emissions) 

 Associated gas venting and flaring (zero methane emissions) 

 Blowdown vent stacks (zero methane emissions) 

 Centrifugal compressors (zero methane emissions) 

 Dehydrators 

 Enhanced oil recovery injection pump blowdown (zero methane emissions) 

Oil and Gas Greenhouse Gas Emission Sources Within the Big Horn Basin

Oil and Gas Source Type

Percentage of 

Total CH4

Emissions

Percentage 

of Total 

CO2

Emissions

Percentage 

of Total 

CO2e 

Emissions

Is Source

Subject to 

Regulation That 

Will Reduce 

Future CH4

Emissions?

Gas from produced oil 

sent to atmospheric tanks 57% 21.5% 44% Yes

Natural gas pneumatic 

devices 21% <0.1% 14% Yes

Other equipment leaks 19% 1.3% 12% Yes

Dehydrators 2% <0.1% <0.1% Yes

Natural gas distribution 

combustion equipment <0.1% 57.0% 21% No

Flare stacks <0.1% 19.5% 7% No

Other sources 1% 0.6% 2% ---

Total 100% 100% 100%
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 Flare stacks 

 Gas well completion and workover 

 Natural gas pneumatic devices 

 Natural gas pneumatic pumps 

 Reciprocating compressors 

 Transmission tanks (zero methane emissions) 

 Well testing venting and flaring 

 Well venting and liquids unloading 

A trade-off exists between methane and CO2 emissions. Combustion of methane contained in 

natural gas decreases methane emissions while increasing CO2 emissions. Flaring of natural gas 

is an example of this trade-off. Natural gas produced during oil production is known as 

associated gas. 

Within the US Department of the Interior (USDI), several initiatives have been launched to 

improve the ability to understand, predict, and adapt to the challenges of climate change. The 

Secretary of the Interior signed Secretarial Order 3289 on February 22, 2010, establishing a 

Department-wide, scientific-based approach to increase understanding of climate change and to 

coordinate an effective response to impacts on managed resources. The order reiterated the 

importance of analyzing potential climate change impacts when undertaking long-range 

planning issues, and also established several initiatives including the development of eight 

Regional Climate Science Centers. Regional Climate Science Centers would provide scientific 

information and tools that land and resource managers can apply to monitor and adapt to 

climate changes at regional and local scales (USDI 2010). The North Central Climate Science 

Center, which will incorporate the planning area, has a target establishment date of 2011. 

Given the broad spatial influence of climate change, which requires response at the landscapelevel, the USDI also established Landscape Conservation Cooperatives, which are 

management-science partnerships that help to inform management actions addressing climate 

change across landscapes. These Cooperatives are formed and directed by land, water, wildlife 

and cultural resource managers and interested public and private organizations, designed to 

increase the scope of climate change response beyond federal lands. 

Rapid ecoregional assessments are one of the tools the BLM uses to monitor and respond to the 

effects of climate change. Ecoregional assessments are geospatial landscape evaluations that 

are designed to identify areas of high ecological value within an ecoregion that may warrant 

conservation, adaptation, or restoration. These assessments can help to identify resources that 

are being impacted by climate change and provide information to facilitate the subsequent 

development of an ecoregional conservation strategy for plants, wildlife and fish communities 

on public lands. Ecoregional assessments can identify areas, species, and ecological features 

and services that are sensitive to ecosystem instability and changes in climatic conditions. One 

of the objectives of the BLM rapid ecoregional assessments is to provide guidance for 

adaptation and mitigation planning in response to climate change. 

In addition to efforts being undertaken to better respond and adapt to climate change, other 

federal initiatives are being implemented to mitigate climate change. The Carbon Storage 

Project was implemented to develop carbon sequestration methodologies for geological (i.e., 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-31

underground) and biological (e.g., forests and rangelands) carbon storage. The project is a 

collaboration of federal agency and external stakeholders to enhance carbon storage in geologic 

formations and in plants and soils in an environmentally responsible manner. The Carbon 

Footprint Project is a project to develop a unified GHG emission reduction program for the 

USDI, including setting a baseline and reduction goal for the Department’s GHG emissions and 

energy use. More information about USDI’s efforts to respond to climate change is available 

from www.doi.gov/whatwedo/climate/index.cfm. 

3.3 Geology 

3.3.1 Geologic Setting 

Mountain ranges in the BiFO planning area include the Absaroka-Beartooth, Big and Little 

Snowy, Pryor, Crazy, and Bull mountains. Rock uplift and resultant erosion has exposed the 

core of these ranges, providing evidence of their structures and the forces which produced them 

(Figure 3-10- Stratigraphic Column). The Absaroka-Beartooth range forms a large rectangular 

block of rock 80 miles long and 40 miles wide. Rocks are predominantly Precambrian 

metamorphic rocks, up to 3.1 billion years old. These rocks were once shale, limestone, and 

sandstone that were altered to gneisses, schists, marble, and quartzite by high temperatures and 

pressures of burial deep beneath the earth’s crust. Rocks in this range have been uplifted 

several thousand feet along faults, folding the overlying Paleozoic and Mesozoic sedimentary 

rock. Along the Beartooth Front south of Red Lodge and up the Boulder River, sedimentary 

rocks have been tilted to a nearly vertical position. 

The Pryor Mountains were developed through generally vertical uplift of deep seated 

Precambrian basement rocks. The overlying strata fractured into five distinct blocks, with high 

angle faults on their north and west flanks. Paleozoic and Lower Mesozoic rocks outcrop over 

most of the range. Only on the East Pryor Mountain fault block was the uplift sufficient to 

bring these basement rocks to the surface (Blackstone 1975). West of the Pryor Mountains, 

successively younger rocks outcrop, with a dip close to that of the Red Pryor Mountain fault 

block. 

The Snowy Mountains are the most obvious expression of a general uplift that affected all of 

central Montana. Here, uplift was caused mainly by horizontal compression rather than the 

vertical forces described above. The strata were folded into a series of anticlines (upfolds) and 

synclines (downfolds) which provide much of the topographic relief in the region. Devil’s 

Basin is a good example of such an anticline (Reeves 1931). 

The Bull Mountains are a series of small, broken plateaus, little more than hills when compared 

to other mountains in the region. The massive sandstones of the Tongue River Member of the 

Fort Union Formation and interspersed clinker (formed when coal beds burned) which cap the 

plateaus, are more resistant to erosion than the soft sandstones and shale which underlie them. 

The harder rocks are preserved as remnants of higher topographic relief, even though the 

geologic structure is a basin (Woolsey, et. a1. 1917; Alt and Hyndman 1991). 

The Crazy Mountains are unique in that they are the only range in the area formed by the 

intrusion of molten rock (magma). Magma rose from great depth and was injected into fissures 
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between strata, doming the overlying sediments. Subsequent erosion has exposed this igneous 

rock, and strata dip away from the mountain core in all directions. Another interesting feature 

of the Crazy Mountains is the system of dikes (magma injected into cracks through the strata) 

that radiate outward from the mountains, resembling spokes from the hub of a wheel. The high 

southern end of the range is one major intrusion, the Big Timber Stock (Alt and Hyndman 

1991). 

The surrounding plains areas are composed of flat lying or slightly tilted sedimentary rocks 

deposited during the Cretaceous Period and Paleocene Epoch. Rocks are predominantly shales 

and sandstones with minor limestone, coal, and bentonite beds. Small anticlines and fault 

systems associated with the mountain uplifts described above affect the bedding and outcrop 

pattern of these rocks. Examples include the Crazy Mountain Basin, Lake Basin fault zone, and 

Nye-Bowler Lineament. 

The most recent sedimentary deposits found in the planning area are gravel alluvium. This 

material often forms benches or terraces. Sources for the material vary, but generally benches 

develop along mountain foothills through accumulation of outwash from the slow erosion of 

those ranges. Terraces, on the other hand, represent old stream channels that have been filled 

with gravel and then abandoned as the streams cut down through their floodplains. No 

continental glaciations reached this far south in Montana, though alpine glaciers occupied the 

upper slopes of the mountain ranges. These glaciers left mountain lakes, U-shaped valleys, and 

mounds of drift as evidence of their passing (Perry 1962). 

Overall, sedimentation has been nearly continuous from the Cambrian to the Paleocene (about 

500 million years) aggregating over 10,000 feet of rock as shown in Figure 3-10– Stratigraphic 

Column. Further information can be found at http://www.mbmg.mtech.edu/gmr/gmrstatemap.asp. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-33

Figure 3-10 Stratigraphic Column 

Formation

Range of Average 

Thickness

(in feet) Description Formation

Range of Average 

Thickness

(in feet) Description

CENEZOIC

QUARTERNARY

Alluvium

Unconsolidated stream and fan 

deposits range from fine to course 

grained.

PALEOZOIC

TRIASSIC

Chugwater

eroded 

0-800’

Brick-red sandstones, shales and 

siltstones, often ripple-marked; gypsum bed 

20-30’ thick.

TERTIARY

Tongue 

River

Member

Fort Union Formation

Up to 2500’

Light yellow sandstone with brown 

and light-dark gray shale; many coal 

beds; reddish clinker.

PERMIAN

Embar

eroded

5-100’ White porous limestone. Reported gypsum 

bed; oil producer in Elk Basin field.

Lebo

Dark gray shale with orange to 

purple ironstone concretions and 

green-gray beds of altered volcanic 

ash. 

PENNSYVANIAN

Ten Sleep 

quadrant

50-105’ White to buff cross-bedded soft sandstone; 

oil producer in Elk Basin field.

Tullock

Light tan to yellow sandstone with 

brown shale and tan-gray siltstone; 

some coal and clinker. Amsden 150-350’

Red shales, white limestone, 

chart/limestone breccias; uranium 

mineralization; contains oil in Central 

Montana fields.

MESOZOIC

CRETACEOUS

Hellcreek 300-1200’ Fresh water deposits of alternating 

sandstones and clay shales.

Fox Hills

Sandstone 100-200’ Gray to yellowish sandstone and sandy shales.

Alaska Bench 100-150’ Hard gray fossiliferous limestone; exposed 

in Snowy Mountains.

Bear Paw 900’

Steel-gray to black marine shale 

containing a few grayish white and 

dark-red concretions and beds of 

bentonite.

Judith River 200-400’

Fresh and brackish water deposits 

consisting of irregularly and thinbedded gray clayey sand, 

sandstone, lignite clay and coal 

beds.

Tyler 5-100’

White to brick-red cross-bedded channel 

sandstone; produces oil in Central Montana 

Field.

Cleggett 500’

Dark-brownish-black marine shale 

containing persistent yellow 

calcareous concretionary beds; 

bentonite and tan sandstone in the 

upper part.

DEVONIAN

Heath

Big Snowy Group

150- 500’

Found in Central and Eastern Montana 

only.

Heath: Black shales and black limestone; 

serves as source rock for petroleum in 

Central Montana oil/metalliferous shale

Eagle 220’

Massive and thin-bedded buff to 

white sandstone, carbonaceous 

shale, and coal beds.

Telegraph 

Creek 180-300’

Dark gray-black, thin beds of marine 

shale with thin sandstone members 

especially near the base; 

fossiliferous; gypsiferous. Otter Otter: Light green shales and limestone.

Niobara 200’ Upper part mark lower lightish yellow 

to whitish limestone.

Kibbey Kibbey: Red to brown sandstones and 

shale; some gypsum.

Carlisle 150-300’

Gray shales with thin shaly to silty 

sandstone layers, some bentonite, 

some ironstone concretions.

Greenhorn 600’

Black shales with hard, thin 

sandstone beds, buff-light gray 

limestone layers in eastern Montana 

with interbedded calcareous shales, 

some bentonite.

MISSISSIPPIAN

Mission 

Canyon

Madison Group

600-1200’

Mission Canyon: Massive while or gray 

(marine) limestone.

Frontier 150-500’

Alternating beds of gray to yellow 

sandstone and dark carbonaceous 

shales; contains bentonite beds in 

Carbon County. Produces gas in Dry 

Creek field.

Lodgepole

Lodegpole: Thin bedded, cherty, 

fossiliferous limestone, produces oil in Elk 

Basin Field.

Mowry 180-325’

Hard light gray shales and thinbedded sandstone; contains 

numerous fish scales; also bentonite 

mined in Carbon County.

Three Forks 200-250’ Multicolored shales with thin dark limestone 

and yellow sandstone.

Thermopolis 700-760’

Upper and lower members are thick 

dark marine shales; middle member 

yellow-brown sandstone; shales 

have bentonite beds mined in 

Carbon County.

Jefferson 50-600’ Brown to gray and black limestone and 

dolomite.

Cloverly 

Kootenai

160-500’

Upper member – Greybull 

sandstone; middle multicolored shale 

member; lower, Pryor conglomerate 

contains vertebrate fossils and 

petrified wood. Some uranium 

mineralization; gas producer in Dry 

Creek field.

ORDOVICIAN

Big Horn Dolomite 250-300’ Thin Bedded or massive limestones and 

dolomite; upper portion very fossiliferous.

JURASSIC

Morrison 150-200’

Interbedded buff sandstone and 

gray-green shales; vertebrate fossils; 

some uranium mineralization

CAMBRIAN

Gros Ventre 700’ Greenish and gray calcareous shales and 

colitic limestones.

Swift 10-300’

Green shales and fine-grained thin 

bedded brown or green sandstone; 

fossiliferous (marine).

Flathead 185’ Hard dense quartzite with red to brown 

sandstone.

Rierdon 50-250’ Gray to green marine shales and thin 

limestone; fossiliferous.

PRECAMBRIAN

PreCambrian

Gneisses and schists, exposed only near 

Dryhead area of East Pryor Mountain, and 

on top of Beartooth Mountains. Piper 0-150’ Red to green shales and limestone 

with some gypsum
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3.4 Soil 

BiFO management decisions affect soil on BLM surface and split estate during minerals 

development. In general, soil management focuses on maintaining soil integrity, reclaiming 

disturbed soils, minimizing erosion and, in some cases, improving soil health. Detailed soils 

inventory data are available for a portion of the planning area; however, there are data gaps in 

the southwest and northwest portions of the planning area. These gaps do not occur on BLM 

managed surface lands, but only occur on 715 acres of BLM managed split estate. 

Additionally, while all of the BLM managed surface lands do have detailed soil data, 

Ecological Site Descriptions (ESDs) are not currently available on 151,211 acres due to several 

factors including limited soil development and rock outcrop formations. 

Major Land Resource Areas (MLRA) are geographically associated land resource units 

identified by the US Department of Agriculture (USDA) to facilitate regional and national 

planning. The dominant physical characteristics of the MLRAs describe the similar land use, 

elevation and topography, climate, water, soils, and potential natural vegetation in a designated 

area. Soils in the planning area are located in the following MLRAs (Map 5) (USDA 2006).

 32 – Northern Intermountain Desertic Basin 

o 17 ecological sites are listed within this MLRA 

 43B – Central Rocky Mountain 

o There are no approved ESDs for this MLRA 

 46S – Northern Rocky Mountain Foothills, South 

o 3 ecological sites are listed within this MLRA 

 58AC – Northern Rolling High Plains, Northern Part

o 21 ecological sites are listed within this MLRA 

 58AE - Northern Rolling Plains, North Part 

 22 ecological sites are listed within this MLRA 

Most of the planning area is in the Northern Rolling High Plains MLRA, an area of old eroded 

plateaus and terraces. Slopes generally are gently rolling to steep and wide belts of steeply 

sloping badlands border a few of the larger river valleys. In some areas, flat topped, steep sided 

buttes rise sharply above the general level of the plains. Elevations range from 2,950 to 3,280 

feet and in the mountains reach 6,900 feet. Shale, siltstone, and sandstone underlie much of the 

area. Marine and continental sediments are found mostly at the higher elevations. The dominant 

soil orders in this MLRA are Entisols and Inceptisols, and soils are generally shallow to very 

deep, well drained, and clayey or loamy. 

The Northern Rocky Mountain Foothills MLRA, with elevation ranges from 3,600 to 7870 feet, 

is in the south and northwestern region of the planning area. The foothills east of the Northern 

Rocky Mountains are on an old plateau of uplifted marine sediments. The rugged hills and low 

mountains are cut by many narrow valleys with steep gradients. Broad floodplains and fans 

border a few of the major rivers. Almost all this area is characterized by marine sediments. 

These rocks are primarily sandstones and shales with some layers of chalk and conglomerate. 

The dominant soil orders in this MLRA are Mollisols and Entisols, and soils are shallow to 

very deep, generally well drained, and loamy or clayey. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-36

Soils in the planning area are derived mainly from sedimentary bedrock and alluvium. Soil 

depth ranges from shallow to bedrock to very deep. Differences in climate, parent material, 

topography, and erosion conditions result in soils with diverse physical and chemical 

properties. An overview of the four geomorphic groups and associated soils in the planning 

area are presented below. 

3.4.1 Geomorphic Group One: Shale and Sandstone Uplands 

These soils formed in shale and sandstone uplands occurring throughout the area. The depth of 

soils in this group range from very shallow to deep, and their surface texture is primarily loamy 

with local areas of clayey or sandy textures. The number of rock fragments and amount of 

calcium carbonate (from limestone) in these soils vary depending on the bedrock and parent 

materials associated with each soil type. Terrain is usually gently rolling to very steep, highly 

dissected landscapes. 

3.4.2 Geomorphic Group Two: Floodplains, Streams, Terraces, and Fans 

This group includes soils that formed on floodplains, stream terraces, and fans found 

throughout the area. These soils contain deep, nearly level to strongly sloping soils that are well 

drained to very poorly drained. Soil textures range from loamy fine sand to clay. Rock 

fragments are more numerous along terrace edges near fast moving water areas. These soils are 

formed in alluvium dissected by incised water channels. 

3.4.3 Geomorphic Group Three: High Terraces and Benches 

Soils in this group formed on high terraces and benches mainly in Carbon, Musselshell, and 

Yellowstone counties. These soils comprise deep, well drained soils on nearly level to 

moderately sloping terrain dissected by deep drainages. Their textures are generally loamy or 

loamy skeletal (includes rock fragments), and the soils are high in calcium carbonate. Soils are 

formed in gravel outwash and alluvium from mixed rock sources. 

3.4.4 Geomorphic Group Four: Mountains and Foothills 

This group includes soils from the mountains (Beartooth, Bull, Crazy, Pryor and Snowy) and 

foothills in the planning area. Soil depths range from very shallow to deep, depending on the 

proximity to rock outcrops. They are well drained and are on gently sloping to very steep, 

dissected terrain. The texture is loamy or loamy skeletal with high calcium carbonate in the 

Pryor and Snowy mountain soils. These soils are formed from material derived from 

sedimentary, igneous, and metamorphic rocks. 

Soil erosion potential and susceptibility to damage can be evaluated using three indicators: 

T factor, Wind Erodibility Group, and Potential Fire Damage Hazard. T factor is an estimate of 

the maximum average annual rate of soil erosion by wind and/or water that can occur without 

affecting soil productivity over a sustained period. Soil erosion is related to soil depth, ground 

cover, slope, and organic matter content in surface layers. The rate is expressed in tons per acre 

per year and is usually compared to the actual rate of soil erosion to determine whether the 

erosion levels are sustainable to soil health and stability. Some soils in the planning area have a 

high T factor of 1 (Map 7 - T Factor Soils). In areas in Stillwater, Musselshell, and Wheatland 

counties, soil data inconsistencies make it difficult to summarize soils in that area and may be 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

3-37 Chapter 3: Affected Environment 

due to differences in the scale of the existing soil surveys. Further data development should be 

pursued whenever possible. 

A Wind Erodibility Group (WEG) is a grouping of soils with similar properties affecting their 

susceptibility to wind erosion of bare ground. Soils assigned to group 1 are the most susceptible 

to wind erosion. Musselshell, Golden Valley, Yellowstone, and Stillwater counties have the 

most soils susceptible to wind erosion in the planning area (Map 6 - Wind Erodibility Groups). 

The third rating indicates the potential hazard of damage to soil nutrients, physical, and biotic 

characteristics from fire. These ratings are based on texture of the surface layer, content of rock 

fragments and organic matter in the surface layer, thickness of the surface layer, and slope. 

Soils are described as having a low, moderate, or high potential for this kind of damage. 

Ratings indicate an evaluation of the potential impact to soils from prescribed fires or wildfires 

that are intense enough to remove the duff layer and consume organic matter in the surface 

layer. 

A rating of “low” indicates the soil has features that reduce its potential for fire damage. Good 

performance can be expected, and little or no maintenance is needed. A “moderate” rating 

indicates the soil has features that result in a moderate potential for fire damage. One or more 

soil properties are less than desirable, and fair performance can be expected. Some maintenance 

is needed. A “high” rating indicates the soil has one or more properties that result in a high 

potential for fire damage. Overcoming the unfavorable properties requires special design, extra 

maintenance, and costly alteration (Map 37 - High Potential Fire Damage Hazard Soils). 

Prime farmland is land that has the best combination of physical and chemical characteristics 

for producing food, feed, forage, fiber, and oilseed crops, and that is also available for these 

uses. The land could be currently used for cropland, pastureland, rangeland, forest land, or 

other land, but not urban or built up land or water areas. 

Unique farmland is land other than prime farmland that is used for the production of specific 

high value food and fiber crops. This land has the special combination of soil quality, location, 

growing season, and moisture supply needed to economically produce sustained high quality 

crops and/or high yields of a specific crop when the lands are treated and managed according to 

acceptable farming methods. 

The Farmland Protection Policy Act (FPPA) states that federal programs that contribute to the 

unnecessary and irreversible conversion of farmland to non-agricultural uses will be minimized 

and shall be administered in a manner that, as practicable, are compatible with state and local 

government and private programs and policies to protect farmland. No Prime or Unique 

Farmlands are located in the decision area. 

3.5 Water 

The United States is divided and subdivided into successively smaller hydrologic units 

classified into four levels: regions, sub regions, accounting units, and cataloging units. 

Generally, a hydrologic unit is defined as a geographic area from where water naturally drains 

to a specific outlet. Hydrologic units are arranged within each other, from the smallest 

(cataloging units) to the largest (regions). 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-38

Water resources in the semi-arid environment of the planning area include both surface and 

subsurface resources. The availability, volume, and quality of water resources affect other 

resources and resource uses, including, but not limited to, wetlands and riparian areas, 

biological resources, livestock grazing, recreation, and public water supplies. 

The BLM is responsible for managing surface lands and federal mineral estate in a manner that 

maintains or enhances water quality and quantity for other uses and complies with state and 

federal water quality standards. The BLM coordinates with state and other federal agencies to 

ensure compliance with required water resource management responsibilities. 

3.5.1 Surface Water 

The BiFO manages approximately 1,002 miles of perennial, intermittent, and ephemeral 

streams. Surface water runoff drains into the Yellowstone, Musselshell, Clarks Fork of the 

Yellowstone, Boulder, Stillwater, and Bighorn rivers (Table 3-11). Each major stream is 

characterized by a pattern of tributary branching streams ranging from ephemeral to perennial. 

Table 3-11 Annual Stream Flow Data 

River/Stream Site Code Parameter Name

Period of Approved Daily-Mean 

(Water Year)

From To Count

Big Horn at St. Xavier, MT 06287000 Discharge Cubic 

feet/sec 1935 2008 27028

Boulder near Big Timber, Mt 06200000 Discharge Cubic 

feet/sec 1947 2008 22009

Clarks Fork of the Yellowstone near 

Edgar, MT 06208500 Discharge Cubic feet/sec 1921 2008 25631

Clarks Fork of the Yellowstone near 

Belfry, MT 06207500 Discharge Cubic feet/sec 1921 2008 31838

Musselshell near Roundup, MT 06126500 Discharge Cubic 

feet/sec 1946 2008 27768

Musselshell near Musselshell, MT 06127500 Discharge Cubic 

feet/sec 1928 2009 19642

Stillwater near Absarokee, MT 06205000 Discharge Cubic 

feet/sec 1910 2008 27135

Yellowstone near Billings, MT 06214500 Discharge Cubic 

feet/sec 1904 2008 29708

Note: 

Source: USGS National Water Information System: http://waterdata.usgs.gov/mt/nwis/current?type=flow 

A total maximum daily load (TMDL) is the allowable pollutant loading from all sources (point, 

non-point, and natural background) established at a level necessary to achieve compliance with 

applicable surface water quality standards. Streams in the planning area meet these standards 

except for those listed below (Table 3-12). A majority of impairment sources are outside of 

BLM administered lands and come from agriculture production and industrial sources. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

3-39 Chapter 3: Affected Environment 

Table 3-12 Impaired Water Bodies 

Impaired Water Bodies by 4th Level Hydrologic Unit Code

4

th Hydrologic Unit Code

Stream Segment on 

BLM Land

Estimated Miles 

in BLM Land

Probable Impairment 

Type(s)A

Probable Impairment 

Source(s)B

Stillwater River

Stillwater 0.3 1, 4, 14 5, 9, 12, 14, 15

Bad Canyon 4.5 12 2

Clarks Fork of the 

Yellowstone

Clarks Fork 0.4 1, 3, 4, 9, 10, 12, 13 3, 4, 12,13

Silvertip 9.6 1, 2, 3, 5, 6, 7, 8, 9, 10, 11 1, 2, 6, 7, 8, 9, 10, 11

SF Bridger 5.2 3, 16 8, 9, 12

Bear 0.7 1, 2, 3, 4, 12 1, 2, 3, 4, 5

Blue Water 1.2 3, 8, 12 2, 3 , 4, 16, 18

Cottonwood .75 2, 5, 8 1, 2, 8, 9, 18

Upper Yellowstone

Yellowstone 4.3 1, 3, 8 3, 9, 10, 16, 17,

Boulder 0.14 1,2,4, 2,3,12

Big Lake .25 8 18

Big Horn Lake Crooked 3.2 13 18

Middle Musselshell

Musselshell 0.9 2, 10, 13 4, 6, 13, 18

North Willow 3.5 1, 3, 4, 6, 15, 9, 11, 12

Total 34.94

Note: 

A Cause: 1 = Nutrients, 2 = Alteration of Streamside Vegetation, 3 = Sediment, 4 = Metals, 5 = Oxygen Depletion, 

6 = Specific Conductance, 7 = Turbidity, 8 = Total Dissolved Solids, 9 = Temperature, 10 = Flow Alterations, 11 = Toxic 

Organics, 12 = Harmful Algae, 13 = Habitat Alterations, 14 = Cyanide, 15 = Sulfates, 16 = Arsenic 

B Source: 1 = Loss of Riparian Habitat, 2 = Rangeland Grazing; 3 = Irrigated Crop Production; 4 = Hydrologic Modification, 

5 = Abandoned Mine Lands, 6 = Channelization, 7 = Impoundments, 8 = Riparian Grazing, 9 = Natural, 10 = Industrial 

Permitted, 11 = Spills, 12 = Unknown, 13 = Streambank modification, 14 = Hard Rock Mining, 15 = Post Fire Runoff, 16 = 

Feedlots, 17 = Municipal Discharge, 18 = Agriculture 

Source: 2010 Montana 303(d)/ 305(b) Intergraded Report 

Wetlands and riparian areas can play a critical role in reducing nonpoint source pollution by 

intercepting surface runoff, subsurface flow, and certain ground water flows. Their role in 

water quality improvement includes processing, removing, transforming, and storing such 

pollutants as sediment, nitrogen, phosphorus, and certain heavy metals. Research also shows 

that riparian areas control the release of herbicides into surface waters (EPA 2005a). Thus, 

wetlands and riparian areas buffer receiving water from the effects of pollutants and/or prevent 

the entry of pollutants into receiving waters. It is important to consider that degradation of 

wetlands and riparian areas can inhibit their ability to treat NPS pollution, and degraded 

wetlands and riparian areas can also become sources of NPS pollution. Current wetland and 

riparian area conditions and management are described in Riparian Areas and Wetlands 

Section.
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-40

3.5.2 Ground Water 

Ground water is a valuable resource in Montana and is vulnerable to the effects of nonpoint 

source (NPS) pollution. Depending on the setting, ground water can be intricately linked with 

surface water. 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 in smaller towns. In 

many cases, ground water is also the primary source of water in streams and rivers during the 

fall and winter ‘baseflow’ period and may be the primary source of lake water. Additionally, 

ground water is vital to wetlands and riparian areas. 

The planning area is underlain by sandstone and limestone that provide large quantities of 

water to wells and springs. In the north, wells drilled to the Kootenai Formation yield good 

volumes and quality water. The Madison Limestone in the Pryor Mountains yields good 

quantities of water that is of quality suitable for domestic and agricultural use. In the Bull 

Mountains, ground water apparently occurs in perched aquifers and springs or seeps and is 

located near outcrops of the Mammoth-Rehder coal bed. Water is not as dependable in the Bull 

Mountains as elsewhere in the region. Water in springs is good quality with calcium, 

magnesium, and bicarbonate the principal ions. Deeper aquifers are present at depths that vary 

from 20 feet to several hundred feet. Deeper aquifers have water of lower quality with sodium 

and sulfate ions present. 

No current, comprehensive, quantification, nor quality measurements have been made on 

ground waters occurring on BLM administered lands. 

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. 

3.6 Vegetation 

There are numerous vegetation cover types in the BiFO planning area. These vegetation types 

are an expression of the wide range of climatic and soil conditions found throughout the 

planning area. The Landscape Fire and Resource Management Planning Tools Project 

(commonly referred to as LANDFIRE) was used to delineate rangelands and identify them as 

existing vegetation types (EVTs) (LANDFIRE 2006). Vegetation cover types and associated 

plant communities were defined and analyzed using the Northwest Regional Gap Analysis 

Project (NWReGAP), information provided by BLM resource specialists and other references, 

as noted (NWReGAP 2001). Nomenclature herein is consistent with the Nature Conservancy’s 

ecological classification database system known as NatureServe (NatureServe 2008). 

Vegetation cover types in the decision area consist primarily of shrubland and rangeland 

communities and cover approximately 386,212 acres (89 percent) of the total BLM managed 

surface acreage. Forest/woodlands and riparian/wetland vegetation cover types, comprise 

approximately 47,035 acres (11 percent) and are a biologically diverse and important resource 

in the decision area. Urban and agricultural cover types comprise the remaining 8,552 acres 

(2 percent) in the decision area. Table 3-13 summarizes vegetation cover types, spatial extent of 

each vegetation type, and a description of each associated plant community in the decision area. 

Map 9 (Vegetative Map) illustrates each vegetation cover type in the planning area. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

3-41 Chapter 3: Affected Environment 

Table 3-13 Percent of Vegetation Cover Types in the Decision Area 

Vegetation Cover Type

Total Cover 

(Acres/Percent) Characteristic Species

Shrubland 243,656 (56.1 %) Wyoming big sagebrush, Basin big sagebrush, 

black sage, saltbush and greasewood species

Rangelands 142,556 acres (32.8 %) Wheatgrass, grama, and needle-and thread 

species

Forest/Woodlands 32,100 acres (7.4 %)

Ponderosa pine, lodgepole pine, limber pine, 

Douglas-fir, subalpine fir, Engelmann spruce, 

quaking aspen, Rocky Mountain juniper, Utah 

juniper, and cottonwood species

Riparian/Wetlands 14,966 acres (3.5 %)

Cottonwood species, quaking aspen, green ash, 

willow, red osier dogwood with understory of 

woody plant and grass/forbs

Urban and Agricultural Lands 876 acres (<1 %)

Agricultural species including hay, alfalfa, corn 

and introduced herbaceous species including 

bluegrass and ornamental grass and tree species

TOTAL 434,154 acres (100.0 %)

Regardless of cover type, the BLM uses the Standards for Rangeland Health to manage public 

lands. The Billings Field Office uses five standards to assess rangeland health. These 

standards are: Standard 1 - Uplands, Standard 2 - Riparian and Wetlands, Standard 3 – Water 

Quality, Standard 4 – Air Quality, Standard 5 – Habitat. Standards 1, 2, and 5 directly relate to 

vegetation, while Standards 3, 4, and potentially 5 are influenced by vegetation. Table 3-17

shows the number of allotments/acres within the decision area where Standards are or are not 

being met and if appropriate action has been taken to make progress towards meeting 

Standards. 

3.6.1 Forest and Woodlands 

Forest and woodland areas were delineated utilizing LANDFIRE. Twenty-two separate forest 

and woodland habitat communities were mapped to identify existing vegetation types (EVTs) 

in the planning area. Forests/woodlands comprise approximately 32,100 acres (7.5 percent) of

the decision area. Cover types are characterized as a composite of evergreen conifer and 

deciduous forest types that occur throughout Montana. Species dominance varies with altitude, 

latitude, slope, aspect, topography, soil characteristics, and climatic regime. The predominant 

tree species include ponderosa pine (Pinus ponderosa), lodgepole pine (Pinus contorta), limber 

pine (Pinus flexilis), Douglas-fir (Pseudotsuga menziesii), subalpine fir (Abies lasiocarpa), 

Engelmann spruce (Picea engelmannii), quaking aspen (Populus tremuloides), and Eastern 

cottonwood (Populus deltoides). Rocky Mountain juniper (Juniperus scopulorum) is the 

predominant woodland species found throughout the decision area. Table 3-14 details each 

forest and woodland ecological system community, the spatial extent of each type, and a 

description of each associated plant community in the decision area. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-42

Table 3-14 Forest/Woodland Vegetation Cover Types

Forest and Woodland 

Ecological System and 

Community Name

Total Vegetation 

Cover in Decision

Area (Percent)

Forest/ Woodland 

Cover in Decision Area

(Percent)

Total 

Acreage

Predominant Woody 

Characteristic 

Species

Northwestern Great PlainsBlack Hills Ponderosa Pine 

Woodland and Savanna & 

Associated Ponderosa Pine 

Communities

3% 42% 13,400

Ponderosa pine and 

Rocky Mountain 

juniper

Middle Rocky Mountain 

Montane Douglas-Fir Forest 

and Woodland/Pseudotsuga 

menziesii Forest Alliance

2% 24% 7,800 Douglas-fir, lodgepole 

pine, subalpine fir

Northern Rocky Mountain DryMesic Montane Mixed Conifer 

Forest 

1% 14% 4,600

Lodgepole pine, 

Douglas-fir, 

Engelmann spruce, 

and subalpine fir

Rocky Mountain Foothill Limber 

Pine-Juniper Woodland 1% 12% 3,800 Limber pine and Rocky Mountain juniper

Other Forest and Woodland 

Ecological Systems and 

Communities

0.6% 8% 2,500

Quaking aspen, Rocky 

Mountain juniper, oneseed juniper 

(Juniperus 

monosperma),

lodgepole pine, 

Engelmann spruce, 

and cottonwood

species.

TOTAL 7.6% 100% 32,100 N/A

Note: 

Source: NatureServe 2008, LANDFIRE National Existing Vegetation Type layer 2006.

Quaking aspen communities or “stands” comprise a small percentage of the overall vegetation 

community structure in the decision area. They are often found as small groves in mountain 

coniferous forest communities. These communities usually support a dense understory of 

mixed grasses and forbs with an occasional shrub component. Quaking aspen communities are 

most abundant along the Beartooth and Absaroka mountains and appear to be mature stands. 

These stands vigorously resprout following fire and are often an early seral stage species in 

forested communities. Many show evidence of invasion by shade tolerant conifers, which may 

eventually replace the quaking aspen component; however, conifer removal would promote 

aspen regeneration (Howard 1996). 

Douglas-fir communities are found on north slopes in the Pryor Mountains and throughout the 

Beartooth and Absaroka mountain areas. This forest type is generally found in steep north or 

northeast facing drainages at middle elevations in the planning area. Soils are usually shallow, 

and the slopes are colder and moister than the surrounding habitat. Douglas-fir is found 

intermixed with limber pine, ponderosa pine, lodgepole pine, and quaking aspen. Numerous 

acres of Douglas-fir throughout the planning area are reported to be infested with western 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

3-43 Chapter 3: Affected Environment 

spruce budworm. Most infestation areas are in older stands, decadent stands, or both (Steinberg 

2002). 

Limber pine communities occupy warm and dry sites at low and middle elevations, primarily in 

the Pryor, Beartooth, and Absaroka mountain areas. Sparse pockets intermingled with 

shrublands are located throughout the entire southern portion of the planning area. Limber pine 

is often found intermingled with other pine species or shrubs, most commonly Douglas-fir and 

lodgepole pine at the higher elevations, and juniper and/or sagebrush at the lower elevations 

(Johnson 2001). 

Lodgepole pine communities in the planning area have three different ecological roles: (1) as a 

seral species to more shade tolerant tree species; (2) as a relatively stable co-dominant with one 

or more other species (persistent); and (3) as the only tree layer dominant (persistent). Found 

primarily in the Absaroka, Beartooth, and Pryor mountain areas, lodgepole pine grows with 

nearly all other mountain conifers in its range and often forms dense, nearly pure stands. Pure 

lodgepole pine stands frequently result after repeated fires and where there is no seed source for 

other species. In pure stands of lodgepole pine, there is seldom an understory of reproduction, 

though in low density stands there may be younger trees in the understory. 

Mixed stands of lodgepole pine and other species are also common; especially stands of 

lodgepole pine, Engelmann spruce, and subalpine fir at higher elevations, and stands of 

lodgepole pine and Douglas-fir and/or limber pine at mid to lower elevations. In mixed stands, 

the overstory may be either pure lodgepole pine or may contain a mix of the above-mentioned 

conifer species, with the more shade tolerant species in the understory. Lodgepole pine invades 

dry meadows and sites previously dominated by big sagebrush. However, lodgepole pine is 

primarily an aggressive pioneer on disturbed sites, with its occurrence due largely to fire. This 

is visible in the various successional stages of homogeneous stands throughout the Beartooth 

and Pryor mountain areas. In fire generated stands of similar age, trees become susceptible to 

mountain pine beetle attack at approximately the same time, resulting in large scale 

infestations. Where lodgepole pine is persistent, mountain pine beetle infests and kills most 

large lodgepole pine trees. The openings created by beetle attacked areas are seeded by 

lodgepole pine, and the cycle is repeated as other trees reach the size conducive to beetle 

populations. Mountain pine beetle and other non-fire disturbances thin the larger size classes. 

When combined with patchy fire spread, this complex disturbance regime results in multistoried, mosaic stands, consisting of different ages and size classes. The overall effect is 

chronic infestations of mountain pine beetle due to the constant food source (Anderson 2003). 

Subalpine fir communities exist at the higher elevations in wetter precipitation zones, generally 

occupying cold and higher mountain forests in the Absaroka, Beartooth, and Pryor mountain 

areas. Subalpine fir is a mid to upper elevation mountain conifer. It is generally found where 

there is a short growing season caused by cold winters, cool summers, frequent summer frosts, 

and heavy snowpack. It forms extensive forests between warm and dry lower elevation forests 

of Douglas-fir, lodgepole pine, or Engelmann spruce, and higher elevation alpine tundra. At 

lower elevations, subalpine fir is often restricted to stream bottoms, ravines, frosty basins, or 

northern exposures. In the Pryor Mountains, subalpine fir is commonly found intermingled with 

limber pine at mid to lower elevations. It increasingly occupies westerly and easterly aspects 

with increasing elevation and may occupy all aspects at upper timberline. Most subalpine fir 

stands throughout the planning area are in some stage of fir beetle and spruce budworm 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-44

infestation. Extended drought and decadent stands contribute to the insect proliferation. 

Numerous insects attack subalpine fir; the most destructive seems to be the western spruce 

budworm. Subalpine fir is one of the western spruce budworm’s most common hosts. This pest 

generally attacks low and middle elevation subalpine fir forests and is largely absent from high 

elevation forests. Other insect pests include the Douglas-fir tussock moth, western blackheaded budworm, and fir engraver beetle (Uchytil 1991). 

The interior ponderosa pine/bunchgrass community type is the most common vegetative 

community throughout the planning area. It is characterized by open grasslands interspersed 

with widely spaced trees. Under pristine conditions, the tree canopy usually covers no more 

than 25 percent of the forest floor. Stand structure in the planning area resembles open savanna 

at lower elevations and dense forest at higher elevations. In the central part of the planning 

area, the interior ponderosa pine type merges into plains grassland at lower elevations and 

limber pine at higher elevations. Limber pine, Douglas-fir, and Rocky Mountain juniper are 

common overstory associates. Interior ponderosa pine is one of the only forest trees in 

southeastern Montana and forms several diverse habitats. On dry sites, it supports an 

understory of plains grassland species. Understories are typically dense on wetter sites and 

include species characteristic of Pacific ponderosa pine forests to the west (Arno 1979). 

Cottonwood species communities are found in wetter drainage bottoms with the largest 

concentrations along the Yellowstone, Clarks Fork of the Yellowstone, Boulder, Bighorn, and 

Musselshell rivers. Many stands are mature or over-mature and in decline. Regeneration is poor 

and exacerbated by domestic animals, encroachment of noxious and undesirable species, and 

wildlife (Taylor 2001). 

Long-term fire suppression since the early 1900s has allowed forests and woodlands to become 

overstocked with dense fuels, such that wildfires often are more intense and severe than under 

historic fire regimes. In some cases, this results in widespread stand replacement and could 

result in vegetation type conversion, severe erosion, or the need for extensive restoration 

efforts, including tree planting. Juniper expansion into coniferous forests and quaking aspen 

stands affects the growth, reproduction, and overall health of these forests. Bartos and 

Campbell (1998) have estimated that 60% to 90% of quaking aspen stands in the western 

United States have been taken over by other species due to fire exclusion since European 

settlement. 

Plains island forests – refugia of trees and tree-dependent species isolated in a grassland matrix 

are at significant risk from climate changes because they are ecotone systems (borderline 

between grassland and forest ecosystems) and therefore sensitive to relatively small changes in 

environmental conditions. In addition, because island forests are relatively small ecosystems, 

they may exhibit reduced genetic diversity and greater vulnerability to catastrophic disturbance 

such as wildfire, pathogen attack, or severe drought (Henderson et al. 2002). 

Silvicultural treatments including harvest, thinning, other mechanical treatments, and 

prescribed fire would reduce conifer stocking levels and create openings of various sizes to 

stimulate the growth and development of forests and woodlands. Increasing growing space 

(e.g., sunlight, water, nutrients, etc.) is expected to maintain or enhance vegetative vigor; 

structure; density; and species composition, pattern, and distribution; which would promote 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

3-45 Chapter 3: Affected Environment 

forest resiliency and productivity and reduce the occurrence of catastrophic wildfire and forest 

insect and disease outbreaks. 

3.6.2 Rangelands and Shrublands 

Rangelands, the second most abundant vegetation cover type, covers approximately 142,556 

acres (32.8 percent) of the decision area. Rangeland communities range from subalpine 

meadows in annual average precipitation zones of 20 or more inches on top of the Pryor 

Mountains to Red Desert saltbush communities receiving less than nine inches as observed in 

southern Carbon County. Vegetation composition and structure varies between and within 

types due to local factors including soils, aspect, precipitation, elevation, slope, and ecological 

condition. Fifteen cover types are identified in the decision area. Of the fifteen cover types 

identified approximately 96% of the acreage occurs within five cover types. These cover types 

are listed in Table 3-15. 

Table 3-15 Rangeland Cover Types

Note: 

Source: NatureServe 2008, LANDFIRE National Existing Vegetation Type Layer 2006. 

1. Ecological System and Community Name derived from Landfire Existing Vegetation Layer 2006. These 

Vegetation types are not referenced in NatureServe 2008. Predominant characteristic species were 

derived from Ecological Site Descriptions, and local knowledge. 

The Northwestern Great Plains Mixedgrass Prairie occurs in all counties within the decision 

area. This system occurs on 110,347 acres (25.4 percent) of the decision area and is the most 

abundant rangeland system in the decision area. This ecological system is found on both 

glaciated and non-glaciated substrate. This system occurs on fine and medium textured soils. 

This system is similar to the Western Great Plains Sand Prairie which occurs on courser 

textured soils. Common vegetation found in this system in Montana includes: western 

wheatgrass (Pascopyrum smithii), green needlegrass (Nassella viridula), needle-and-thread 

Rangeland Cover Types

Rangeland Ecological 

System and Community 

Name

Total vegetation 

cover in Decision 

Area (Percent)

Rangeland cover in 

Decision Area 

(Percent)

Total 

Acreage

Predominant Characteristic 

Species

Northwestern Great Plains 

Mixedgrass Prairie 25.4 77.4% 110,347

Green needlegrass, western 

wheatgrass, needle-and-thread, 

prairie junegrass, threadleaf 

sedge

1

Introduced Upland 

Vegetation-Annual and 

Biennial Forbland

2.8% 8.7% 12,454 Crested Wheatgrass, alfalfa, 

sweet clover

Northern Rocky Mountain 

Lower Montane-FoothillValley Grassland1.14% 4.2 5,954 Bluebunch wheatgrass, Idaho 

Fescue, rough Fescue

Western Great Plains 

Sand Prairie 1.1 3.2% 4,590

Blue grama, needle-and-thread, 

little bluestem

Inter-Mountain Basins 

Semi-Desert Grassland 0.8% 2.67% 3,815

Needle-and- thread, bluebunch 

wheatgrass, Sandberg 

bluegrass

Other 1.2% 3.78% 5,396 N/A

Total 32.44% 99.95% 142,556 N/A
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-46

(Hesperostipa comata), prairie junegrass (Koeleria macrantha), and threadleaf sedge (Carex 

filifolia). Communities within this system adjacent to the Northern Rocky Mountain Lower 

Montane Foothills Valley Grassland system may begin to pick up Idaho Fescue (Festuca 

idahoensis). 

The Introduced Upland Vegetation-Annual and Biennial Forbland system is common in 

Carbon, Musselshell, and Yellowstone Counties. This system occurs on approximately 12,500 

acres or (2.8 percent) of the decision area. These systems typically occur on lands that have 

been degraded due to past management practices, such as grazing or agriculture. Common 

species on these lands include crested wheatgrass (Agropyron cristatum), dryland alfalfa 

(Medicago ssp.), sweet clover (Melilotus ssp.), and milkvetch species (Astragalus ssp.). 

The Northern Rocky Mountain Lower Montane-Foothill-Valley Grassland system is located in 

Carbon, Stillwater, Sweet Grass, Golden Valley, and Wheatland Counties. This system occurs 

on approximately 6,000 acres or (1.14 percent) of the decision area. This system is found at 

foothill elevations of the Beartooth, Absaroka, Pryor, Crazy, Little Belt, and Big Snowy 

mountain ranges. This system often is adjacent to the Northwestern Great Plains Mixedgrass 

Prairie System which typically occurs at lower elevations. This system is commonly found on 

relatively deep, fine textured soils, often with course fragments. Common vegetation within 

this system includes: bluebunch wheatgrass (Pseudoroegneria spicata), Idaho fescue, rough 

fescue (Festuca campestris), and needle-and-thread. 

The Western Great Plains Sand Prairie system is similar to the Northwestern Great Plains 

Mixed Grass Prairie, which can surround the Western Great Plains Sand Prairie system. Soils 

separate the two systems, as the Western Great Plains Sand prairie system occurs on courser 

soils with a sand influence, while the Northwestern Great Plains Mixed Grass Prairie occurs on 

fine to medium textured soils. Weathered in place sandstone typically provides the substrate 

needed for this system to occur in Montana. This system occurs on approximately 4,500 acres 

or (1.1 percent) of the decision area. In the decision area, this system is occurs in eastern 

Carbon and southern and south eastern Yellowstone Counties. In these counties the common 

species found within this system include: prairie sandreed (Calamovilfa longifolia), little 

bluestem (Schizachyrium scoparium), and needle-and thread. 

The Inter-Mountain Basins Semi-Desert Grassland within the decision area is found in the 

northern portions of the bighorn basin which occurs in southern Carbon County. This system 

occurs on approximately 3,800 acres or (0.8 percent) of the decision area. This system is found 

on a variety of landforms in the area and may constitute a mosaic within shrubland systems. In 

Montana, this system is dominated by bluebunch wheatgrass and Sandberg bluegrass (Poa 

secunda). Other common herbaceous species in this system include indian ricegrass 

(Achnatherum hymenoides), blue grama (Bouteloua gracilis), and needle-and-thread. 

Shrublands, the most abundant cover type in the decision area, compose approximately 243,653 

acres within the decision area. This represents approximately 56.1 percent of the area. Of the 

19 cover types identified, approximately 97% of the decision area occurs within five cover 

types. These cover types are listed in Table 3-16. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

3-47 Chapter 3: Affected Environment 

Table 3-16 Shrubland Cover Types

Note: 

Source: NatureServe 2008, LANDFIRE National Existing Vegetation Type Layer 2006. 

The Inter-Mountain Basins Big Sagebrush shrubland is the most dominant cover type in the 

decision area. This cover type is found on approximately 142,500 acres (32.8 percent) of the 

decision area. This system is found throughout most of Carbon County, and eastern 

Musselshell and Yellowstone Counties. This system is typically found in broad basins between 

mountain ranges, plains, and foothills. Soils are typically deep and well drained. Dominant 

shrub species in this system includes Wyoming big sagebrush (Artemisia tridentata ssp. 

Wyomingensis), rubber rabbitbrush (Ericameria nauseosa), and green rabbitbrush

(Chrysothamnus viscidiflorus). Common understory vegetation includes: indian ricegrass, blue 

grama, Sandberg bluegrass, and bluebunch wheatgrass. 

The Inter-Mountain basins Big Sagebrush Steppe system occurs on approximately 65,000 acres 

(15 percent) of the decisions areas. This system occurs in Carbon, Musselshell and Yellowstone 

Counties. This system is similar to the Inter-Mountain Basins Big Sagebrush Shrubland 

system; however shrub diversity is typically lower in the steppe system. This system is 

typically dominated by Wyoming big sagebrush, with western wheatgrass, indian ricegrass, 

needle-and-thread, green needlegrass, and bluebunch wheatgrass common herbaceous 

understory vegetation. 

The Inter-Mountain Basins Montane Sagebrush Steppe occurs on approximately 17,000 acres 

(4 percent) of the decision area. This system is found in Carbon, Golden Valley, Stillwater, 

Sweet Grass, and Wheatland Counties. This system occurs at foothill elevations of the 

Absaroka, Beartooth, Crazy, Little Belt, Pryor, and Big Snowy Mountains. This system is 

Shrubland Cover Types

Shrubland Ecological 

System and Community 

Name

Total vegetation 

cover in Decision 

Area (Percent)

Rangeland cover in 

Decision Area 

(Percent)

Total 

Acreage

Predominant Characteristic 

Species

Inter-Mountain Basins Big 

Sagebrush Shrubland 32.8% 58.5% 142,549

Wyoming big sagebrush, rabbit 

brush, saltbush, needle-andthread, bluebunch wheatgrass

Inter-Mountain Basins Big 

Sagebrush Steppe 15% 26.6% 64,892

Wyoming big sagebrush, western 

wheatgrass, indian ricegrass, 

needle-and-thread

Inter-Mountain Basins 

Montane Sagebrush 

Steppe 3.96% 7% 17,204

Mountain big sagebrush, 

snowberry, timber oatgrass, Idaho 

fescue, muttongrass, Sandberg 

bluegrass, bluebunch wheatgrass

Inter-Mountain Basins 

Curl-leaf Mountain 

Mahogany Woodland and 

Shrubland

1.3% 2.6% 5,757

Curl leaf mountain mahogany, 

mountain big sagebrush, Idaho 

fescue, bluebunch wheatgrass

Wyoming Basins Dwarf 

Sagebrush Shrubland and 

Steppe 1.15% 2% 5,012

Birdsfoot, black, dwarf, and 

Wyoming sage brush species, 

blue grama, Idaho fescue, 

bluebunch wheatgrass

Other 1.89% 3.3% 8,239 N/A

Total 56.1% 100% 243,653
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-48

found on mesic sites with gentle topography and fine soils. The dominant shrub in this system 

is mountain big sagebrush (Artemisia tridentata ssp. Vaseyana); other shrub species include 

snowberry (Symphoricarpos spp.) rubber rabbitbrush, green rabbitbrush, and Wyoming big 

sagebrush. Common understory vegetation includes timber oatgrass (Danthonia intermedia), 

Idaho fescue, muttongrass (Poa fendleriana), Sandberg bluegrass, and bluebunch wheatgrass. 

The Inter-Mountain Basins Curl-Leaf Mountain Mahogany Woodland and Shrubland System 

occurs on approximately 5,800 acres or (1.3 percent) of the decision area. This system is found 

predominantly in Carbon County in the foothills of the Pryor Mountains. This system is 

typically found in small stands on ridges and steep rimrock slopes. This system is dominated by 

curl leaf mountain mahogany (Cercocarpus ledifolius) and mountain big sagebrush. 

Understory vegetation is typically sparse and includes bluebunch wheatgrass and Idaho fescue. 

The Wyoming Basins Dwarf Sagebrush Shrubland and Steppe system occurs on approximately 

5,000 acres (1.1 percent) of the decision area. This system is found predominantly in southern 

Carbon County. This system is occurs on gently rolling hills to long gentle slopes. Sites are 

typically very windy with shallow rocky soils. Short shrubs distinguish this system and 

contribute at least 66% of the canopy cover. Common shrub species include birdsfoot 

sagebrush (Artemisia tripartita), black sagebrush (Artemisia nova), and wind dwarfed 

Wyoming big sagebrush. 

Ecological site descriptions (ESDs) are available for most of the locations within the decision 

area. These ESDs describe the expected soils and vegetation characteristics that should be 

found on individual sites, as well as the transitional pathways a community may experience due 

to disturbance and management practices. Information contained in the ESDs has been used 

extensively in local planning efforts, including Allotment Management Plans. 

Rangeland communities range from subalpine meadows in annual average precipitation zones 

of 20 or more inches on top of the Pryor Mountains to Red Desert saltbush communities 

receiving less than nine inches, as observed in southern Carbon County. Vegetation 

composition and structure varies between and within types due to local factors including soils, 

aspect, precipitation, elevation, slope, and ecological condition. Loehman (2009) found that

“Climate changes in the Prairie Potholes and Grasslands bioregion include increased seasonal, 

annual, minimum, and maximum temperature and changing precipitation patterns.”

Vegetation can be grouped into three broad geographic zones in the decision area: Eastern 

Sedimentary Plains, Western Sedimentary Plains, and Foothills and Mountains (Map 9 –

Vegetative Map). The Eastern Sedimentary Plains zone encompasses the area between the 

Musselshell and Yellowstone rivers and east of U.S. Highway 87. This area includes 

approximately 110,000 acres of public land and is in the 10 to14 inch precipitation zone. This is 

primarily a sagebrush/grassland vegetative type consisting of big sagebrush, bunch grasses, and 

western wheatgrass. A ponderosa pine/grassland type is also included in this zone. 

The Western Sedimentary Plains zone includes a variety of vegetative types. This zone takes in 

essentially all of northern Musselshell, Golden Valley, Wheatland, and western Yellowstone 

counties, those portions of Stillwater and Sweet Grass counties north of the Yellowstone River, 

and the Clarks Fork valley and triangle area in Carbon County. Precipitation ranges from five 

to 20 inches. Collectively, this zone encompasses approximately 260,000 acres of public land. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

3-49 Chapter 3: Affected Environment 

Vegetation consists primarily of sagebrush/grassland and grassland types, though it does 

include the red desert/saltbush type on the Wyoming border in southern Carbon County, as well 

as some areas of ponderosa pine/grassland type vegetation. 

The remaining 55,000 acres of public land are located in the Foothills and Mountain zone. This 

zone includes the Pryor Mountains, the north face of the Beartooth Mountains, and the south 

face of the Big Snowy Mountains. 

The Natural Resource Conservation Service (NRCS) developed site-specific “Technical Range 

Site Guides” that apply to each of the broad regions. The guides describe the expected soil and 

vegetative characteristics that should be found on individual range sites and the expected 

departure in condition with respect to varying degrees of management. Information contained 

in the guides has been used extensively in local planning efforts, including Allotment 

Management Plans. 

In August 1997, the Montana/Dakotas Standards for Rangeland Health and Guidelines for 

Livestock Grazing (S&Gs) became effective for all BLM lands in Montana and the Dakotas. 

Standards describe the conditions needed to sustain public land health and apply to all uses of 

public lands. Rangeland health is the minimum ecological standard, independent of how a 

rangeland is used or managed. If rangeland health is protected, a variety of uses could be 

appropriate for any particular rangeland. Standards apply to rangeland health and not to the 

important byproducts of healthy rangelands such as more fish, higher livestock weaning 

weights, regional social and cultural values, increased timber production, economic viability of 

livestock operations, or higher numbers of game animals. The sustainability of the rangeland 

health processes produces these social values and commodities. 

The S&Gs are intended to maintain healthy and productive public rangelands essential to 

support long term grazing and stable communities that rely on the land. Standards are 

measurable levels of resource quality, condition, or function upon which management decisions 

are based. It is the BLM’s policy to achieve rangeland health standards through management of 

existing uses when feasible. Standards provide the technical and scientific basis for measuring 

progress towards healthy, productive rangelands. Standards are not expected to recreate 

theoretical “pristine” rangeland conditions that may have existed before livestock grazing 

began. It is assumed most areas will be grazed unless there is no way to graze them and still 

achieve standards or that the area is dedicated to other uses such as campgrounds, mining, and 

cultural/historical sites, such as Pompeys Pillar. Refer to Appendix I – Land Health Standards 

outlining the standards conformance review determinations for each allotment in the decision 

area. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-50

Table 3-17 Rangeland Conditions 

Rangelands 

meeting all 

Standards

Rangelands 

making significant 

progress toward 

meeting

Standards

Rangelands not 

meeting Standards, 

but changes have 

been made

Rangelands not 

meeting Standards 

and no changes 

have been made

Rangelands not 

meeting Standards 

due to causes other 

than livestock

grazing

No Assessment 

Completed

Allotments Acres* Allotments Acres* Allotments Acres Allotment Acres* Allotments Acres* Allotments Acres*

309 309,658 34 41,153 8 3,675 1 80 2 80 16 6,835

Figures listed below represent Land Health Standards for lands/allotments located within Priority Sage-grouse habitat

85 194,762 12 33,251 2 1,501 0 0 0 0 3 1,135

Note: 

Source: 2012 year end rangeland monitoring report. 

* Due to acreage accounting differences in the PMWHR, the administrative pastures are double counted as an allotment and 

as part of the HMA. 

At a minimum, state or regional standards must address the following: watershed function; 

nutrient cycling and energy flow; water quality; habitat for endangered, threatened, proposed, 

Candidate 1 or 2 or special status species; and habitat quality for native plant and animal 

populations and communities. 

3.6.3 Riparian and Wetlands 

Riparian/wetlands were analyzed through the LANDFIRE database, delineating this 

community in some 14,966 acres (3.5 percent) of the decision area. The riparian zone is a 

minor community in the decision area; however its importance to water quality and wildlife 

habitat is widely recognized. Riparian zones are defined as “a form of wetland transition 

between permanently saturated wetlands and upland areas.” These areas exhibit vegetation or 

physical characteristics reflective of permanent surface or subsurface water. Lands along, 

adjacent to, or contiguous with perennially flowing rivers and streams, wetlands, glacial 

potholes, and shores of lakes and reservoirs with stable water levels, are typical riparian areas. 

Ephemeral streams or washes that do not exhibit the presence of vegetation dependent upon 

free water in the soil are excluded (BLM Manual 1737). 

Wetlands are defined as “areas that are inundated or saturated by surface or groundwater at a 

frequency and duration sufficient to support, under normal circumstances, a prevalence of 

vegetation typically adapted for life in saturated soil conditions.” Wetlands include marshes, 

shallows, swamps, lakeshores, bogs, muskegs, wet meadows, estuaries, and riparian areas 

(BLM Manual 1737). These areas provide a wide range of functions critical to many different 

wildlife species, water quality, scenery, and recreation (Brimson 2001). 

Jurisdictional wetlands, those regulated by the US Army Corps of Engineers (USACE) under 

Section 404 of the Clean Water Act (CWA), must exhibit all three of the following 

characteristics: hydrology, hydrophytic vegetation, and hydric soils (USACE 1987). It is 

important to note that some areas function as wetlands ecologically, but exhibit only one or two 

of the three characteristics. Consequently, they do not currently qualify as USACE 

jurisdictional wetlands, and activities there are not regulated under the Section 404 program. 

These wetlands still perform valuable functions. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

3-51 Chapter 3: Affected Environment 

Riparian diversity in the decision area is extensive, ranging from subalpine to prairie and desert 

community types. Herbaceous and woody species common to riparian areas vary widely from 

site to site. Riparian communities along the larger perennial drainages are often dominated by 

cottonwood (Populus spp.) and willow (Salix spp.) with occasional stands of box elder (Acer 

negundo) and green ash (Fraxinus pennsylvanica). In mountain streams, riparian communities 

are dominated by willow, water birch (Betula occidentalis), red osier dogwood (Cornus 

sericea), cottonwood, and conifers such as Douglas-fir and lodgepole pine. The understory 

often consists of woody plants such as buffaloberry (Shepherdia spp.), snowberry 

(Symphoricarpos spp.), Woods’ rose (Rosa woodsii), and grasses and forbs. 

In the southern portion of the decision area, there is a small desert region that receives an 

average of five inches of precipitation a year. However, several springs and intermittent 

streams in this area support a lush riparian zone. These narrow bands of lush vegetation and 

free water are invaluable to wildlife in the area, and this elevates the value of the riparian area. 

Along many of the prairie and desert streams, infestation of plants such as Russian olive and 

salt cedar is prevalent. Control of these invasive species is difficult since riparian segments on 

public land are limited and fragmented. To effectively remove Russian olive (Elaeagnus 

angustifolia) and salt cedar (Tamarix ramosissima) from a riparian zone, it would be critical to 

manage/treat all adjacent areas, upstream and down, to control seed dispersal. 

The ongoing drought, which started in 1997 (NOAA, NCDC), has resulted in new ephemeral 

streams that do not support riparian communities. Range and riparian surveys and observations 

have recorded perennial wetlands in pre drought conditions; however, the areas have since 

become dry washes that do not support riparian communities or diversity has diminished to a 

single hardy obligate species. 

Climate factors can have a significant effect on the health and vigor of many wetlands. 

“Because wetlands exist in the transition zone between aquatic and terrestrial 

environments, they are vulnerable to changes in the surface and ground water 

hydrology. These hydrologic shifts may push wetland species beyond their limits 

of adaption and tolerance. Wetlands that depend upon precipitation as their 

primary water source are the most vulnerable to climate variation and change.”

(Burkett and Kusler 2000).

Information on the condition of riparian areas and wetlands is available from proper 

functioning condition (PFC) assessments conducted from 1989 to the present (available at the 

BiFO). All riparian habitats are dependent on a balanced combination of physical (stream bank, 

channel, and soil characteristics), hydrologic (regular occurrence of surface water), and 

vegetation (hydrophytic communities) components. When any of these three components (soil, 

water, and vegetation) are negatively affected, the functional capacity of a riparian habitat may 

be degraded. A PFC assessment evaluates these components then rates the riparian area as 

either: PFC; Functioning at Risk, Upward Trend (FAR-U); Functioning at Risk, Trend Not 

Apparent (FAR-NA); Functioning at Risk, Downward Trend (FAR-D); and Non-Functional 

(NF). 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-52

Since the purpose of the PFC assessment is to evaluate most of the indicators for land health 

Standard 2, the functional rating (PFC, FAR, NF) for each riparian area determines whether the 

standard is being achieved. A PFC rating means most or all the indicators in the system’s 

potential have been met, and therefore Standard 2 has been achieved. A FAR-U rating 

generally means that several indicators have not been met but that significant progress is being 

made toward achieving them. A FAR-D or FAR-NA rating means several indicators have not 

been met and generally, Standard 2 is not achieved. Similarly, an NF rating means critical 

indicators have not been met and, consequently, Standard 2 is not achieved. 

For swift flowing (lotic) systems, a riparian/wetland area is considered to be in PFC when 

adequate vegetation, landform, or large woody debris is present to accomplish the following: 

 Dissipate stream energy associated with high water flow, 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 stream banks against cutting action 

 Develop diverse ponding and channel characteristics to provide habitat and 

water depth, duration, and temperature necessary for fish production, waterfowl 

breeding, and other uses 

 Support greater biodiversity (Technical Reference BLM-RS-ST-99-001+1737) 

For still or slow flowing (lentic) systems, riparian wetland areas are functioning properly when 

adequate vegetation, landform, or debris is present to accomplish the following: 

 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 floodwater retention and groundwater recharge 

 Develop root masses that stabilize islands and shoreline features against cutting 

action 

 Restrict water percolation 

 Develop diverse ponding characteristics to provide habitat and water depth, 

duration, and temperature necessary for fish production, waterfowl breeding, 

and other uses 

 Support greater biodiversity (Technical Reference BLM-RS-ST-99-001-1737) 

Each riparian/wetland area is judged against its capability and potential (Technical Reference 

BLM-RS-ST-98-001-1737). 

The decision area contains limited lentic riparian habitat. The extended drought, coupled with 

soil and geographic characteristics, has created minimal ponding features, and many reservoir 

attempts in the decision area have failed. Lentic areas that do exist are closed systems with high 

alkaline constituent, limiting riparian obligates to a few species that can adapt to such 

conditions. These communities offer little beneficial riparian wildlife habitat. Due to the limited 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

3-53 Chapter 3: Affected Environment 

number of lentic areas and loss of climatic moisture from the drought, many of these areas have 

not been inventoried. Additional inventories may provide additional information about the 

lentic status in the decision area. 

The most recent results of the PFC assessments are identified in Table 3-18 and Table 3-19,

and illustrated in Map 10 (Riparian Properly Functioning Condition Surveys).

It is difficult to directly correlate changes in lotic and lentic riparian condition over the years. 

As streams and wetlands are inventoried and assessed, stream miles and wetland acres are 

sometimes added or removed from the inventory. Using geographic positioning system (GPS) 

technology makes accurate measurements easier, allowing for a higher standard of data and 

repeatability. 

Table 3-18 2010 Functional Condition of Lotic Systems by County (miles) 

County

Proper Functioning 

Condition

Functioning at 

Risk Non-Functioning Unknown

Big Horn 0.0 0.2 0.1 0.3

Carbon 19.2 19.5 7.8 8.0

Golden Valley 0.0 0.6 0.0 0.0

Musselshell 4.3 17.6 3.5 0.0

Stillwater 6.0 0.3 1.4 1.8

Sweet Grass 0.8 0.5 0.3 3.8

Wheatland 0.0 0.3 0.0 0.5

Yellowstone 10.9 28.5 7.0 0.4

All Counties Total 58.5 67.5 8.0 12

Percentages 40 46 6 8

Note: 

Source: BLM Internal Records – PFC Data 

Table 3-19 Functional Condition of Lentic Systems by County 

County

Acres of 

Riparian Wetland Name Type

Assessment 

Date PFC

Musselshell 1.0 Devils Basin Playa 9/2008 FAR-U

Musselshell 2.0 Willow Reservoir Reservoir 8/2008 FAR-U

Musselshell 1.3 Donaldson Reservoir Reservoir 5/2010 FAR-U

Stillwater 1.0 Big Lake Lake N/A Not surveyed

Carbon 0.5 Sage Creek Reservoir 8/2008 PFC

Sweet Grass 3.0 Reed Point Playa 8/2008 PFC

Note: 

Source: BLM Internal Records – PFC Data 

The Table 3-18 indicates approximately 50 percent of the riparian areas in the decision area are 

functioning at risk. Decision-area-wide, the primary stressors that contribute to the FAR rating 
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Chapter 3: Affected Environment 3-54

include: invasive and non-native vegetative infestations, bank alteration from livestock grazing, 

channel instability (both vertical and lateral), and lack of riparian obligate recruitment and 

riparian vigor. FAR ratings determined in the last decade, give or take a few years, may be 

attributed to climatic conditions (drought) that have stressed riparian systems throughout the 

decision area. These conditions are difficult to manage for, as they are relatively unpredictable. 

Livestock grazing systems that have succeeded in maintaining PFC in many areas pre-drought 

can have negative impacts on these systems during the drought (reduced vegetative cover, 

recruitment and vigor, and stream bank alteration). Trying to manage grazing impacts in 

response to drought conditions is challenging and can involve building fences and developing 

water sources to keep livestock out of riparian areas. 

The Clean Water Act requires a list of water bodies that do not fully support beneficial uses 

such as aquatic life, fisheries, drinking water, recreation, industry, or agriculture. These 

inventories are known as 303(d) lists and characterize waters as fully supporting, impaired, or 

in some cases threatened for beneficial uses. The decision area has 14 segments of stream, 

river, or lake shore listed as impaired on the DEQ’s 303(d) list. Riparian degradation can lead 

to water quality impairment. Table 3-20 lists those waters with riparian degradation as one of 

several causal factors by the MT DEQ. It is important to note that this riparian degradation is 

not necessarily found on BLM managed lands, as the stream segments generally cover many 

miles while BLM may only manage as little as 0.25 miles of the stream. 

Table 3-20 DEQ Impaired Waters List in the Planning Area 

Impaired Water Bodies by 4th Level Hydrologic Unit Code (from 2010 Montana 303(d)/ 305(b) Intergraded Report)

4th Hydrologic Unit Code 

Name

Stream Segment on 

BLM Land

Estimated 

Miles on BLM 

Land

Probable Impairment 

Type(s)A

Probable Impairment 

Source(s)B

Stillwater River Stillwater 0.3 1, 4, 14 5, 9, 12, 14, 15 

Bad Canyon 4.82 12 2

Clarks Fork of the 

Yellowstone

Clarks Fork 2.2 1, 3, 4, 9, 10, 12, 13 3, 4, 12,13

Silvertip 11.6 1, 2, 3, 5, 6, 7, 8, 9, 10, 11 1, 2, 6, 7, 8, 9, 10, 11 

SF Bridger 6.3 3, 16 8, 9, 12

Bear 0.7 1, 2, 3, 4, 12 1, 2, 3, 4, 5 

Blue Water 0.1 3, 8, 12 2, 3 , 4, 16, 18

Cottonwood 0.75 2, 5, 8 1, 2, 8, 9, 18

Upper Yellowstone Yellowstone 8.1 1, 3, 8 3, 9, 10, 16, 17, 

Boulder 0.16 1,2,4, 2,3,12

Big Lake .25 8 18

Middle Yellowstone Yellowstone 11.5 1,8,12,16 9,11,17,18

Big Horn Lake Crooked 3.2 13 18

Middle Musselshell Musselshell 0.9 2, 10, 13 4, 6, 13, 18

North Willow 4.75 1, 3, 4, 6, 15, 9, 11, 12 

Total 55.63
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3-55 Chapter 3: Affected Environment 

Impaired Water Bodies by 4th Level Hydrologic Unit Code (from 2010 Montana 303(d)/ 305(b) Intergraded Report)

4th Hydrologic Unit Code 

Name

Stream Segment on 

BLM Land

Estimated 

Miles on BLM 

Land

Probable Impairment 

Type(s)A

Probable Impairment 

Source(s)B

A Cause: 1=Nutrients, 2=Alteration of Streamside Vegetation, 3=Sediment, 4=Metals, 5=Oxygen Depletion, 6=Specific Conductance, 

7=Turbidity, 8=Total Dissolved Solids, 9=Temperature, 10=Flow Alterations, 11=Toxic Organics, 12=Harmful Algae, 13=Habitat Alterations, 

14=Cyanide, 15=Sulfates, 16=Arsenic

B Source: 1=Loss of Riparian Habitat, 2=Rangeland Grazing; 3=Irrigated Crop Production; 4= Hydrologic Modification, 5=AML, 

6=Channelization, 7=Impoundments, 8=Riparian Grazing, 9=Natural, 10=Industrial Permitted, 11=Spills, 12=Unknown, 13=Streambank 

modification, 14=Hard rock Mining, 15=Post Fire Runoff , 16=Feedlots, 17=Municipal Discharge, 18=Agriculture

Best management practices, state (MT DEQ), and federal guidance set the foundation for BLM 

management of aquatic resources through sound riparian habitat and water quality 

management. A clear establishment of the importance of riparian health is critical in 

understanding the connectivity between riparian vegetation, water quality and quantity and 

aquatic resources. The following guidance, as well as the use of BMPs sets the foundation for 

BLM management of aquatic resources through sound habitat and water quality management. 

3.6.4 Urban and Agricultural Lands 

The urban land use and agricultural cover types comprise approximately 8,550 acres (2 percent) 

of the decision area. This area is covered by 30 percent or more of non-native species, 

including introduced and noxious weed species. Total vegetation cover ranges from 20 to 

80 percent. Crested wheatgrass (Agropyron cristatum) and yellow sweet clover (Melilotus 

officinalis) are introduced species that have been used widely for rangeland pasture 

improvement. Such habitats are often used for early season livestock grazing. Urban areas are 

often dominated by bare ground and have been disturbed or altered by human use including 

irrigated and dryland crops, surface mining operations, and human settlements. 

3.6.5 Invasive Species and Noxious Weeds 

Noxious weeds, designated by Montana state law and county weed boards, are exotic plant 

species that may harm native plant communities. Most invasive plant species currently known 

to occur in south central Montana were originally introduced to North America from Europe 

and Asia (Sheley and Petroff 1999). Introductions were both intentional for various reasons or 

unintentionally brought in as contaminants of feed, seed, and ship ballast. Once established, 

these plants spread rapidly by natural (wind, water, and wildlife) and artificial (roads, 

equipment, and movement of contaminated feed and seed) means. These plants generally 

invade disturbed soils and stressed plant communities. Once established, many invade healthy 

plant communities and alter healthy plant systems. These aggressive invaders decrease wildlife 

habitat value, reduce livestock range productivity, and increase land management costs. 

Noxious and invasive species move across jurisdictional boundaries and property lines; 

therefore, coordination and partnerships with local, state, tribal governments, and other federal 

agencies, as well as with interested organizations and individuals, is a critical management 

component. Noxious and invasive plant species in the planning area are currently managed 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-56

using an integrated weed management (IWM) approach. This approach includes prevention, 

early detection and rapid response strategies; and priority inventory and treatment areas. 

Management of vegetation for resources and habitat enhancement is accomplished with a 

variety of treatment methods, including, but not limited to: herbicides, prescribed fire, manual 

and mechanical methods, and biological controls (insects, pathogens, and domestic grazing 

animals). 

The BiFO cooperates with county weed boards in Yellowstone, Musselshell, Carbon, Stillwater 

and Sweet Grass counties through assistance agreements and Cooperative Weed Management 

Areas (WMAs) for noxious weed management and control. The purpose of creating WMAs is 

to facilitate cooperation among all land managers and land owners to manage a common 

problem in common areas. 

The formation of a WMA replaces jurisdictional boundaries that are barriers to weed 

management programs in favor of more logical boundaries that facilitate weed management 

and control. The advantages include, but are not limited to, establishing common priorities, 

channeled communication, and shared (and more secure) funding. 

The Billings Field Office is currently a member of ten WMAs throughout the planning area. 

Cooperators include: USDA – USFS, USDA - NRCS, Montana Fish, Wildlife, and Parks, 

Montana Department of State Lands, county governments and weed boards, local land owners 

and land owner organizations. 

Golden Valley and Wheatland counties do not have a weed board or a county weed department. 

Cooperation with the counties involves providing BLM funding to map, treat, and monitor 

noxious/invasive species; data and information exchange; and providing education to the 

general public. 

Noxious plant lists are established on federal, state, and county levels. Table 3-21 outlines all 

noxious and invasive weed species currently designated by the State of Montana, the Noxious 

Weed Control Act and Administrative Rules of Montana (maintained as a county designation). 

The County Noxious Weed Control Act and Administrative Rules of Montana declare that each 

county is allowed to designate plant species as “noxious.” The purpose of this list is to gather 

more information on potentially problematic weed species and monitor for occurrence or 

spread. Although there is no regulatory aspect to the list, information collected may be used to 

justify future inclusion on the state noxious weed list. BLM is currently building a national 

mapping database, NISIMS, which will be an information management system that would be 

used to track the mapping, treatment, and monitoring of invasive species (Map 13). 

The State of Montana lists and prioritizes 34 state-designated noxious weeds based on the 

following prioritization: 

 Priority 1A (1 species) – These weeds are not present in Montana. Management 

criteria will require eradication if detected, education, and prevention. 

► Yellow starthistle (Centaurea solstitialis) 

 Priority 1B (8 species) – These weeds have limited presence in Montana. 

Management criteria will require eradication or containment and education. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

3-57 Chapter 3: Affected Environment 

► Dyer’s woad (Isatis tinctoria) 

► Flowering rush (Butomus umbellatus) 

► Japanese knotweed complex (Polygonum spp.) 

► Purple loosestrife (Lythrum spp.) 

► Rush skeletonweed (Chondrilla juncea) 

► Eurasian water milfoil (Myriophyllum spicatum) 

► Scotch broom (Cytisus scoparius) 

► Curlyleaf pondweed (Potamageton crispus) 

 Priority 2A (8 Species) – These weeds are common in isolated areas of 

Montana. Management criteria will require eradication or containment where 

less abundant. Management shall be prioritized by local weed districts.

► Tansy ragwort (Senecio jacobea) 

► Meadow hawkweed complex (Hieracium spp.) 

► Orange hawkweed (Hieracium aurantiacum) 

► Tall buttercup (Ranunculus acris) 

► Perennial pepperweed (Lepidium latifolium) 

► Yellowflag iris (Iris pseudacorus) 

► Blueweed (Echium vulgare) 

► Hoary alyssum (Berteroa incana) 

 Priority 2B (16 Species) – These weeds are abundant in Montana and 

widespread in many counties. Management criteria will require eradication or 

containment where less abundant. Management is prioritized by local weed 

districts.

► Canada thistle (Cirsium arvense) 

► Field bindweed (Convolvulus arvensis) 

► Leafy spurge (Euphorbia esula) 

► Whitetop (hoary cress; Cardaria draba) 

► Russian knapweed (Centaurea repens) 

► Spotted knapweed (Centauria stoebe or maculosa) 

► Diffuse knapweed (Centaurea diffusa) 

► Dalmatian toadflax (Linaria dalmatica) 

► St. John’s Wort (Hypericum perforatum) 

► Sulfur cinquefoil (Potentilla recta) 

► Common tansy (Tanacetum vulgare) 

► Oxeye daisy (Chrysanthemum leucanthemum or Leucanthemum vulgare) 

► Houndstongue (Cynoglossum officinale) 

► Yellow toadflax (Linaria vulgaris) 
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Chapter 3: Affected Environment 3-58

► Saltcedar (Tamarix spp.)

 Priority 3 (2 Species) – These weeds are regulated plants, not Montana listed 

noxious weeds. These regulated plants have the potential to have significant 

negative impacts. The plant may not be intentionally spread or sold other than as 

a contaminant in agricultural products. The state recommends research, 

education, and prevention to minimize the spread of the regulated plant. 

► Cheatgrass (Bromus tectorum) 

► Hydrilla (Hydrilla verticillata) 

Russian olive (Elaeagnus angustifolia) is not listed as a state/county noxious weed species or a 

regulated plant; however, the BiFO is applying integrated weed management to this species. 

Russian olive is invasive in riparian areas due to high seed production and viability, seed 

longevity, seed dispersal by birds and mammals, vegetation reproduction following injury, 

drought and salt tolerance, and the ability to establish in the absence of disturbance in late 

successional communities. The Salt Cedar and Russian Olive Control Demonstration Act was 

signed into public law on October 11, 2006 for funding to assess extent of species infestation, 

demonstrate long term management, and assess economic means to dispose of biomass created 

when removing salt cedar and Russian olive. Russian olive site inventory is currently in 

process, and some management of these species is being conducted. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-59

Table 3-21 Noxious and Invasive Weed Species by County 

Common Name Scientific Name

County Species Designations1

BLM Acre 

Class Montana 2. 3

Big Horn 

County, MT

Carbon 

County

Musselshell 

County

Stillwater 

County

Sweet Grass 

County

Yellowstone 

County

Common burdock Arctium minus N/A x N/A N/A x N/A N/A Low

Absinth wormwood Artemisia absinthium N/A N/A x N/A N/A N/A N/A Low

Hoary alyssum Berteroa incana x (Priority 2A) N/A x N/A N/A N/A x Rare

Flowering rush Butomus umbellatus x (Priority 1B) N/A N/A N/A N/A N/A N/A None

Whitetop or hoary 

cress

Cardaria draba x (Priority 2B) N/A x x x x x Moderate

Musk thistle Carduus nutans N/A N/A x N/A N/A x N/A Low

Diffuse knapweed Centaurea diffusa x (Priority 2B) N/A x x N/A x x Low

Spotted knapweed Centaurea maculosa x (Priority 2B) N/A x x x x x High

Russian knapweed Centaurea repens x (Priority 2B) N/A x x x x x Low

Yellow starthistle Centaurea solstitialis x (Priority 1A) N/A N/A N/A x N/A N/A Rare

Rush 

skeletonweed Chondrilla juncea x (Priority 1B) N/A N/A N/A N/A N/A N/A None

Oxeye-daisy Chrysanthemum 

leucanthemum x (Priority 2B) N/A x N/A x x x Low

Canada thistle Cirsium arvense x (Priority 2B) N/A x x x x x High

Poison hemlock Conium maculatum N/A x N/A N/A N/A N/A x Low

Field bindweed Convolvulus arvensis x (Priority 2B) N/A x x x x x High

Common crupina Crupina vulgaris N/A N/A N/A N/A N/A N/A N/A Rare

Houndstongue Cynoglossum officinale x (Priority 2B) N/A x x x x x Moderate

Scotch broom Cytisus scoparius x (Priority 1B) N/A N/A N/A N/A N/A N/A None

Common teasel Dipsacus fullonum N/A N/A N/A N/A N/A N/A x Low

Blueweed Echium vulgare x (Priority 2A) N/A N/A N/A N/A x N/A Rare

Urban spurge Euphorbia agraria N/A N/A N/A N/A N/A x N/A Low

Leafy spurge Euphorbia esula x (Priority 2B) N/A x x x x x High

Orange hawkweed Hieracium aurantiacum x (Priority 2A) N/A N/A N/A N/A x N/A Rare

Meadow 

hawkweed 

complex

Hieracium 3-59retense, 

H. floribundum, 

H. piloselloides

x (Priority 2A) N/A N/A N/A N/A N/A N/A None

Black henbane Hyoscyamus niger N/A x N/A N/A N/A x N/A Low

St. Johnswort Hypericum perforatum x (Priority 2B) N/A N/A N/A N/A x x Rare

Yellowflag iris Iris pseudacorus x (Priority 2A) N/A N/A N/A N/A N/A N/A None

Dyer’s woad Isatis tinctoria x (Priority 1B) N/A x N/A N/A N/A N/A Rare

Perennial 

pepperweed Lepidium latifolium x (Priority 2A) N/A N/A N/A N/A N/A N/A Low

Dalmatian toadflax Linaria dalmatica x (Priority 2B) N/A x x N/A x x

Low 

Moderate

Yellow toadflax Linaria vulgaris x (Priority 2B) N/A x x x x x Low

Purple loosestrife Lythrum salicaria, 

L. virgatum x (Priority 1B) N/A x N/A N/A N/A x Rare

Eurasian water 

milfoil Myriophyllum spicatum x (Priority 1B) N/A N/A N/A N/A N/A N/A None

Scotch thistle Onopordum acanthium N/A N/A x x N/A N/A N/A Low

Japanese 

knotweed complex

Polygonum cuspidatum, 

P. sachalinense, 

P. polystachyum

x (Priority 1B) N/A N/A N/A N/A N/A N/A None

Sulfur cinquefoil Potentilla recta x (Priority 2B) N/A x x x x x Low

Tall buttercup Ranunculus acris x (Priority 2A) N/A N/A N/A N/A x x Rare

Woodland sage Salvia nemorosa N/A N/A N/A N/A N/A x N/A Low

Tansy ragwort Senecio jacobea x (Priority 2A) N/A N/A N/A N/A N/A N/A None

Milk thistle Silybum marianum N/A N/A x N/A N/A N/A N/A Low

Salt Cedar or 

Tamarisk Tamarix spp. X (Priority 2B) N/A x x x x x High

Common tansy Tanacetum vulgare x (Priority 2B) N/A N/A x N/A x x Low

Puncture vine Tribulus terrestris N/A N/A N/A N/A N/A N/A x High

Common mullein Verbascum thapsus N/A N/A N/A N/A x N/A x Low

Curlyleaf 

pondweed Potamageton crispus x (Priority 1B) N/A N/A N/A N/A N/A N/A None

Cheatgrass Bromus tectorum x (Priority 3) x x x x x x High

Hydrilla Hydrilla verticillata x (Priority 3) N/A N/A N/A N/A N/A N/A None

Note: 

1 Golden Valley and Wheatland counties do not maintain a separate noxious weed list. 

2 Acreage calculations based on historic data and map digitization; acreage calculations are not mutually exclusive. 

3 BLM Class Values: None = 0; Rare = <1 acre; Trace = 1-5 acres; Low = 5-50 acres; Moderate = 50-500 acres; High = >500 acres. 

As of July 2011, MT-DOA will no longer post county designated noxious weeds. County Weed Districts will now provide this information when requested. 

Source: Montana Department of Agriculture 2008. 
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Noxious weeds and invasive plant species are mostly associated with areas experiencing natural 

or manmade disturbances such as waterways, roads, recreational destinations, heavily utilized 

rangeland, pipelines, drilling pads, rights-of-way (ROWs), and livestock/wildlife paths and 

congregation areas. Table 3-21 indicates the presence of noxious weeds and invasive plant 

species in the planning area using historic data and map digitization. Acreage was calculated 

using data collected for the presence of weed species, acres of treatment evaluation, and acres 

of applied weed treatments. 

3.6.6 Special Status Plants 

Special status species are species listed as threatened or endangered under the Endangered 

Species Act (ESA), species proposed or candidates for listing, species designated as sensitive 

by BLM, and state listed species. These species require particular management attention due to 

population or habitat concerns. 

Management of special status species on public lands administered by BLM occurs under a 

variety of laws, policies, and other requirements, as summarized in Chapter 1. There are no 

federally listed plants within the planning area. 

There are 21 BLM sensitive plant species documented as occurring or containing suitable 

habitat in the decision area (Map 14). The BiFO inventories for presence of special status plant 

species and determines restrictions in areas with known populations on a case by case basis. 

Table 3-22 summarizes each species, its listed status, and known range and habitat associations 

in the decision area (BLM 2009). 

There are nine areas of critical environmental concern (ACECs) in the decision area; however, 

only the Meeteetse Spires and East Pryor ACECs have documented special status plant species 

populations. The Shoshone carrot, a BLM sensitive species, has been identified in the 

Meeteetse Spires. The species population trend in the ACEC was recorded as stable. The 

ACEC Decision Record and Approved Amendment of the Billings, Powder River, and South 

Dakota RMPs identifies numerous management actions to protect the species and enhance 

associated habitats including, but not limited to, closures to livestock grazing, closure to entry 

for locatable minerals, closure to mineral material sales, no geophysical exploration, and OHV 

limitations on existing road and trails. The Shoshone carrot was also identified in the East Pryor 

ACEC; however, it was determined no further protection or habitat enhancement measures 

were needed to protect the population (BLM 1999). 

Table 3-22 Special Status Plant Species

Common 

Name1 Scientific Name1

BLM 

Status Known Range and Habitat Associations

Nodding 

Rock Cress

Arabis demissa var. 

languid (Boechera

demissa)

Sensitive 

Primarily inhabits canyon bottoms and outwash plains with dry, stony soils 

derived from limestone. Known to occur in two places in the decision area, 

known only from Pryor Mountains and foothills vicinity and the Bighorn 

Canyon National Recreation Area (BCNRA). 

Cushion 

Milkvetch

Astragalus aretioides 

(Orophaca aretioides) Sensitive

Primarily inhabits foothill and montane communities on exposed ridges and 

slopes in thin soil usually derived from limestone or calcareous sandstone 

in openings of Douglas-fir between 4,400 to 7,800 feet amsl. This species 

is endemic known mainly in the Pryor Mountains in Montana where there 
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Table 3-22 Special Status Plant Species

Common 

Name1 Scientific Name1

BLM 

Status Known Range and Habitat Associations

are three known occurrences. 

Geyer’s 

Milkvetch Astragalus geyeri Sensitive

Occupies loose sandy soil habitats with little or no organic matter in alluvial 

plains and terraces. This species is known to occur in the Pryor Mountain 

foothills at four sites. 

Gray’s 

Milkvetch Astragalus grayi Sensitive Occupies open soil, valley habitats in sagebrush steppe communities. Species is known from three occurrences in the Pryor Mountain foothills. 

Oregon 

Milkvetch Astragalus oreganus Sensitive

Occupies sandy soil habitats associated with the Chugwater Formation 

below 5,000 feet amsl often forming large colonies. A regional endemic of 

south central Montana and central Wyoming, five species occurrences are 

known in the decision area, restricted to the Pryor Mountain foothills. 

Blackfoot 

River 

EveningPrimrose

Camissonia andina 

(Oenothera andina) Sensitive

Occupies exposed, sandy soil habitats of dry prairie slopes, flats, and 

depressions in moist swales on south facing hillsides dominated by big 

sagebrush, curl-leaf mountain mahogany, and occasionally, Douglas-firUtah juniper woodlands between 4,000-6,200 feet amsl. Species is known 

from seven occurrences in the decision area, restricted to the south side of 

the Pryor Mountains. 

Lewis River 

Suncup

Camissonia parvula 

(Oenothera parvula) Sensitive

Occupies sandy soil habitats weathered from calcareous sandstone 

between juniper woodland and sagebrush steppe zones. Species is known 

from two occurrences in the decision area on the southern edge of the 

Pryor Mountains. 

Yellow 

Spiderflower Cleome lutea Sensitive

Occupies open, often sandy soil of sagebrush steppe valley communities. 

Species is known from four occurrences in the decision area, restricted to 

the Pryor Mountain foothills.

Pinyon 

Desert 

Cryptantha

Cryptantha scoparia Sensitive Occupies dry, sandy, limestone uplands at approximately 4,500 feet amsl. 

Species is known from one location in the Pryor Mountains. 

Spiny 

Hopsage Grayia spinosa Sensitive

Occupies dry shrublands in the valleys and foothills usually on sandy 

textured alkaline soils below 5,000 feet amsl. Species is known from 10 

occurrences in the decision area and is restricted to the Pryor Mountain 

foothills. 

Mat Prickly 

Phlox

Leptodactylon 

caespitosum

Sensitive

Occupies north or east facing slopes in dry, open sandy breaks confined to 

outcroppings of Chugwater sandstone. Species is known from 16 

occurrences in the decision area and is restricted to the Pryor Mountain 

foothills. 

Pryor 

Mountain 

Bladderpod

Lesquerella lesicii 

(Physaria lesicii) Sensitive

Occupies two distinct vegetation types: (1) woodlands with a sparse 

overstory of Rocky Mountain juniper-mountain mahogany on moderate to 

steep, usually warm slopes between 5,300-6,300 feet amsl, and (2) open, 

south facing, gentle slopes of exposed ridge crests surrounded by forests 

in bunchgrass/cushion plant communities. Species is known from 10 

occurrences in the decision area, is endemic to the Pryor Mountains, and 

restricted to a few areas of limestone outcrops in the eastern Pryor 

Mountains. 

Torrey’s 

Desert

Dandelion

Malacothrix torreyi (M. 

sonchoides v. torreyi) Sensitive Occupies sandy alluvium, five occurrences are known from the south side of the Pryor Mountains.

Dwarf Mentzelia pumila Sensitive Occupies open habitats, usually characterized by sandy soil in desert 
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Table 3-22 Special Status Plant Species

Common 

Name1 Scientific Name1

BLM 

Status Known Range and Habitat Associations

Mentzelia shrubland and woodland valley and foothill zones. Species is known from 

16 occurrences in the Pryor Mountain foothills. 

Leafy Nama Nama densum Sensitive Occupies sandy soil habitats weathered from outcrops of calcareous 

sandstone and is known from one site in the Pryor Mountain foothills. 

Wasatch 

Bluegrass Poa arnowiae Sensitive Occupies sparsely vegetated soil of Douglas-fir forest floors in the montane zone and is known from one occurrence in the Pryor Mountains. 

Platte River 

Cinquefoil Potentilla plattensis Sensitive

Occupies grassland and sagebrush steppe habitats in the valley and 

montane zones. Species is known from one site in the decision area in the 

Pryor Mountains. 

Largeflower 

Goldenweed

Pyrrocoma 

carthamoides var. 

subsquarrosa 

(Haplopappus

carthamoides var. 

subsquarrosus)

Sensitive

Occupies grassland and sagebrush habitats dominated by bunchgrasses 

or bunchgrass with sagebrush, frequently found on cooler, moderate to 

steep slopes. Species is known from eight occurrences in the decision 

area and is a regional endemic restricted in Montana to the eastern front of 

the Beartooth and Pryor mountain foothills. 

Persistent 

Sepal 

Yellowcress

Rorippa calycina Sensitive

Occupies sparsely vegetated, moist sandy to muddy banks of streams, 

stock ponds, and manmade reservoirs near the high water line. Species is 

only known from one historic site in the decision area. 

Shoshone 

Carrot Shoshonea pulvinata Sensitive

Occupies open, exposed limestone outcrops, ridge tops, and canyon rims 

in thin rocky soils. Species is known from six occurrences in the decision 

area and is a regional endemic species to the Absaroka, Owl Creek, and 

Pryor mountains of Park and Fremont counties, Wyoming and Carbon 

County, Montana. In addition, stable populations have been identified in 

the Meeteetse Spires and East Pryor Mountains ACECs. 

Salty 

Buckwheat

Stenogonum 

salsuginosum 

(Eriogonum 

salsuginosum)

Sensitive

Occupies bentonite soils in dry, open slopes of breaklands at 

approximately 4,700 feet amsl. Species is known from two small 

populations documented on the south side of the Pryor Mountains. 

Note: 

1 Species nomenclature consistent with the USDA PLANTS database (USDA 2009). 

amsl = above mean sea level 

Source: BLM 2009, USDA 2009. 

3.7 Wildlife Habitat and Special Status Species 

Wildlife species in the BiFO planning area include big game animals, raptors, upland game 

birds, and other species. These populations are managed by the U.S. Fish and Wildlife Service 

(USFWS) and Montana Fish, Wildlife and Parks (MTFWP). The BLM works cooperatively 

with these agencies to manage wildlife habitat on public lands. Therefore, the BLM is directly 

responsible for managing fish and wildlife habitat on public lands and is indirectly responsible 

for the health and well-being of fish and wildlife populations supported by habitats on public 

lands. 

Distribution and abundance of wildlife in the decision area are primarily functions of habitat 

availability and conditions. Wildlife habitat is best characterized by the various vegetation 

cover types in the decision area (Vegetative Communities Section). The diversity of habitat 
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types in the decision area is high (37 types) and ranges from moderate/high cover grasslands to 

Douglas-fir forests. Habitat types are a subcategory of vegetation cover types and are defined 

as a land area that supports, or has the potential of supporting, the same primary climax 

vegetation. For example, a shrubland vegetation cover type could be composed of several 

species of sagebrush and other shrub habitat types. 

These 37 habitat types can be grouped into the following primary vegetative 

communities: grasslands, shrublands, forests, riparian/wetlands, and urban and agricultural 

lands (see Table 3-13). The most common vegetation community is grassland and shrubland, 

which represents approximately 87 percent of the decision area, and the least common 

community type is agricultural lands, which represents 2 percent of the decision area. Carbon 

County has the northern most extension of the Big Horn Basin cold desert into Montana. This 

area creates additional floral and faunal species diversity due to its northern cold desert climate. 

For example, this is the only area in Montana that has white-tailed prairie dogs and a breeding 

population of blue-gray gnatcatchers. 

The diversity and populations of fish and wildlife throughout the decision area provide 

considerable recreational opportunity and economic benefit. The species listed in Table 3-23

characterize fish and wildlife resources in the planning area and include game species, species 

vulnerable to impacts, and species with high economic or recreational value. 

3.7.1 Wildlife Habitat Threats 

Fragmentation of habitats and corridors continues to be an ongoing problem for wildlife. There 

are seven large blocks of public land over 5,000 acres in the decision area. Refer to Map 1 and 

1a for locations of the large blocks of public land. The remaining public land is mixed 

ownership of scattered public lands. Wildlife management opportunities for the BLM are very 

limited on the small or scattered tracts of public land. Wildlife species that are mobile, such as 

big game and birds, are affected by management of habitat on the surrounding ownerships. 

BLM can effectively manage wildlife habitat on the large blocks of public land, although 

management options are less effective on scattered public lands, due to the influence of habitat 

management on surrounding areas. Maintaining connectivity and continuity of habitat with 

scattered land ownership is difficult. Conversely, these small tracts of relatively undisturbed 

public land can provide valuable islands of native habitat, native species, and biodiversity. 

Wildlife habitat threats in the scattered public land ownership include: habitat loss and 

conversion from construction and farming; subdivisions with the associated infrastructure 

developments; rights-of-ways for pipelines, power lines, roads, and fences; disturbances from 

human activities; and noxious weeds. All of these actions can prevent wildlife movement and 

reduce, eliminate, or fragment wildlife habitat and quality. 

3.7.2 Priority Wildlife Species 

Priority wildlife species include game animals and non-game species of special interest. The 

latter includes those species considered to have a unique role in the ecosystem, are of public 

interest, have a low abundance or declining population, are associated with rare habitats, have 

potential threats, may be sensitive to BLM management activities, and have a majority of their 
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habitat on BLM lands. Availability and quality of data vary for individual species. Refer to 

Maps 15-23 and 25 for some of the wildlife and big game species maps. 

In addition to the species described in Table 3-23, the following species are considered priority 

wildlife species: white-tailed prairie dog, mountain plover, Blue-gray gnatcatcher, Greater 

sage-grouse, and Yellowstone cutthroat trout. White-tailed prairie dogs, mountain plover, and 

Yellowstone cutthroat trout are considered priority species due to their rarity, low abundance, 

and declining populations in Montana. Blue-gray gnatcatchers are considered a priority due to 

their unique, rare, and only known documented breeding location in Montana. Greater sagegrouse are considered a priority species due to their declining population trends and number of 

habitat threats.
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Table 3-23 Habitat for Priority Wildlife Species in the Planning Area 

Species Occurrence in Planning Area General Habitat Associations Abundance & Trends in Area

Mule deer Most abundant big game species. Use wide variety of habitat; generally prefer 

sagebrush, grassland, and conifer areas.

Mule deer populations in prairie habitats are below levels in 

the early 1990s and mountain mule deer populations are well 

below levels of the 1980s and 1990s.a

White-tailed deer Well distributed throughout suitable 

habitat.

Prefer riparian drainage bottoms and conifer 

forests.

White-tailed deer populations in south-central Montana have 

remained relatively stable at above average levels. 

b

Pronghorn antelope Second most abundant big game 

species.

Use grasslands, sagebrush and other shrubgrasslands, and agricultural fields.

From 1998 to 2006 numbers increased in most districts. Low 

fawn numbers and a bluetongue outbreak during 2007 have 

resulted in reduced antelope populations in many districts 

during 2007 and 2008. b

Rocky Mountain elk

Common in Beartooth and Bull 

mountains; less common in southcentral portion of the planning area.

Use grasslands, shrub-grasslands, 

woodlands, and riparian/wetlands.

Of the 14 Elk Management Units (EMUs) 6 showed population 

increases, 7 showed population declines and 1 unit was not 

inventoried. b

Bighorn sheep Occur as a single herd -in the Pryor 

Mountains.

Use cliffs, mountain slopes, and rolling 

foothills with open to semi-open conditions 

(rocks, grasses, shrubs).

Pryor Mountain population trend has been increasing since 

2003 with 78 bighorn sheep in 2008. Hunting was initiated in 

1990. Three ram permits have been issued since 2005 and 

three either-sex permits were issued beginning in 2008. b

Moose Historically, in the Boulder River 

and Beartooth Mountain foothills.

Often use southerly aspects in winter, forest, 

wet meadows, and riparian/wetland areas.

Flight efficiencies are too variable to make any statements 

about moose population trends. b

Black Bear Pryor Mountains and Beartooth 

Front. Forested habitats in the mountain ranges. 

Population data is unavailable, although according to 

observations of cubs/female the population trend appears to 

be static and close to the average over 27 years of data.b

Mountain Lion Widespread, concentrated where 

deer and elk prey base is available All habitats where deer and elk are present.

Population data is unavailable, although according to the 

report, ranges have expanded substantially to previously 

uninhabited areas due to the distribution and habitat

expansion of deer and elk, their primary prey base. b

FurbearersBobcat, marten, fisher, 

beaver, muskrat, mink, 

otter

Widespread over Field Office Variable depending on the species

 Population trends are unknown.

 Trapping harvest data in 2008 indicate beaver, muskrat, 

coyote, mink, weasel, fox, and badger were 46% below 

the long term average from 1993-2009. 

 Total number of bobcats trapped has steadily increased 

from 1995 to 2009. b
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Chapter 3: Affected Environment 3-67

Species Occurrence in Planning Area General Habitat Associations Abundance & Trends in Area

Upland Birds:

1

Sharp-tailed grouse, blue 

grouse, ruffed grouse, wild 

turkey, ring-necked 

pheasant, Hungarian 

partridge, chukar partridge

Generally well distributed 

throughout suitable habitat.

 Sharp-tailed grouse use grasslands, 

shrub-grasslands, woodlands, 

riparian/wetlands, and agricultural areas.

 Wild turkey use forested riparian areas, 

use Ponderosa pine hillsides, agricultural 

fields.

 Ring-necked pheasant use riparian 

bottoms with adjacent agricultural fields.

 Hungarian partridge use grasslands with 

interspersed agricultural fields and 

brushy/weedy areas. Chukar partridge 

are found in the broken terrain in south 

Carbon County.

 Sharp-tailed grouse are declining in abundance.

c

 Hungarian partridge population in the state has been 

increasing since the 1940s due to increased grain 

production.

d

 2009 harvest data indicate blue grouse harvest at 12% 

below average and ruffed grouse 10% above average.

 2010 data show ring-necked pheasant population trends 

down 11%. 

 Wild turkey harvest data indicates an upward trend in 

populations. b

 Population trend data is not available for chukar partridge.

Bats:

Spotted, Townsend’s BigEared, Pallid, Hoary, 

Fringed Myotis 

Not well known other than caves. Primarily caves and forested or riparian 

areas.

Data is not available.

Waterfowl Well distributed throughout suitable 

habitat. Use reservoirs, wetlands, and rivers. Information is not available.

Raptors

Well distributed; riparian areas are 

important habitat for raptors in 

BiFO.

Utilize key habitat features such as Cliffs, 

Steep banks, structures, large trees, etc.

Information is not available. Peregrine falcon and bald eagle 

populations increasing.

Reptiles:

Spiny softshell Turtle, 

Snapping turtle, Western 

hog-nosed snake, pale 

milksnake, greater shorthorned lizard, common 

sagebrush lizard

Some species such as pale 

milksnake and western hog-nosed 

snake not well documented; other 

species well distributed in suitable 

habitat.

Turtles in large rivers and snakes and lizards 

in open and rocky shrublands. Population trend data is not available.

Note: 

1 1 Greater sage-grouse are addressed in the Special Status Species section. 

2

a Source: Progress Report (MFWP, 2007 – 2008) 

3

b Source: Progress Report (MFWP, 2009 – 2010)

c 4 J. Newell, pers. comm. 2005 

5

d MTFWP and MNHP 2005 
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3.7.3 Terrestrial Wildlife 

3.7.3.1 Big Game 

Big game species in the planning area include mule deer, white-tailed deer, pronghorn antelope, 

Rocky Mountain elk, bighorn sheep, moose, black bear, and mountain lion. Winter is a crucial 

and stressful time for big game; therefore, winter range is often the focus of management and a 

criterion for analyzing the impacts to big game from resource management (see Table 3-23). 

Big game maps are included in Appendices/ Maps 16-20, and will be updated as information 

becomes available. 

Threats to big game habitat in the decision area are direct habitat loss, disturbance from human 

activities, fragmentation from habitat loss, and barriers to movement such as fencing. The 

greatest barrier to big game movements are woven-wire or net-wire fences, particularly for 

young big game. Currently, there is not an inventory of fences not meeting BLM fencing 

standards. Most of the net-wire fences exist along highway and road rights-of-ways. 

Table 3-24 Big Game Habitat and Distribution by Land Ownership in the Planning Area 

Species Habitat/Distribution BLM Total

Mule Deer

Year round distribution 428,896 (5%) 8,506,948

General winter range 93,099 (3%) 2,942,431

Crucial winter range 72,432 (5%) 1,335,622

White-tailed Deer

Year round distribution 70,673 (2%) 3,208,637

General winter range 25,439 (2%) 1,295,443

Crucial winter range 6,076 (3%) 205,530

Pronghorn Antelope

Year round distribution 179,690 (4%) 4,859,757

General winter range – not identified — —

Crucial winter range 35,086 (8%) 454,789 

Rocky Mountain Elk

Year round distribution 79,353 (1%) 7,734,652

General winter range 12,240 (2%) 586,235

Crucial winter range 13,567 (6%) 229,393

Bighorn Sheep Year round distribution 13,875 (4%) 358,368

Moose

Year-round distribution 12,595 (2%) 791,814

General winter range 3864 (1%) 278,996

Crucial winter range * *

Gray Wolf FWP Wolf District 34,457 (2%) 1,529,493

Lynx Year-round distribution 0 528,367

Grizzly Bear Year-round distribution 0 140,674 

Note: 

Source: Crucial winter range values taken from Montana Fish Wildlife & Parks Historic (1970s) inventory data. All other data 

obtained from the Montana Fish Wildlife and Parks website: http://fwp.mt.gov/doingBusiness/reference/gisData/default.html/ 

Last accessed 01/14/2010
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3.7.3.1.1 Mule Deer 

Mule deer are the most abundant big game species in the planning area and use the greatest 

variety of habitats (refer to Table 3-24 and Map 19 [Mule Deer Distribution]). Areas of yearround mule deer distribution total over 8 million acres in the planning area, with about

5 percent of that acreage on BLM public lands. An important limiting factor for mule deer, as 

well as other big game in the planning area, is the availability of winter range (Map 15 – Big 

Game Winter Range). 

Spring and summer drought reduces forage abundance and, therefore, populations fluctuate. 

Only a small area of mule deer winter range is documented in the MTFWP database. 

3.7.3.1.2 White-tailed Deer 

Although less abundant than mule deer, white-tailed deer are common in the planning area 

(Table 3-24). White-tailed deer prefer riparian drainage bottoms and conifer areas and will also 

use a variety of other habitats (Map 20 – White-tailed Deer Range Distribution). 

Approximately 25,439 acres or 2 percent of the over 3 million acres of white-tailed deer habitat 

in the planning area is on public lands. 

3.7.3.1.3 Pronghorn Antelope 

Pronghorn antelope are the second most abundant big game species in the planning area (Table 

3-24). These animals are generally associated with grasslands and shrublands, and they will 

also use agricultural fields (Map 16 – Antelope Range Distribution). Approximately 179,690 

acres or 4 percent of the more than 4 million acres of pronghorn antelope habitat in the 

planning area are on BLM public lands. Currently, Antelope Winter range has not been 

designated by MTFWP in the planning area. Historically, there were 35,086 acres of Antelope 

Crucial Winter Range identified in the planning area. Documented crucial winter range for 

pronghorn antelope was most abundant in Sweet Grass, Golden Valley, Musselshell, 

Yellowstone and Carbon counties. Antelope populations reached record high numbers in 1990-

1994, declined from 1995-1997, and generally have increased since 1998. Habitat conditions 

for antelope are unknown, other than that extensive drought may have decreased forage 

availability. Portions of the planning area have been affected by outbreaks of blue tongue 

disease. 

3.7.3.1.4 Rocky Mountain Elk 

Rocky Mountain elk are associated with grasslands, shrublands, woodlands/forests, and 

riparian/wetlands (Table 3-24). This species is common in the Bull, Snowy, Crazy, and 

Beartooth mountains foothills in the planning area (Map 18 – Elk Range Distribution). A recent 

increase in elk populations into new areas where there is more open sagebrush/grassland and 

open timber types have been observed. Summer habitat is primarily in the Bull Mountains and 

foothills of the decision area. Winter habitat is concentrated in the mountain foothills and the 

area south of the Bull Mountains. There are 14 known elk herds in the planning area. The 2010 

population trends were up in six herds, down in seven elk herds, and one herd not inventoried, 

when compared to 2008 -2009 population levels. 
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3.7.3.1.5 Bighorn Sheep 

Rocky Mountain bighorn sheep occur as a single herd and occupy areas on USFS, National 

Park Service (NPS), BLM, state, and private lands surrounding the east and west Pryor 

Mountains. Approximately 13,875 acres or 4% percent of the occupied area occurs on BLM 

public lands (Map 17 –Bighorn Sheep Range Distribution). Historically, there was a herd along 

the Boulder River but died out due to disease. Habitats include cliffs, mountain slopes, and 

rolling foothills. A 2008 survey for bighorn sheep indicated the second highest population 

count since 1997. 

3.7.3.1.6 Moose

Moose are associated with forested and riparian/wetland areas of the Beartooth Mountains. 

Populations have remained static. Seasonal habitat data from the 1970s indicate there are 

approximately 3,864 acres of moose winter range on BLM lands, or 1% of total winter range, 

and little summer range in the decision area. 

3.7.3.1.7 Black Bear 

Black bears use a variety of habitats depending on seasonal variation in diet and availability of 

food. Black bears are omnivorous; however, much of their diet consists of berries, fruits, 

grasses, sedges, and inner bark. In the planning area, black bears tend to prefer dense forested 

areas, riparian areas, open slopes, and mountain meadows (Foresman 2001). Black bears tend 

to be relatively tolerant of land uses since they have a large home range and can utilize a 

variety of habitats. Recreation, road development, and timber management are land uses that 

bears tolerate less. 

3.7.3.1.8 Mountain Lion 

Mountain lions are distributed throughout the planning area where suitable habitat is present. 

They use different habitat types, depending on prey availability, cover, and preference for areas 

with minimal human disturbance. Mountain lions typically prefer mountainous and foothill 

areas; however, in eastern Montana, they are commonly associated with riparian areas and 

woody draws. Mountain lions are carnivorous and feed on a variety of animals. However, they 

prefer deer, elk, porcupines, and rabbits. 

3.7.3.1.9 Furbearing Animals 

Furbearing animals in the planning area include otter, beaver, bobcat, mink, weasel, muskrat, 

and marten. Bobcats are habitat generalists and can be found throughout the planning area, 

although bobcat do not occupy high mountain areas. Beaver, mink, and muskrat are common in 

the waters and riparian areas throughout the planning area. Marten occur in forested regions of 

the mountains in the planning area. Short-tailed weasels are found in coniferous forest, riparian 

shrub, and meadow habitats, while long-tailed weasel are typically found in rock outcrops near 

water in desert shrub, grassland, and riparian shrub habitats (Cerovski et al. 2004). 

3.7.3.1.10 Game Birds 

Upland game birds common to the planning area include sharp-tailed grouse, greater sagegrouse, blue grouse, ruffed grouse, wild turkey, ring-necked pheasant, Hungarian, and chukar 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-71

partridge (Table 3-25). Greater sage-grouse is considered a special status species and is 

addressed further in the Special Status Species section. 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 

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. 

Waterfowl species common in the planning area include Canada and snow geese and 18 species 

of ducks (Table 3-26). The presence of open water is the most important factor for waterfowl 

production. Grassland habitats adjacent to open water are also important for waterfowl in the 

planning area. There are 241,079 acres of open water habitat in the planning area including 

rivers, streams, natural potholes, and artificial reservoirs. Natural and constructed islands on 

reservoirs are important to Canada geese and some duck species because they provide security 

from predators during nesting and brood rearing. In addition to the breeding season, waterfowl 

use the planning area during spring and fall migrations seeking agricultural fields, wetlands, 

and major rivers such as the Yellowstone, for roosting, cover, and feeding. 

The Bundy Island area, just west of Pompeys Pillar, NM in Yellowstone County, and other 

river bottom riparian areas provide brood rearing habitat for Canada geese and other waterfowl 

species. Other wildlife such as bald eagles, white-tailed deer, ring-necked pheasants, numerous 

furbearers, and various non-game species inhabit the island. Bundy Island is one of the few 

islands in the Yellowstone River managed by the BLM. 

Table 3-25 Upland Game Bird Habitat and Distribution by Ownership in the Planning 

Area 

Species Habitat/Distribution BLM4 Total

Sharp-Tailed Grouse1

Overall distribution

307,236 (4%) 8,263,040

Wild Turkey2,3 74,044 (4%) 2,055,715

Ring-Necked Pheasant2

Good/excellent habitat 9094 (2%) 438,250

Fair habitat 2081 (1%) 219,139

Total pheasant habitat 11,175 (2%) 637,389

Hungarian Partridge2 Overall distribution 292,975 (3%) 8,584,264

Chukar 

No data available

No data No data

Blue Grouse 97,649 (4%) 2,354,033

Ruffed Grouse 139,107 (8%) 1,837,558

Note: 

a. Totals may not add up, due to rounding errors. 

1. Data are from BLM 2000a. 

2. Data from MTFWP. 

3. Distribution and habitat data for wild turkey and ring-necked pheasant on tribal/BIA land are incomplete. 

4. There are no areas designated as potential (unoccupied) turkey habitat in the Billings decision area. 

5. Numbers in parentheses are the percent of habitat located on BLM-administered land. 
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Table 3-26 Waterfowl Species Known to Occur in the Planning Area 

Dabbling Ducks Diving Ducks Other Waterfowl

American widgeon

Barrow’s goldeneye

Blue-winged teal

Cinnamon teal

Green-winged teal

Gadwall

Harlequin duck

Mallard

Northern pintail

Northern shoveler

Wood duck

Bufflehead

Canvasback

Common goldeneye

Common merganser

Redhead

Ring-necked duck

Ruddy duck

Lesser scaup

Canada goose

Snow goose

Note: 

Source: BLM 2000a 

3.7.3.2 Non-Game Animals 

Various non-game species occur in the planning area including small mammals, bats, 

songbirds, raptors, reptiles, and amphibians. Non-game mammals include an undetermined 

number of small mammals such as ground squirrels, mice, chipmunks, rabbits, skunks, and 

raccoons that provide the main prey for raptors and larger carnivores. 

Raptors and other migratory birds are protected under the Migratory Bird Treaty Act. Under 

Executive Order 13186, Responsibilities of Federal Agencies to Protect Migratory Birds, 

federal agencies are required to address migratory birds in all of their activities. A wide variety 

of migratory birds reside in the planning area, and species are generally associated with 

particular habitat types. Migratory birds with declining population trends and/or those 

associated with uncommon habitats, as identified through the Montana Partners in Flight Bird 

Conservation Plan, are of the greatest conservation concern (Casey 2000). 

Montana Audubon and the National Audubon Society has identified one Important Bird Area 

(IBA) in the planning area at Bear Canyon in the foothills of West Pryor Mountain, near the 

Wyoming border. The area is four square miles, and the Utah juniper supports 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 (Audobon.org). 

Currently, approximately 94 raptor nests are documented in the planning area, of which 28 

raptor nests are on BLM administered surface land. Not all of these nests are occupied. Raptors 

include eagles, hawks, owls, falcons, and vultures, and the planning area provides seasonal and 

year round habitat for a multitude of raptor species. Raptor utilization for specific and region 

wide areas varies greatly year to year and season to season depending on prey availability, 

habitat quality, level of raptor populations, and other factors. Common breeding raptors in the 

planning area include Swainson’s hawk, ferruginous hawk, red-tailed hawk, northern harrier, 

golden eagle, prairie falcon, American kestrel, and great-horned owl. Of these raptors, golden 
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Chapter 3: Affected Environment 3-73

eagle and great-horned owl are year round residents, and smaller winter populations of redtailed hawk and northern harrier occur in the planning area. 

The Special Status Species section addresses the bald eagle, golden eagle, ferruginous hawk, 

Swainson’s hawk, burrowing owl, northern goshawk, and peregrine falcon. Other raptor 

species found during various times of the year include rough-legged hawk, a winter resident; 

snowy owl, a rare winter visitor; long-eared owl, a denizen of open and forested areas; and 

short-eared owl. Ospreys are common summer residents along major river and stream systems 

in the planning area. 

Forest raptors in the planning area include sharp-shinned hawk, Cooper’s hawk, northern 

goshawk, and northern saw-whet owl. Management direction for the BLM is identified in the 

BLM Fish and Wildlife 2000 Raptor Habitat Management Plan (BLM 1992b). Management 

procedures and activities for raptors have been identified by the USFWS management 

guidelines (USFWS 2002) and Avian Protection Plan guidelines (APLIC and USFWS 2005). 

Golden eagles also are protected under the Bald and Golden Eagle Protection Act and the Eagle 

Act. 

Raptors have specific nesting territory requirements, including vegetation structure and 

diversity. Requirements for physiographic features (elevation, slope), as well as prey 

availability, vary by species. Raptors typically reuse the same nesting territory for years, and 

alterations to these areas could reduce the viability of raptor populations. Threats to raptors 

include loss of habitat, reduction in food supply, and disturbance during nesting. Habitat loss 

from changing land use to industrial, agricultural, or recreational could reduce available food 

supply or alter nesting territories. Each raptor nest, its offspring, and supporting habitat are 

considered important to the long term viability of raptor populations. 

Generally courtship, nest construction, incubation, and early brooding are considered higher 

risk periods during which adults are easily prone to temporarily or permanently abandon nests 

in response to disturbance. This may result in abandonment of eggs or young. Loss or alteration 

of habitat for any raptor species can also result in a loss of or change in the raptor prey base or 

historical nesting territories (USFWS 2002). 

The Billings Field Office harbors the greatest diversity of bat species in Montana, including 3 

species listed as Sensitive by the BLM, MFWP, and Montana Natural Heritage, including 

spotted bat, Pallid bat, and Townsend’s big-eared bat. Ten bat species have been documented, 

and the potential exists for additional species to be present (Hendricks et al., 2004). 

Other animals include amphibians, which are considered a special management group of 

species due to their association with rare habitats (wetlands and riparian areas), their sensitivity 

to environmental conditions, global population declines for some species, and the limited 

knowledge regarding their occurrence and distribution in the planning area. Amphibians that 

are known or expected to occur in the planning area include the tiger salamander, plains 

spadefoot, Great Plains toad, Woodhouse’s toad, boreal chorus frog, and northern leopard frog 

(Table 3-23). 
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3.7.3.3 Wildlife Special Status Species 

Special status species are species listed as threatened or endangered under the Endangered 

Species Act (ESA), species proposed or candidates for listing and species designated as 

sensitive by BLM. These species require particular management attention due to population or 

habitat concerns. 

Management of special status species on public lands administered by BLM occurs under a 

variety of laws, policies, and other requirements, as summarized in Chapter 1. No management 

actions are permitted on BLM lands that would jeopardize the continued existence of species 

that are federally listed, proposed for listing, or candidates for listing. Consultation is required 

on any action that a federal agency proposes that (1) may adversely impact a federally listed 

species, or (2) will result in jeopardy or adverse modification of critical habitats. BLM Manual 

6840 - Special Status Species Management (BLM 2008) addresses management with the 

objectives to: 

1) Conserve listed species and the ecosystems on which they depend 

2) Ensure that actions requiring authorization or approval by the BLM are 

consistent with conservation needs of special status species and do not 

contribute to the need to list special status species either under the provisions of 

the ESA or BLM Manual 6840 

3) Prioritize needed conservation work with an emphasis on habitats (BLM 2008) 

BLM sensitive species are defined as species that: 

 Could become endangered in or extirpated from a state, or within a significant 

portion of its distribution 

 Are under status review by the usfws and/or the national marine fisheries service 

(nmfs) 

 Are undergoing significant current or predicted downward trends in habitat 

capability that would reduce a species’ existing distribution 

 Are undergoing significant current or predicted downward trends in population 

or density such that federally listed, proposed, candidate, or state-listed status 

may become necessary 

 Typically have small and widely dispersed populations 

 Inhabit ecological refugia or other specialized or unique habitats, or 

 Are state listed, but which may be better conserved through application of BLM 

sensitive species status. 

For federally listed species that do not have critical habitat designated, BLM cooperates with 

the USFWS to determine and manage habitats of importance. The USFWS provides regulatory 

oversight for all fish, plant, and wildlife species listed as threatened or endangered, proposed 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-75

for listing, or that are candidates for listing under the ESA. Management of federally listed 

species and the designation of critical habitats are overseen by the USFWS in accordance with 

the ESA. 

BLM, Montana State Office entered into a Memorandum of Understanding (MOU) with the 

USFWS, Montana Field Office, to improve the efficiency and effectiveness of plan level 

Section 7 consultation processes under the ESA. The MOU states that during planning BLM 

agrees to promote conservation of candidate, proposed, and listed species and to consult on 

RMP effects for listed species, confer on RMP effects for proposed species, and develop 

conservation strategies for candidate species (BLM-MOU-MT923-0402, June, 2004). The 

BLM maintains specific goals of contributing to the recovery of species currently listed under 

the ESA and to promoting the recovery and conservation of all special status animal and plant 

species in the planning area 

3.7.3.4 Special Status Wildlife in Planning Area

Currently, there are 48 special status wildlife species that occur in the planning area (Table 

3-27). Four species are listed under the ESA: the black-footed ferret (endangered), the grizzly 

bear (threatened), the Canada lynx (threatened), and the whooping crane (endangered). Three 

species, the gray wolf, peregrine falcon, and bald eagle, were delisted; however, they are 

considered BLM sensitive species. No critical habitat for ESA listed species occurs in the 

planning area. 

In addition, migratory birds have special protections through the Migratory Bird Treaty Act and 

Executive Order 13186. Two federally listed species (the black-footed ferret and grizzly bear) 

had historically occurred in the planning area but are no longer present. The grizzly bear 

recovery zone has been identified along the FS/BLM boundary in the Beartooth Mountain 

foothills. Grizzly bears and wolves may be occasional migrants on BLM lands and still require 

consideration in BLM activities. Lynx exist along the perimeter of the planning area on FS 

lands; however, there are no Lynx Analysis Units, (management areas that contain suitable 

lynx habitat and approximate the size of a female home range (Ehle and Keinath 2002), 

identified on public lands in the planning area. Lynx may be occasional migrants onto public 

lands. Whooping cranes may also be an occasional migrant into the planning area. If prairie 

dog populations expand in the future, the possibility exists that black-footed ferrets may be 

considered for reintroduction into portions of the planning area, particularly in Musselshell 

County. Due to that possibility, they are included in this section, although habitat suitability 

models would have to be analyzed. Sources of information include GIS data from the BLM, 

MTFWP, the 1984 RMP, communications with regional biologists (BLM, USFWS and 

MTFWP), and a literature review. 

Table 3-27 Special Status Wildlife Species in the Planning Area 

Common Name Scientific Name

Federal 

Listing

Status1 BLM 

Listing

State 

Listing

Mammals

Black-footed Ferret Mustela nigripes LE, XN Special Status S1

Black-tailed Prairie Dog Cynomys ludovicianus Sensitive S3
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Common Name Scientific Name

Federal 

Listing

Status1 BLM 

Listing

State 

Listing

Fringed Myotis Myotis thysanodes Sensitive S3

Gray Wolf Canis lupus DM Sensitive S3

Grizzly Bear Ursus arctos LT Sensitive S2S3

Meadow Jumping Mouse Zapus hudsonius Sensitive S2

Pallid Bat Antrozous pallidus Sensitive S2

Spotted Bat Euderma maculatum Sensitive S2

Townsend’s Big-eared Bat Corynorhinus townsendii Sensitive S2

White-tailed Prairie Dog Cynomys leucurus

Wolverine Gulo gulo LT Sensitive S3

Canada Lynx Lynx canadensis LT Special Status S3

Birds

Baird’s Sparrow Ammodramus bairdii Sensitive S3B

Bald Eagle Haliaeetus leucocephalus DM Sensitive S3

Black Tern Chlidonias niger Sensitive S3B

Bobolink Dolichonyx oryzivorus Sensitive S3B

Brewer’s Sparrow Spizella breweri Sensitive S3B

Burrowing Owl Athene cunicularia Sensitive S3B

Chestnut-collared Longspur Calcarius ornatus Sensitive S2B

Ferruginous Hawk Buteo regalis Sensitive S3B

Golden Eagle Aquila chrysaetos Sensitive S3

Great Gray Owl Strix nebulosa Sensitive S3

Greater Sage-Grouse Centrocercus urophasianus Candidate Sensitive S2

Harlequin Duck Histrionicus histrionicus Sensitive S2B

Loggerhead Shrike Lanius ludovicianus Sensitive S3B

Long-billed Curlew Numenius americanus Sensitive S3B

McCown’s Longspur Calcarius mccownii Sensitive S3B

Mountain Plover Charadrius montanus Sensitive S2B

Northern Goshawk Accipiter gentilis Sensitive S3

Peregrine Falcon Falco peregrinus DM Sensitive S3B

Red-headed Woodpecker Melanerpes erythrocephalus Sensitive S3B

Sage Thrasher Oreoscoptes montanus Sensitive S3B

Sprague’s Pipit Anthus spragueii Candidate Sensitive S3B
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Common Name Scientific Name

Federal 

Listing

Status1 BLM 

Listing

State 

Listing

Swainson’s Hawk Buteo swainsoni Sensitive S4B

Whooping Crane Grus americana LE Special Status S1M

Fish

Northern Redbelly x Finescale 

Dace Phoxinus eos x phoxinus neogaeus Sensitive S3

Sauger Sander canadensis Sensitive S2

Yellowstone Cutthroat Trout Oncorhynchus clarkii bouvieri Sensitive S2

Amphibians

Great Plains Toad Bufo cognatus Sensitive S2

Northern Leopard Frog Rana pipiens Sensitive S1

Plains Spadefoot Spea bombifrons Sensitive S3

Reptiles

Greater Short-horned Lizard Phrynosoma hernandesi Sensitive S3

Milksnake Lampropeltis triangulum Sensitive S2

Snapping Turtle Chelydra serpentina Sensitive S3

Spiny Softshell Apalone spinifera Sensitive S3

Western Hog-nosed Snake Heterodon nasicus Sensitive S2

Note: 

Source: Montana Natural Heritage Program (MTNHP 2009) 

1 LE - Listed endangered: Any species in danger of extinction throughout all or a significant portion of its range (16 U.S.C. 

1532(6)). 

LT - Listed threatened: Any species likely to become an endangered species in the foreseeable future throughout all or a 

significant portion of its range (16 U.S.C. 1532(20)). 

DM - Recovered, delisted, and being monitored: Any previously listed species that is now recovered, has been delisted, and 

is being monitored. 

XN - Nonessential population: An experimental population of a listed species reintroduced into a specific area that receives 

more flexible management under the Act. 

C - Candidate: Those taxa for which sufficient information on biological status and threats exists to propose to list them as 

threatened or endangered. We encourage their consideration in environmental planning and partnerships; however, none 

of the substantive or procedural provisions of the Act apply to candidate species.

PS - Partial status: Status in only a portion of the species’ range. Typically indicated in a “full” species record where an 

infraspecific taxon or population, that has a record in the database has ESA status, but the entire species does not. 

PS:Value - Partial status: Status in only a portion of the species’ range. The value of that status appears in parentheses 

because the entity with status is not recognized as a valid taxon by Central Sciences (usually a population defined by 

geopolitical boundaries or defined administratively, such as experimental populations). 

PS:C. - Partial Status – Candidate: Designated as a Candidate in the Western US Distinct Population Segment (DPS) 

(subspecies occidentalis).

Sensitive - Denotes species listed as sensitive on BLM lands. 

Special Status - Denotes species listed as endangered or threatened under the ESA.

Montana Species of Concern are defined as vertebrate animals with a state rank of S1, S2, or 

S3. Vertebrate species with a rank indicating uncertainty (SU), a “range rank” extending below 
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the S3 cutoff (e.g., S3S4), or those ranked S4 for which there is limited baseline information on 

status are considered Potential Species of Concern. Because documentation for invertebrates is 

typically less complete than for vertebrates, only those ranked S1 or S2 are included as SOC. 

Invertebrates with a range rank extending below S2 (e.g., S2S3) are included as SOC only if 

their global ranks are G2G3 or G3, or if experts agree their occurrence in Montana has been 

adequately documented. Other invertebrates of concern with global ranks other than G1, G2, or 

G3 and with state ranks below S2 or range ranks extending below S2 (e.g., S3S4) are treated as 

Potential Species of Concern. Rank definitions and qualifiers are as follows: 

 Rank Definition 

► S1 At high risk because of extremely limited and/or rapidly declining

population numbers, range, and/or habitat, making it highly vulnerable to 

global extinction or extirpation in the state. 

► S2 At risk because of very limited and/or potentially declining

population numbers, range, and/or habitat, making it vulnerable to global 

extinction or extirpation in the state. 

► S3 Potentially at risk because of limited and/or declining numbers, 

range, and/or habitat, even though it may be abundant in some areas. 

► S4 Apparently secure, though it may be quite rare in parts of its range, 

and/or suspected to be declining. 

 Qualifiers 

► B Breeding - Rank refers to the breeding population of the species in 

Montana. Appended to the state rank, e.g. S2B,S5N = At risk during 

breeding season, but common in the winter

► M Migratory - Species occurs in Montana only during migration. 

3.7.3.5 Mammals 

3.7.3.5.1 Black-Tailed Prairie Dog (BLM Sensitive) 

The USFWS recently evaluated the status of the black-tailed prairie dog and determined that 

listing the black-tailed prairie dog as either threatened or endangered is not warranted at this 

time (Federal Register /Vol. 74, No. 231 / 12- 3-09 ). Ongoing threats are: (1) conversion of 

native prairie habitat to cropland;(2) urbanization;(3) oil, gas, and mineral extraction;(4) habitat 

loss caused by loss of prairie dogs; and(5) livestock grazing, fire suppression, and weeds. 

According to the Montana Prairie Dog Working Group (2002), the black-tailed prairie dog 

population in Montana is fragmented, and prairie dogs have been extirpated from local areas 

such as Richland County, most of Carter County, and portions of other counties. Despite this 

reduction in prairie dog distribution, the state still has substantial numbers of black-tailed 

prairie dogs. 
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Chapter 3: Affected Environment 3-79

In the planning area, black-tailed prairie dogs occur in grassland habitats. The potential exists 

for increased prairie dog populations based on the amount of grassland habitat available. 

Grasslands cover approximately 12,159,081 acres (all ownerships) or about 47 percent of the 

area. There are 166 known prairie dog towns in the planning area; 69 (41.6 percent) of which 

occur on public lands (Table 3-28). Long term trends in prairie dog abundance in the area are 

unknown. 

Table 3-28 Black-tailed Prairie Dog Acreage in the Planning Area 

Year/Source BLM State Private / Other National Wildlife 

Refuges Total

2004 Survey 7,098 3,364 15,412 1,399 27,273

% of Total Acreage 26% 12% 57% 5% 100%

3.7.3.5.2 White-Tailed Prairie Dog (BLM Sensitive) 

The USFWS reviewed a petition to list the white-tailed prairie dog under the ESA and 

determined that listing is not warranted at this time (Federal Register / Vol. 75, No. 104 / June 

1, 2010). 

White-tailed prairie dogs generally are found in desert grassland and shrub grassland habitats 

with moderate slopes at altitudes ranging between 5,000 and 10,000 feet. White-tailed prairie 

dogs are susceptible to rapid population declines resulting from flea-borne sylvatic plague. In 

addition, historic and current activities, including shooting, poisoning, and habitat conversion 

have affected white-tailed prairie dog populations. White-tailed prairie dog towns occur only in 

southern Carbon County. There has been a noticeable decline in white-tailed prairie dog towns 

from the 1970s to the early 2000s as illustrated in Table 3-29 below. Definite reasons for the 

decline are unknown, although it is speculated that sylvatic plague has been the primary cause. 

White-tailed prairie dog towns located during surveys from 1975-1977 and in 2003 and 2005 

are shown in Table 3-29. The list for each survey year is in no particular order. 

Table 3-29 White-tailed Prairie Dog Acreage in the Planning Area 

Colony ID

Colony* Size

1975-1977

(acres)

2003

(acres)

2005

(acres)

1 5 – 10 40.5 40

2 2 13 12

3 74 – 84 15 23

4 20 22.5 10

5 Undocumented 18.5 18.5

6 2.5 10 14.6

7 69 – 99 — 4.2

8 10 – 20 — 72

9 79 — 6

10 49 – 79 — 53
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11 39.5 – 59 — —

12 2.0 – 9 — —

13 2.5 — —

14 1 – 2.5 — —

15 2.5 – 10 — —

Total Colonies

Total Acres

15 colonies

692

6 colonies

120

10 colonies

253

Note: 

*”Colony” is used interchangeably with “town” when referring to prairie dog locations and size. 

Sources: 1984 RMP and Backlog Consultation dated May 8, 2008 with the USFWS. 

3.7.3.5.3 Gray Wolf (Federally Delisted and BLM Sensitive) 

On April 2, 2009, the final rule was published that identified the Northern Rocky Mountain 

population of gray wolf (Canis lupus) as a distinct population segment (DPS) and to revise the 

List of Endangered and Threatened Wildlife by removing most of the gray wolves in the DPS. 

This rule complies with that directive. This action is effective May 5, 2011. (Federal Register / 

Vol. 76, No. 87 / Thursday, May 5, 2011). Currently, the gray wolf population is managed by 

Montana Fish, Wildlife, and Parks. 

The gray wolf is present in the planning area and is discussed because of its presence on public 

lands. Two identified wolf packs occasionally range onto public lands along the Beartooth 

Mountain front. 

3.7.3.5.4 Grizzly Bear (Listed Threatened) 

Grizzly bears prefer remote forest habitats with low road density and minimum human 

disturbance (Map 21 – Grizzly Bear Habitat). The planning area is not in a grizzly bear 

Recovery Zone, as designated by the USFWS in the 1993 Grizzly Bear Recovery Plan 

(USFWS 1993); however the perimeter of the grizzly bear range is adjacent to public lands 

along the Beartooth Mountain foothills. Grizzly bears may be present as migrants throughout 

the planning area. A 10-year-old male grizzly bear with a history of killing livestock was 

euthanized after it was captured for killing cattle southeast of Red Lodge, Montana. The 400-

pound bear was caught in a culvert trap Friday, September 9, 2011, on the Sunlight Ranch near 

the upper forks of the Bear Creek Basin. There are BLM managed public lands in this area. 

(http://billingsgazette.com/news/state-and-regional/montana/article_49387a6c-de3b-11e0-

9d9e-001cc4c002e0.html#ixzz1YVmiUBz7) 

3.7.3.5.5 Lynx (Listed Threatened) 

Canada lynx are classified as a furbearer in Montana; however, currently there is no trapping 

season for them. In Montana, lynx are found in mountain and forest regions. East of the 

Continental Divide the subalpine forests inhabited by lynx occur at higher elevations (5,413 to 

7,874 feet) and are mostly species of fir. Secondary habitat is intermixed Englemann spruce 

and Douglas-fir with lodgepole pine as a major seral species (Ruediger et al. 2000). Throughout 

their range, shrub-steppe habitats may provide important linkage habitat between the primary 

habitats described above (Ruediger et al. 2000). 
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There have been no Lynx Analysis Units designated on public lands in the planning area. 

However, there is some potential habitat above the 6,000 foot elevation in the Meeteetse Spires 

and Pryor Mountain areas adjacent to the USFS lands. Only lynx linkage habitat areas are 

identified on Map 22 – Lynx Habitat.

3.7.3.5.6 Black-footed Ferret (Listed Endangered) 

The black-footed ferret was listed as an endangered species in 1967, under a precursor to the 

Endangered Species Act (ESA 1973). The main causes of the species decline included habitat 

conversion for farming, intentional efforts to eliminate prairie dogs and disease (USFWS 

2000). Black-footed ferrets depend almost exclusively on prairie dog colonies for food, shelter, 

and denning (Henderson et al. 1969, Forrest et al. 1985). 

Historically, black-footed ferrets ranged throughout the non-mountainous portion of Montana 

in areas that supported prairie dogs, their primary prey. The black-footed ferret was thought to 

be extirpated from virtually its entire range by the 1970s due to habitat loss, prairie dog 

eradication, disease, and shooting. The species now exists at 17 reintroduction sites across 8 

States, Canada, and Mexico (2 of the 19 reintroduction sites no longer have a ferret population) 

http://www.fws.gov/mountain-prairie/species/mammals/blackfootedferret/ Last updated: April 

5, 2011. Reintroduced populations do not occur in the planning area; the closest populations are 

in the Northern Cheyenne Indian Reservation. As shown in Table 3-28 and Table 3-29, prairie 

dog town concentrations or complexes large enough to support black-footed ferret populations 

are not currently present in the planning area. The largest concentrations of prairie dog towns 

exist in Wheatland County, Montana. Additionally, black-footed ferrets are not documented in 

this area. 

3.7.3.5.7 Wolverine (BLM Sensitive) 

Wolverines occur in coniferous forests in the planning area. There is the potential for 

wolverines to utilize the planning area, especially large, contiguous areas. The planning area 

does not provide the required snow depths for denning due to lower elevations, although the 

large home range of wolverines would allow occasional migratory occurrences in the planning 

area. Montana Fish, Wildlife and Parks trapping records from 1974-2013 indicate three known 

occurrences of wolverines in the Region 5 area (similar to the Billings Field Office planning 

area boundary). The trapping occurrences were in Rockvale community area (Lower Clark’s 

Fork of the Yellowstone) (2003 – private land), Morrisy Narrows in the Little Belt Mountains 

in 2004, and the Bounder River (2004) about 45 miles south-southwest of Big Timber, 

Montana. The last two locations are on U.S. Forest Service managed land. 

3.7.3.5.8 Bats 

The Pryor Mountains support the most diverse bat fauna in Montana. Ten bat species are 

known to be present, and additional species are possible (Hendricks et al., 2004).

Townsend’s Big-eared Bat (BLM Sensitive) 

The occurrence of Townsend’s big-eared bat has been documented in Montana and the 

planning area. Townsend’s big-eared bats were captured at two caves in the Pryor Mountains 

and a new bluff site in the Bull Mountains (Hendricks et al., 2004). 
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Spotted Bat (BLM Sensitive) 

Spotted bat vocalizations were recorded at eight nesting sites in the Pryor Mountains and at one 

location in the Bull Mountains (Hendricks et al., 2004). There is only one other location 

documented in Montana (MFG, 2011). 

The most immediate management action that can benefit this species (and other bat species as 

well) is protection of water sources in arid regions where this bat is present and water sources 

are limited. Open waste sumps, and similar hazardous standing water bodies associated with oil 

and gas fields, could present a significant hazard to Pallid Bats and other bat species as these 

energy resources are exploited (MFG, 2011). 

Pallid Bad (BLM Sensitive) 

A pallid bat was captured at a site along the base of the Pryor Mountains where the species was 

first discovered in Montana in 1978 (Hendricks et al., 2004). There is one other location 

documented in Montana in Rosebud County (MFG, 2011). 

3.7.3.5.9 Meadow Jumping Mouse (BLM Sensitive) 

Small mammal surveys have not been conducted in the BIFO. The meadow jumping mouse 

prefers areas of dense cover in mesic habitats, such as along stream and marshes. Specimens 

have been collected in Big Horn County, Montana (Foresman, 2001). 

3.7.3.5.10 Birds 

Bald Eagle (BLM Sensitive) 

Since the federal delisting of the bald eagle on July 9, 2007 (USFWS, 2007), the species 

continues to be protected under the Bald and Golden Eagle Protection Act. Bald eagles are 

large, primarily fish eating raptors, although they also consume waterfowl and carrion. Bald 

eagles nest and roost near large bodies of water, including lakes, reservoirs, and large rivers. 

Nest and winter roost sites typically are located in large trees adjacent to water. Bald eagles 

commonly nest along the Yellowstone, Clarks Fork, and Stillwater rivers in the planning area. 

There is one nest site on BLM lands in the planning area. This nest site is the Nibbe bald eagle 

nest territory, near Pompeys Pillar, upriver from Bundy Bridge. According to MTFWP and 

BLM maps, there are 10 nest sites along the Yellowstone, Clarks Fork of the Yellowstone, and 

Stillwater rivers adjacent to or in one mile of BLM lands. Additionally, short term 

concentrations of up to 100 bald eagles have been documented at Pompeys Pillar. 

Whooping Crane 

The whooping crane was listed as an endangered species in 1967, under a precursor to the ESA 

(1973). The main cause of the species decline was conversion of pothole and prairie habitat for 

agriculture and shooting. Current threats to wild cranes include collisions with manmade 

objects such as power lines and fences, shooting, predators, disease, habitat destruction, severe 

weather, and a loss of two thirds of the original genetic material. 

Whooping cranes are not known to breed in the planning area or any other portion of Montana. 

Whooping cranes from the Aransas-Wood Buffalo NP occur as transient/migrant species 

known to fly through Montana during both spring and fall migrations. The planning area is 
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located on the extreme western edge of the central migration pathway. Data on whooping 

cranes in the state is limited. There were no sightings from 1996-2002, and the only historic 

sighting prior to 1991 was on the very eastern edge of the planning area (Lenard, S. et al., 

2003). Bird sightings have generally been in marshy areas and grain and stubble fields as well 

as wet meadows and wet prairie habitat (Montana Field Guide 2009). 

Mountain Plover (BLM Sensitive) 

The mountain plover is associated with shortgrass prairie/grasslands (especially those that are 

heavily grazed and are on level or gently sloping areas), and they regularly occupy prairie dog 

towns. Intensive grazing is thought to be beneficial to the birds because they prefer areas with 

extremely short vegetation and a high percentage of bare soil. Records indicate that mountain 

plovers have declined in abundance in Montana over the past century, possibly due to increased 

irrigated agriculture and/or prairie dog control (Montana Field Guide 2009). Limited mountain 

plover surveys have been conducted in the planning area; however, it has been documented that 

mountain plovers are nesting in the shortgrass prairie in the foothills south of the Snowy 

Mountains. In addition, breeding has been documented in southern Carbon County (FaunaWest 

Wildlife Consultants, 2006). 

Long-billed Curlew (BLM Sensitive) 

Long-billed curlews are found across Montana between March and September. Putnam and 

Kennedy (2005) identify shortgrass prairie, mid-grass prairie, sage-steppe, and prairie potholes 

as preferred breeding habitats in the state. Long-billed curlews prefer expansive, open, level to 

gently sloping or rolling grasslands with short vegetation, such as shortgrass or recently grazed 

mixed-grass prairie. During migration, birds use agricultural fields, grazed pastures, wetlands, 

and mudflats (Fellows and Jones, 2009). 

Observations of long-billed curlews in the field office have been more prevalent in the short 

grass prairie areas in the foothills of the Snowy, Little Belt, and east side of the Beartooth 

Mountains. These areas have only scattered tracts of public land and are mostly private lands. 

Conservation concerns include habitat loss (sod busting, weed invasion, general conversion of 

prairie land to other uses), breeding habitat in the state that is either fragmented, unprotected, or 

mismanaged, and/or human directed disturbance to grassland habitats (impacts of cattle 

grazing, roads, and adjacent land activities, pesticide application, and draining of wetlands) 

(Montana Comprehensive Fish and Wildlife Conservation Strategy 2005). 

Greater Sage Grouse (BLM Sensitive) 

On March 5, 2010, the USFWS determined that the greater sage grouse was to be listed as 

warranted, but precluded by other higher priority species, and therefore is a Candidate species 

under the ESA. 

Greater sage grouse use a variety of shrub-steppe habitats throughout their life cycle and are 

considered obligate users of several sagebrush species (USFWS 2005). Nest sites are generally 

under sagebrush cover. In the early brood rearing period, birds remain near the nest site and 

typically move to moist habitats (riparian areas, wet meadows) during the late brood rearing 

period. During winter, the birds rely exclusively on sagebrush for forage and cover. In the state 

of Montana, the greater sage-grouse population declined sharply from 1991 to 1996, then 
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increased through 2000 (Montana Sage Grouse Working Group 2004). Primary ongoing threats 

to greater sage-grouse include loss, fragmentation, and deterioration of habitat from such 

factors as the spread of noxious weeds, infrastructure development, oil and gas (O&G) 

development, wildfire, and conifer invasion (USFWS 2005). Wildfire has been the largest 

factor affecting habitat loss in the planning area. All other factors are minor when acreage 

affected is considered on BLM lands. Private lands have been more affected from habitat 

conversion through dryland farming whereas BLM lands are not affected. Rangeland allotment 

boundary and pasture fences have caused some mortality of sage grouse where they were 

located near lek sites and habitat. Data is not available, although it should be analyzed in the 

future, to identify priorities for marking problem fences. 

The planning area includes approximately 3.68 million acres (all ownerships) of greater sagegrouse habitat and 19 known active lek sites, including approximately 336,000 acres (nine 

percent) on BLM public lands (Table 3-30). 

Table 3-30 Greater Sage Grouse Habitat and Lek Sites in the Planning Area 

Habitat/Distribution BLM State Private

Other

Miscellaneous Total

Total occupied habitat (acres): 336,479 219,199 3,078,179 53,223 3,687,080

**Number of known active lek sites 19 

(27 total; 8 inactive)

11

(15 total; 4 inactive) 220 3 265

Note: 

* Acreage data derived from draft habitat maps from MTFWP. 

**Lek site data is from MTFWP. 

BLM public lands comprise 9 percent of the total occupied greater sage-grouse habitat in the 

planning area. 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. Other BLM GIS data indicate that the planning area contains 265 known 

active greater sage-grouse lek sites. On public lands, there are 19 active and 8 inactive (27 

total) lek sites. Public lands comprise 7 percent of the total leks in the planning area. 

There are 30 lek sites on Federal mineral estate. According to the Reasonable Foreseeable 

Development (RFD) scenario for oil and gas development, there are 103 leks in Moderate 

Potential development areas and 122 leks in Low Potential development areas (Map 124). 

Sage grouse core areas are designated by MTFWP. BLM designated Priority Habitat 

Management Areas (PHMA), Restoration Areas (RA), and General Habitat Management Areas 

(GHMA) with consideration for several factors such as, core or key area designations, lek sites, 

population densities, habitat suitability, habitat disturbances, habitat fragmentation, and land 

ownership (Map 168 – Greater Sage-Grouse Habitat Core Areas). Please refer to the Glossary 

for descriptions of the three Sage Grouse Habitat areas. 

Montana Audubon and the National Audubon Society have identified two Important Bird Areas 

(IBAs) in the planning area. Musselshell and Bridger sage-steppe areas are 3.060,736 and 

358,302 acres respectively. The Bridger sage-steppe area is entirely in Carbon County and the 

Musselshell IBA has acreage in Musselshell and Golden Valley counties in the field office area 
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and four other counties outside of the field office area. The IBAs 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 .

The range of the greater sage-grouse in North America has been divided into seven sage-grouse 

management zones based on populations within floristic provinces (Stiver et. al. 2006). The 

floristic provinces are areas within which similar environmental factors influence vegetation 

communities (Knick and Connelly 2011). The Billings Field office is bisected by two greater 

sage-grouse management zones; the Great Plains Management Zone (MZ1) and the Wyoming 

Basins Management Zone (MZ2). Most of the planning area lies within MZ1; however the 

majority of the sage-grouse habitat managed by the BLM in the planning area lies within the 

extreme northern portion of MZ2 (Figure 3-11). The following discussion of the landscape 

context of the planning area related to greater sage-grouse describes MZ1 since that is where 

the majority of the planning area is located and the issues and descriptions of MZ1 are mostly 

the same as those that would be described for the northern portion of MZ2 found in the 

planning area. 

Greater sage-grouse habitats in Management Zone 1 (MZ1) were historically a function of the 

interaction of physical factors (e.g., climate, soils, geology, and elevation), 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. The sagebrush species associated with greater sage-grouse 

habitat in MZ1 is primarily Wyoming big sagebrush (Artemisia tridentata ssp. wyomingensis). 

Other shrubs present may include basin big sagebrush (Artemisia tridentata ssp. tridentata), 

silver sagebrush (Artemisia cana), greasewood (Sarcobatus vermiculatus), saltbush (Atriplex 

species), rubber rabbitbrush (Ericameria nauseosa), green rabbitbrush (Chrysothamnus 

viscidiflorus), and antelope bitterbrush (Purshia tridentata) and overall shrub cover is less than 

10 percent (Montana Field Guide 2011). Perennial herbaceous components typically contribute 

greater than 25% vegetative cover and consist mostly of rhizomatous and bunch-form grasses, 

with a diversity of perennial forbs (Montana Field Guide 2011). The dominant grass in this 

system is western wheatgrass (Pascopyrum smithii) and sites may include other species such as 

Indian ricegrass (Achnatherum hymenoides), blue grama (Bouteloua gracilis), Sandberg’s 

bluegrass (Poa secunda), or bluebunch wheatgrass (Pseudoroegneria spicata) (Montana Field 

Guide 2011). Dryland sedges such as threadleaf sedge (Carex filifolia) and needleleaf sedge 

(Carex duriuscula) are very common and important in the eastern distribution of this system in 

Montana and Wyoming (Montana Field Guide 2011). Common forbs include Hood’s phlox 

(Phlox hoodii), sandwort (Arenaria species), prickly pear (Opuntia species), scarlet 

globemallow (Sphaeralcea coccinea), purple prairie clover (Dalea purpurea), gayfeather 

(Liatris punctata), and milkvetch (Astragalus species) (Montana Field Guide 2011). Big 

sagebrush is easily killed by fire at all intensities, and when exposed to fire, plants do not 

resprout (Wright et al. 1979). In southwestern Montana, Wambolt and others (2001) found that 

fire in big sagebrush is stand replacing, killing or removing most of the aboveground 

vegetation, and that recovery to pre-burn cover (of sagebrush) takes at least 20 years. In 

Montana, Wyoming big sagebrush may require a century or longer to recover from fire (Lesica 

et al. 2005). Big sagebrush occurs on level to gently rolling plains, plateaus, sideslopes and 
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toeslopes, and as small and large patches in dissected landscapes such as breaks (Montana Field 

Guide 2011). 

Land ownership throughout MZ1 is predominantly private (70%). Ownership of the remaining 

range of the greater sage-grouse in MZ1 is 68% private and 13% state or other federal 

ownership (not including the Fort Peck and Fort Belknap Indian Reservations), with 83% of the 

federal lands in the range of greater sage-grouse in MZ1 managed by BLM. 

Sage-grouse populations have declined in portions of MZ1 through wholesale loss of habitat as 

well as through impacts to birds on the remaining habitat through disturbance and direct 

mortality. The most pervasive and extensive change to the sagebrush ecosystems in MZ1 is the 

conversion of nearly 60% of native habitats to agriculture (Samson et al. 2004). The 

conversion was facilitated by the Homestead Act of 1862 in the United States and the Canada 

Dominion Act of 1872 (Knick 2011). Under the Homestead Act, nearly 1.5 million people 

acquired and plowed over 309,000 sq. mi. (800,000 km2) of land, primarily in the Great Plains 

(Samson et al. 2004). The impacts of land conversion in the late 1800s and early 1900s were 

probably greatest for sagebrush habitats nearest perennial water sources in MZ1. 

 

Much of the direct habitat loss from conversion to agriculture has occurred primarily in the far 

northwestern and northeastern portions of the management zone (Knick et al. 2011). Cropland 

currently cover nearly 19% of the MZ and 91% of the MZ is within 6.9 km of cropland (Knick 

et al. 2011) (Figure 3-12). Recent interest in bio-fuel production and high prices for small 

grains has resulted in an increase in the conversion of native grasslands or lands formerly 

enrolled in the Conservation Reserve Program (CRP) to cropland, further emphasizing the 

importance of BLM lands and associated private lands managed for grazing to maintain large 

blocks of native grassland and shrubland habitats. 

 

Converting native grasslands to agricultural lands not only resulted in a direct loss of habitats 

for native wildlife, it began a process of habitat fragmentation. Habitat loss is exacerbated 

when fragmentation reduces the size and/or isolates remaining habitat patches below the size 

thresholds necessary to support components of biological diversity or blocks the movement of 

animals between habitat patches. As large contiguous blocks of habitat are dissected into 

smaller blocks, they became more isolated from one another by dissimilar habitats and land 

uses. Adverse impacts from fragmentation can occur to individual plant and animal species and 

communities. The impacts of habitat fragmentation to biological resources can occur on 

multiple scales and can vary by species and the type of fragmentation. Individual species have 

different thresholds of fragmentation tolerance; greater sage-grouse (Centrocercus 

europhasianus) have large spatial requirements and eventually disappear from landscapes that 

no longer contain large enough patches of habitat while smaller birds like the Sprague’s pipit 

(Anthus spragueii) can persist in landscapes with smaller patches of habitat because their 

spatial requirements are smaller. 

Changes in vegetation can also result in the loss and fragmentation of native habitats. The 

conversion of large acreages of sagebrush to predominately grassland communities results in 

the direct loss of sagebrush habitat and can also fragment remaining habitat for sagebrushdependent species, such as the greater sage-grouse. Roads and OHV use can promote the 
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spread of noxious weeds through vehicular traffic and noxious weed infestations can further 

exacerbate the fragmentation effects of roadways. Irrigation water has also supported the 

conversion of native plant communities to hayfields, pasture, and cropland, thereby 

fragmenting sagebrush habitats. Excessive grazing can result in the demise of the most 

common perennial grasses in this system and lead to an abundance cheatgrass or Japanese 

brome (Montana Field Guide 2011).

The remaining sagebrush habitats in MZ1 are mostly managed as grazing lands for domestic 

livestock. Domestic livestock function as a keystone species in the MZ through grazing and 

management actions related to grazing. These actions do not preclude wildlife and vegetation, 

but they do influence ecological pathways and species persistence (Bock et al. 1993). The 

effects of grazing on sagebrush habitats in this management zone are much different than 

effects noted in the Great Basin since the landscape throughout MZ1 is adapted to withstand 

grazing disturbance (Knick et al. 2011). Historically large numbers of bison (Bos bison) moved 

nomadically through the MZ in response to changes in vegetation associated with drought, past 

grazing, and fire. Grazing by bison occurred in large areas as huge herds moved through, and 

the impacts of these herds on the vegetation, soils, and riparian areas were probably extensive. 

The interval between grazing episodes may have ranged from one to eight years (Malainey and 

Sherriff 1996). Bison were replaced with domestic livestock in the late 1800s. The intensity 

and duration of grazing in the MZ increased as domestic livestock numbers and annual grazing 

pressure increased. The high intensity grazing probably increased the density and perhaps the 

distribution of sagebrush in the MZ particularly when combined with a concurrent reduction in 

the amount of fire on the landscape. Grazing on public lands was unregulated until the passage 

of the Taylor Grazing Act in 1934. Since the passage of the Taylor Grazing Act, range 

conditions have improved due to improved grazing management practices and livestock 

operations related to decreased livestock numbers and the annual duration of grazing. In 

addition, the BLM has applied Standards for Rangeland Health since 1997 to enhance 

sustainable livestock grazing and wildlife habitat while protecting watersheds and riparian 

ecosystems. However, developments to facilitate grazing management often include elements 

detrimental to sage-grouse. Perhaps the most pervasive change associated with grazing 

management in sage-grouse habitats throughout the MZ is the construction of fencing and 

water developments (Knick et al. 2011) (Figure 3-13). Barbed wire fences contribute to direct 

mortality of sage-grouse through fence collisions (Stevens 2011) and water developments may 

contribute to increased occurrence of West Nile Virus in greater sage-grouse (Walker and 

Naugle 2011). Water developments are particularly prevalent in the north central portion of the 

MZ (Figure 3-14). Additional habitat modifications associated with grazing management 

include mechanical and chemical treatments to increase grass production, often by removing 

sagebrush (Knick et al. 2011). 

Other major land uses in the MZ include energy development (primarily oil and gas 

development), and urbanization and infrastructure. Oil and gas development in the MZ has 

occurred throughout the MZ but is concentrated in the southern portions (Powder River Basin) 

the north (Bowdoin Field) and the south and east (Williston Basin) (Figure 3-15). Oil and gas 

development includes direct loss of habitat from well pad and road construction as well as 

indirect disturbance effects from increased noise and vehicle traffic. Oil and gas developments 

directly impact greater sage-grouse through avoidance of infrastructure, or when development 
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affects survival or reproductive success. Indirect effects include changes to habitat quality, 

predator communities, or disease dynamics (Naugle et al, 2011). 

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). Much of the current oil and gas development is 

occurring on private lands with little or no mitigation efforts, which elevates the ecological and 

conservation importance of sage-grouse habitat on public lands. 

Urbanization and infrastructure development in MZ1 has also impacted greater sage-grouse 

habitat. Development at population centers and subdivisions or smaller ranchettes and 

associated buildings, roads, fences, and utility corridors has also contributed to habitat loss and 

fragmentation in portions of the MZ. Current estimates suggest about 16% of the MZ is within 

6.9 km of urban development, although MZ1 generally has lower population densities and 

lower rates of population increases compared to the other management zones (Knick et al 

2011). Infrastructure development effects to greater sage-grouse habitats in MZ1 are primarily 

related to highways, roads, powerlines and communication towers, with nearly 92% of the MZ 

within 6.9km of a road, 32% within 6.9km of a powerline and 4% within 6.9km of a 

communication tower (Knick et al. 2011) (Figure 3-16). Increased recreation and OHV use on 

lands in the MZ are also thought to impact greater sage-grouse habitats, but have not been 

studied (Knick et. al. 2011). 

The cumulative and interactive impact of multiple disturbances and habitat loss has influence 

the current distribution of greater sage-grouse in MZ1. The cumulative extent of human caused 

changes, the human footprint, on sage-grouse habitat in MZ one is highest at the northern edge 

of the MZ but occurs throughout the MZ (Leu and Hanser 2011) (Figure 3-17). Population 

centers for greater sage-grouse in MZ1 (Dohertly et al. 2011) generally correspond to areas 

lacking a 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 sagegrouse range in MZ1 is overall very similar to portions of the range where sage-grouse have 

been extirpated i.e. areas with high human footprints, mostly because of the 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 the sage-grouse range. 
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Figure 3-11 Sage-Grouse Management Zones in the Western U.S. and Canada

 (Western Association of Fish and Wildlife Agencies' Sage-grouse Conservation Planning Framework Team 2006, 

http://sagemap.wr.usgs.gov/ftp/sab/SG_MgmtZones_ver2_20061018.txt) 
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Figure 3-12 Agricultural Lands within the Sage-Grouse Conservation Area 

 (From Knick et al. 2011). Agricultural lands within the Sage-Grouse Conservation Area. Mapped land cover 

depicts primarily croplands although pasture was included in the agriculture category (Landfire 2006). 
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Figure 3-13 Linear Density of Fences on Public Lands in the Sage-Grouse Conservation 

Area 

 (from Knick et. al. 2011). Linear density (kilometers/kilometers2) of fences (estimated from allotment and pasture 

boundaries) on public lands in the Sage-Grouse Conservation Area (GIS coverages obtained from United States 

Bureau of Land Management Geocommunicator). 
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Figure 3-14 Water Developments on Lands Managed by the US Bureau of Land 

Management 

(from Knick et al. 2011). Water developments on lands managed by the US Bureau of Land Management (United 

States Bureau of Land Management Range Improvement data base). Locations of water development are recorded 

to the nearest 2.59 km2. 
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Figure 3-15 Locations of Producing Oil and Gas Wells within Sage-Grouse Management 

Zones I and II 

(from Naugle et al 2011). (A). Locations of producing oil and gas wells within sage-grouse management zones I 

and II (Connelly et al. 2004). Range of Greater Sage-Grouse (Schroeder et al. 2004) within management zones is 

shown in gray. (B). Federal mineral estate is shown in gray. Authorized leases from the federal mineral estate in 

the US and Canada are shaded black. Leases were authorized for exploration and development on or before 1 June 

2007 for each state except Utah (1 May 2007). Leases in Canada were authorized for development on or before 29 

January 2008 in Saskatchewan and 4 April 2008 in Alberta. A swath of authorized leases across southern 

Wyoming appears lighter in color because mineral ownership is mixed.
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Figure 3-16 Contoured Secondary Roads in the Sage-Grouse Conservation Area 

 (From Knick et al. 2011). Contoured secondary roads in the Sage-Grouse Conservation Area (density 

[kilometers/kilometers2] within an 18-km radius) (GIS coverages obtained from United States Census Bureau). 
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Figure 3-17 Spatial extent of Three Human-footprint-intensity Classes for the 

Conterminous US within the Current Range of Sage-Grouse and Sage-Grouse 

Management Zones 

(from Leu and Hanser, 2011). Spatial extent of three human-footprint-intensity classes for the conterminous US 

within the current range of sage-grouse and sage-grouse management zones (Stiver 2006). Human-footprintintensity classes are low (class 1–3; Leu et al. 2008), intermediate (class 4–6), and high (class 7–10). 

Predators 

Predation is one of five specific ESA listing criteria; however the USFWS did not identify 

predation as a significant threat to sage-grouse populations in their 2010 decision to list the 

species as warranted for protection under the Endangered Species Act. The USFWS 

acknowledged that increasing patterns of landscape fragmentation are likely contributing to 

increased predation on the species and identified two areas, neither in Montana [North Dakota, 

South Dakota] (southwestern Wyoming and northeastern Nevada), where predators may be 

limiting sage-grouse populations because of intense habitat alteration and fragmentation. 

Despite the USFWS document stating that predation is not a significant threat to sage-grouse 

populations in Montana [North Dakota, South Dakota], the public remains concerned about the 

influence of predators on sage-grouse conservation. 

Predators are part of the ecosystem and they have always preyed upon sage-grouse. Predators 

that prey on sage-grouse tend to be generalists that take prey opportunistically but do not focus 

solely or preferentially on sage-grouse (Hagen 2011). Predators of juvenile and adult sagegrouse are commonly coyote, red fox, American badger, bobcat, golden eagles, and several 
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other species of raptors (Schroeder and Baydack 2001; Hagen 2011). Younger birds can also 

be taken by common ravens, northern harriers, ground squirrels, and weasels. Nest predators 

include coyote, American badger, common raven and black-billed magpie (Schroeder and 

Baydack 2001; Hagen 2011). Smaller predators of sage-grouse, such as red fox or skunks, can 

also serve as prey to larger predators such as coyotes. 

Historically, predator control programs in North America were designed to protect domestic 

livestock, not wildlife (Hagen 2011). Predator control as a tool to manage grouse populations 

was rarely recommended historically, even for threatened and endangered populations in 

altered or fragmented habitats (Patterson 1952, Schroeder and Baydack 2001). It is likely the 

termination of widespread predator control in the early-1970s has influenced changes in 

predator abundance observed anecdotally by the public in recent years (Montana Sage Grouse 

Working Group 2005). Maintaining and enhancing intact ecosystems of sufficient size and 

quality to support a particular species is of greater ecological value and sustainability than an 

alternate approach that relies heavily on human intervention (e.g., artificial feeding, predator 

control, animal husbandry, zoos). The former approach works with the natural system that is 

adapted to working as an interconnected resilient network. The latter approach is costly, 

temporary, risks variable results, and is not likely to avert an ESA listing (United States 

Department of Interior 2010). 

Human altered landscapes have contributed to significant increases over historical numbers in 

some predator abundances, particularly red fox and ravens (Coates and Delehanty 2010, Sauer 

et al. 2012). The influx of predators in altered sagebrush habitat can lead to decreased annual 

recruitment of sage-grouse (Schroeder and Baydack 2001, Coates 2007, Hagen 2011). Sagegrouse in altered systems are also typically forced to nest in less suitable or marginal habitats 

where predators can more easily detect nesting birds (Connelly et al. 2004). In Strawberry 

Valley, Utah, low sage-grouse survival was attributed to an unusually high density of red fox 

that were attracted to the area by anthropogenic activity (Baxter et al. 2007). Holloran (2005) 

attributed increased nest depredation rates on sage-grouse to high corvid abundance in western 

Wyoming; the latter was influenced by anthropogenic structures associated with natural gas 

development. In the same area, Bui (2009) found ravens used road networks, fences, power 

lines, and other infrastructure associated with development. Bui et al. (2010) also detected a 

negative association between raven presence and sage-grouse nest and brood fate. Coates and 

Delehanty (2010) found increased raven density in northeastern Nevada was associated with 

decreased sage-grouse nest success, especially in areas with lower shrub density. Habitat 

fragmentation, infrastructure, weather, urban development, and improper grazing can increase 

predation pressure on sage-grouse. Sage-grouse populations demonstrate annual and cyclic 

fluctuations, which are influenced by weather patterns such as drought and the composition and 

abundance of predators (Montana Sage Grouse Working Group 2005). Montana populations 

appear to cycle over approximately a 10-year period under existing habitat conditions and the 

current combination of weather and predation (Montana Sage Grouse Working Group 2005; 

Montana Fish, Wildlife and Parks, unpubl. data). Longer term trends in sage-grouse population 

abundance and distribution can be a function of habitat loss or deterioration (Garton et al. 

2011). 

The majority of Montana’s sage-grouse populations are expected to persist over the next 100 

years, if habitat conditions remain consistent, which suggests Montana’s populations are 
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relatively stable (Garton et al. 2011). Sage-grouse are part of the sagebrush grassland 

ecosystem that comprises an interlinked web of plant and animal species, including herbivores 

and carnivores. As one of many prey species in sagebrush habitats, sage-grouse are adapted to 

predation and in unaltered systems will persist indefinitely with predation pressure (Hagen 

2011). The influence of predation on sage-grouse population dynamics only becomes a 

problem when vital rates, especially nest, chick, and hen survival, are consistently reduced 

below naturally occurring levels (Taylor et al. 2012). Naturally-occurring variability in vital 

rates is a function of annual variation in conditions (e.g., weather, vegetation cover quality, 

predator abundance) and is expected with a species that shows cyclic tendencies. Based on a 

number of research projects, reported vital rates for sage-grouse populations in Montana vary 

within range-wide estimates, suggesting predation rates are within the range of normal 

variability (Table 3-31). 

Good quality and quantity of habitat reduces predation pressure and quality habitat is essential 

for sage-grouse population stability. Predator management can provide beneficial short-term 

relief to localized sage-grouse populations where predation has been identified as a limiting 

factor for population stability. Predator control is managed cooperatively by Animal and Plant 

Health Inspection Service (U.S. Department of Agriculture) Wildlife Service, FWP, and the 

USFWS. Federal laws, such as the Migratory Bird Treaty Act and Bald and Golden Eagle 

Protection Act, limit options for managing avian predators. 

Recent predator control programs designed to benefit sage-grouse have had mixed results 

(United States Department of Interior 2010, Hagen 2011). In Strawberry Valley, Utah, fox 

removal appeared to increase adult survival and productivity but inference is limited because a 

control area was not included to compare changes in demographic rates, which were 

coincidentally increasing across the region during the study period (Baxter et al. 2007). Coyote 

control, however, appeared to have no effect on nest success or chick survival in Wyoming 

(Slater 2003). In fact, removal of coyotes can lead to a release of otherwise suppressed 

medium-sized predators, such as red fox, which tend to be more effective predators of sagegrouse nests and individuals (Mezquida et al. 2006). Ongoing control efforts of mammalian 

and avian predators (except raptors) in southwestern Colorado designed to increase recruitment 

in a small population of Gunnison’s sage-grouse may be showing some success but sample 

sizes are extremely low (5 chicks monitored/year; Colorado Parks and Wildlife, pers. comm.). 

There are 13 displaying males currently in this population and cost of monitoring and control 

has totaled $267,000 over 5 years (Colorado Parks and Wildlife, pers. comm.), bringing in to 

question the sustainability of this program. Raven removal in northeastern Nevada resulted in 

short-term reductions in raven populations; however, other individuals re-populated the vacated 

habitat within a year (Coates 2007). Badger predation may also have compensated somewhat 

for decreases in raven numbers (Coates 2007). Predation by ravens on sage-grouse in 

southwestern Wyoming was attributed primarily to territorial pairs, not groups of juveniles, 

sub-adults, and non-breeding birds (Bui et al. 2010). Thus, the removal of raven groups at 

foraging sites is unlikely to influence sage-grouse nest success, and the removal of territorial 

pairs will likely have only short-term effects until the habitat is re-occupied by a new pair. 
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Table 3-31: Sage-Grouse Vital Rates in Montana 

Vital Rate Range-wide 

Rates1 Montana Rates Years of Montana Study Location Reference

Nest success 15 – 86%

64% 1969 - 1972 Petroleum Co. Wallestad and 

Pyrah 1974

28 - 43% 2004 - 2005

Musselshell and 

Golden Valley 

Co.

Sika 2006

35 – 61% 2001 - 2003 S. Phillips Co. Moynahan et al. 

2007

53 – 61% 2007 - 2008 Milk River Basin Tack 2009

59% 2011 - 2012

Musselshell and 

Golden Valley 

Co.

Berkeley, unpubl. 

data2

Chick survival 12 – 50%

33 – 38% 2007 - 2008 Milk River Basin Tack 2009

12% 2011 - 2012

Musselshell and 

Golden Valley 

Co.

Berkeley, unpubl. 

data2

Hen survival 37 – 78%

25 – 96%3 2001 – 2003 S. Phillips Co, 

Montana

Moynahan et al. 

2006

94%

(nesting season)

84 – 93%

(late summer)

2004 - 2005

Musselshell and 

Golden Valley 

Co.

Sika 2006

55 – 91% 

(spring/summer)

84 – 92%

(over winter)

2007 - 2008 Milk River Basin Tack 2009

59% 2011 - 2012

Musselshell and 

Golden Valley 

Co.

Berkeley, unpubl. 

data

1Range-wide estimates from Connelly et al. 2011. 

2 Spring and early summer weather during 2011 and 2012 were subject to historic extremes of high precipitation in 2011 and severe drought in 2012, which 

likely affected nest and chick survival rates. 

 325% annual survival in 2003 was attributed to a WNv outbreak and severe winter conditions; annual survival in 2001-2002 averaged 96%. 

Burrowing Owl (BLM Sensitive) 

Burrowing owls are widely distributed east of the Continental Divide in Montana. They are 

typically associated with open grasslands and commonly use abandoned mammal burrows for 

nest sites. Burrowing owls are opportunistic feeders and their diet varies seasonally. There are 

several observations of burrowing owls in the field office that are closely related to the 

presence of prairie dog towns or ground squirrels. Populations appear to have declined, 

possibly due to the reduction in prairie dog populations. 
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Brewer’s Sparrow (BLM Sensitive) 

Brewer’s sparrows are sagebrush obligate species that prefer sites with high shrub cover and 

large patch size (Ashley and Stoval 2004). Their open cup shaped nests are typically found in 

live sagebrush. These sparrows occur in the planning area and were intensively studied in the 

southern BiFO area and their breeding habitat has been documented (Chalfoun 2006). 

Golden Eagle (BLM Sensitive) 

In Montana, golden eagles eat primarily jackrabbits, ground squirrels, and carrion. They 

sometimes prey on deer and antelope fawns, small mammals, waterfowl, and grouse. Golden 

eagles nest on cliffs, in large trees, or occasionally on artificial structures such as power poles. 

Golden eagles are protected by the Bald and Golden Eagle Protection Act (BGEPA). Due to 

low snow fall levels and open winters in the northern Big Horn Basin, (or southern Carbon 

County), there is documented evidence of wintering golden eagles in the area. Threats to their 

populations are disturbance to nests, power pole electrocutions, and secondary lead poisoning 

from consuming prey shot with lead bullets. 

Chestnut-collared Longspur (BLM Sensitive) 

The Montana distribution for chestnut-collared longspurs is east of the Continental Divide on 

native mixed-grass and tall and shortgrass prairies. Chestnut-collared longspurs arrive on 

Montana breeding ground in late April and first clutches are initiated in early to mid-June. 

Flocking occurs as nesting ends in mid-August, and migration begins in early September. The 

majority of Montana Natural Heritage Tracker observations are from the northern and western 

area of the field office with one in Carbon County. Only two to three observations are from 

public land, with the remaining sightings occurring on private lands. 

Loggerhead Shrike (BLM Sensitive) 

Loggerhead shrikes breed throughout much of eastern Montana in a variety of habitats such as 

grassland prairies with scattered trees, riparian areas, woody draws, or cultivated land with 

shelterbelts. In Montana grasslands and shrub steppe, loggerhead shrikes tend to select areas 

with a significant presence of shrubs and forbs (Dechant et al. 1998). Loggerhead shrikes have 

been documented in the planning area (Lenard et al. 2003). 

McCown’s Longspur (BLM Sensitive) 

Montana provides a large portion of the available breeding habitat for McCown’s longspurs. 

They can be found throughout Montana, east of the Continental Divide. There is indirect 

evidence of breeding in northern Musselshell County (Lenard et al., 2003). 

Sage Thrasher (BLM Sensitive) 

Sage thrashers are sagebrush obligate, as they are common inhabitants of shrub-steppe 

communities dominated by big sagebrush. Nest site selection is specific, as most nests are 

located in or beneath sagebrush plants with high foliage and branch density (MPIF 2000). 

Dense patches of large sagebrush plants and low densities of exotic plants also seem to be an 

important habitat characteristic for sage thrashers. Documented breeding habitat occurs in the 

planning area (Lenard et al. 2003). 
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Sprague’s Pipit (BLM Sensitive) 

In Montana, Sprague’s Pipit nest sites were in grasslands primarily with native grasses of 

intermediate height and density, with little bare ground or clubmoss and few shrubs, and in nest 

patches with greater litter cover and depth, while avoiding areas with prickly pear cactus cover 

(Map 25) (Dieni and Jones 2003). There is indirect evidence of breeding in the northern part of 

the planning area (Lenard et al., 2003) 

Ferruginous Hawk (BLM Sensitive) 

The ferruginous hawk occurs in grassland and shrublands throughout the planning area during 

the spring, summer, and fall. Ferruginous hawks often nest on the ground, lone trees, 

topographic high points, or cliffs. They typically occur in areas with abundant prey, most often 

grassland rodents and lagomorphs (Johnsgard 1990). This species is considered sensitive to 

disturbance during the nesting period, and nest sites have been documented in Musselshell 

County. 

Peregrine Falcon (BLM Sensitive) 

The peregrine falcon is a mid to large sized falcon associated with a variety of habitats during 

the spring, summer, and fall seasons. Nesting habitats for this species include cliffs, canyons, or 

other secure topographic features typically near larger water bodies and an abundant prey base. 

Peregrine falcons have five known nest sites in the planning area. Three of these sites are on 

BLM lands. This species was delisted from the federal endangered species list in 1999. 

Northern Goshawk (BLM Sensitive) 

The northern goshawk, a large bird of prey is a seasonal migrant in the planning area. Nesting 

habitats are generally in coniferous forests, and northern goshawks often forage throughout the 

forest, including aspen stands, meadows, and forest openings. The limited amount of suitable 

forested areas in the planning area indicates that few nesting northern goshawks are present. No 

known active nests occur in the planning area. 

Swainson’s Hawk (BLM Sensitive) 

The Swainson’s hawks breeds throughout Montana, generally nesting in river bottom forests, 

brushy coulees, and shelterbelts. They hunt in grasslands and agricultural areas, especially 

along river bottoms (Montana Field Guide 2011). Two nest locations were recorded during a 

raptor survey (Centmont Bioconsultants, 2005). 

Blue-gray gnatcatcher 

Breeding habitat in Montana is restricted to open stands of Utah juniper (Juniperus 

osteosperma) and limber pine (Pinus flexilis) with intermixed big sage (Artemisia tridentata). 

All nests found have occurred 0.8 to 1.7 meters above ground in Utah juniper or big sage 

growing on the lower slopes or bottoms of canyons (P. Hendricks unpublished data The 

northern Bighorn Basin that extends into Carbon County is the northern most extension of their 

breeding range (MFG, 2011).

Montana Audubon identified an Important Bird Area (IBA) in the planning area at Bear 

Canyon in the foothills of West Pryor Mountain, near the Wyoming border. The area is four 

square miles, and the Utah juniper supports breeding populations of more than a dozen species 
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Chapter 3: Affected Environment 3-101

on the Montana Priority Bird Species List. The area also has the highest known number of 

nesting blue-gray gnatcatchers among the foothill canyons in the area and the only documented 

breeding occurrence of blue-gray gnatcatchers in Montana. Refer to: 

http://www.audubon.org/bird/iba - National Audubon Society. 

Baird’s Sparrow (BLM Sensitive) 

Baird’s Sparrows prefer to nest in native prairie; however structure may ultimately be more 

important than plant species’ composition. Nesting may take place in tame grasses (nesting has 

been observed in crested wheat, while smooth brome is avoided) (Sutter 1998). This sparrow 

has also been found to use drier areas during unusually wet years and wet areas during 

unusually dry years (Casey 2000). Because a relatively complex structure is so important for 

nesting, areas with little or no grazing activity are required (MFG, 2010. 

Black Tern (BLM Sensitive) 

Black Tern breeding habitat in Montana is mostly wetlands, marshes, prairie potholes, and 

small ponds. However, several breeding locations are on manmade islands or islands in 

manmade reservoirs. Across all Montana sites where Black Terns are present, approximately 30 

percent to 50 percent of the wetland complex is emergent vegetation. Vegetation in known 

breeding colonies includes alkali bulrushes, canary reed-grass, cattail, sedge, rush, reed, grass,

Polygonum spp., Juncus spp. and Potamogeton spp., indicating a wide variety of potential 

habitats. Water levels in known breeding localities range from about 0.5 m to greater than 2.0 

m with most having depths between 0.5 m and 1.0 m (MTNHP 2003; Montana Field Guide 

[Retrieved on February 4, 2010, from http://FieldGuide.mt.gov/detail_ABNNM10020.aspx]). 

The only historic breeding records documented in the southern area of the BiFO (Lenard et al., 

2003). 

Bobolink (BLM Sensitive) 

Nests are built in tall grass and mixed-grass prairies, and this species prefers “old” hay fields 

with high grass-to-legume ratios (Montana Field Guide, [Retrieved on February 4, 2010 from

http://FieldGuide.mt.gov/detail_ABPBXA9010.aspx]). Indirect evidence of breeding in BiFO 

has also been documented (Lenard et al., 2003). 

Great Gray Owl (BLM Sensitive) 

Little specific habitat information for Montana is currently available, as systematic surveys for 

Great Gray Owls have not been done. Great Gray Owls are, however, known to use lodgepole 

pine / Douglas-fir as habitat in Montana. Habitat information from other Great Gray Owl 

sources state that their habitat is dense coniferous and hardwood forest, especially pine, spruce, 

paper birch, poplar, and second-growth, especially near water. They forage in wet meadows 

and coniferous forest and meadows in mountainous areas (Montana Field Guide [Retrieved on

February 4, 2010 from http://FieldGuide.mt.gov/detail_ABNSB12040.aspx]). Breeding records 

have been documented in the BIFO (Lenard et al., 2003). 

Red-headed Woodpecker (BLM Sensitive) 

With no systematic surveys completed in Montana, little is known about Red-headed 

Woodpecker habitat in the state. When this species have been observed, they are usually found 

along major rivers with associated riparian forest. They may also be found in open savannah 
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3-102 Chapter 3: Affected Environment

country, as long as adequate ground cover, snags, and canopy cover can be found. Large burn 

areas may also be utilized by the species (Bent 1939, Ehrlich et al. 1988; Montana Field Guide 

[retrieved on February 4, 2010 from http://FieldGuide.mt.gov/detail_ABNYF04040.aspx]). 

3.7.3.5.11 Amphibians 

An inventory of amphibians and reptiles in the BiFO was undertaken and completed in 2006. 

This inventory recorded where reptiles were located within the region (Vitt et al., 2006). This 

was the most recent inventory for herps in the Field Office, although numerous other 

observation locations are available from other sources, such as, “Amphibians and Reptiles Of 

Montana,” Werner et al. 2004. 

Great Plains Toad (BLM Sensitive) 

There is documented occurrence of this species in Yellowstone County; however inventories 

did not find adults or larvae in Carbon County (Vitt et al., 2006).

Northern Leopard Frog (BLM Sensitive) 

The northern leopard frog occupies riparian and wetland habitats and typically is found in 

cattail marshes and beaver ponds in the plains, foothills, and montane zones up to 9,000 feet 

above mean sea level in the planning area. Adults feed on tadpoles, insects, and other 

invertebrates. With the exception of the desert and foothills area west of the Pryor Mountains, 

leopard frogs occur throughout the study area (Vitt et al., 2006). 

Plains Spadefoot (BLM Sensitive) 

There are documented occurrences of plains spadefoot in 15 locations in the planning area. All 

locations consisted of open areas in and around shallow stock ponds surrounded by friable 

soils, but at significant distances from any water source (Vitt et al., 2006). 

3.7.3.5.12 Reptiles 

Greater Short-horned Lizard (BLM Sensitive) 

Lizards are typically found in sagebrush shrublands with areas of bare ground and a low 

density of sagebrush. This species was documented at six locations in the BiFO during the 

inventory (Vitt et al., 2006). 

Milksnake (BLM Sensitive) 

Milksnake habitat is typically rocky hillsides in grassland and shrubland areas. The inventory 

found seven locations for this snake in the BiFO (Vitt et al., 2006). 
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Snapping Turtle (BLM Sensitive) 

Snapping turtle occur in large rivers and adjacent ponds, lakes, and wetlands. Several records 

exist in eastern Big Horn County and one record in northeastern Yellowstone County. 

Additional trapping will be necessary to determine whether populations exist in the 

Yellowstone River farther upstream from the confluence with the Big Horn River(Vitt et al., 

2006). 

Spiny Softshell (BLM Sensitive) 

This species inhabits large rivers and water bodies and in the BiFO, they are known from the 

Yellowstone, Musselshell, and Clark’s Fork of the Yellowstone rivers. One spiny softshell 

turtle was documented in Yellowstone County (Vitt et al., 2006). 

Western Hog-nosed Snake (BLM Sensitive) 

These snakes are typically found in open habitats with friable soils (i.e., sand) along river banks 

and floodplains. A few scattered records exist in Big Horn, Stillwater, Yellowstone, and 

Musselshell counties. 

3.8 Fisheries Habitat and Special Status Species 

Management of fish species and populations in the planning area is regulated and overseen by 

the MTFWP. The USFWS is responsible for providing regulatory oversight for all species that 

are listed or proposed for listing as threatened or endangered under the Endangered Species Act 

(ESA). The BLM is charged with conserving and/or enhancing aquatic habitat and riparian 

areas on BLM administered lands, as well as protecting water quality that is necessary to 

support the fish and aquatic wildlife populations (amphibians and aquatic insects). 

The BiFO management direction is to work cooperatively with USFWS and MTFWP to 

establish programs that are consistent with ecologically sound and sustainable practices, 

conserve and enhance high quality aquatic habitat, protect native aquatic species, and enhance 

game fishing opportunities. In the planning area, the USDA Custer National Forest is also an 

integral partner in managing sensitive species on shared aquatic habitats. The continuity 

between managing fish populations and aquatic habitat requires a close working relationship 

among the agencies to be effective. 

The aquatic resources of the planning area include fish and aquatic macro-invertebrates and 

their habitats. These habitats consist of rivers and streams, springs, seeps, and lakes or 

reservoirs that provide year round (perennial) or seasonal (intermittent) habitat for a variety of 

fish species, aquatic macro-invertebrates, and aquatic plant communities (Map 26 – Red and 

Blue Ribbon Streams). Water quality is a key indicator of environmental conditions for fish and 

aquatic habitats. Other elements critical to aquatic habitat and suitable fish habitat, including 

riparian habitat, are water volume, water temperature, and the presence/absence of non-native 

competitors. The BLM uses its surveys and those done by DEQ and MTFWP to assess the 

abundance, distribution, and health of fish populations and aquatic habitat in the decision area. 

According to MTFWP surveys, 43 species of fish are present in the planning area (Table 3-32).

Of these species, 28 are indigenous and 15 species are introduced. Most are warm water species 
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that live in the lower Yellowstone and Musselshell rivers; only a few are coldwater species that 

live in the mountain streams. 

Table 3-32 Native and Non-Native Fish Species Occurring in the Planning Area 

Native Scientific Name Non-Native Scientific Name

Bigmouth buffalo Ictiobus cyprinellus Blackhead bullhead Ictalurus melas

Brassy minnow Hybognathus hankinsoni Black crappie Pomoxis nigromaculatus

Brook stickleback Culaea inconstans Brook trout Salvelinus fontinalis

Burbot Lota lota Brown trout Salmo trutta

Channel catfish Ictalurus punctatus Common carp Cyprinus carpio

Emerald shiner Notropis atherinoides Green sunfish Lepomis cyanellus

Fathead minnow Pimephales promelas Largemouth bass Micropterus salmoides

Flathead chub Hybopsis gracilis Pumpkinseed Lepomis gibbosus

Freshwater drum Aplodinotus grunniens Rainbow trout Oncorhynchus mykiss 

Goldeye Hiodon alosoides Smallmouth bass Micropterus dolomieu

Lake chub Couesius plumbeus Spottail shiner Notropis hudsonius

Longnose dace Rhinichthys cataractae White crappie Pomoxis annularis

Longnose sucker Catostomus catostomus Yellow bullhead Ictalurus natalis 

Mottled sculpin Cottus bairdi Yellow perch Perca flavescens 

Mountain sucker Catostomus platyrhynchus Walleye (unknown) Stizostedion vitreum

Mountain whitefish Prosopium williamsoni 

Northern pike Esox lucius

Northern red-bellied dace Phoxinus eos

Plains minnow Hybognathus placitus

River carpsucker Carpiodes carpio

Sand shiner Notropis stramineus

Sauger Stizostedion canadense

Shorthead redhorse Moxostoma macrolepidotum

Smallmouth buffalo Ictiobus bubalus

Stonecat Noturus flavus 

Western silvery minnow Hybognathus argyritis

White sucker Catostomus commersoni

Yellowstone cutthroat trout Onchornynchus Clarki bouvieri

Note: 

Source: 

3.8.1 Coldwater Species 

Higher elevation waters located in the Pryor Mountains and Beartooth Mountain Front support 

coldwater fish, including the Yellowstone cutthroat trout (YCT), classified as a sensitive 

species by the BLM and an S2 state classification (at risk of local extinction). The emphasis of 

BLM habitat management is to protect and enhance native species habitat, such as for the YCT 

(Maps 27, 28). In the decision area, Crooked, Bad Canyon, and Piney creeks are strongholds of 

isolated, genetically pure populations of YCT. Table 3-33 shows the total miles of fish bearing 

water in the decision area. 
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Table 3-33 Fish Bearing Streams in the Decision area 

Stream Name Miles Sensitive Species Cold/Warm

Bad Canyon Creek 5.1 YCT Cold

Bear Creek 2.4 Warm

Boulder River (MF) 0.25 Cold

Boulder River (WF) 0.5 Cold

Bridger Creek SF 2 Warm

Bridger Creek Spring 0.5 Warm

Clarks Fork River 3.85 Warm

Crooked Creek 3.5 YCT Cold

Musselshell River 0.5 Warm

Piney Creek 0.33 YCT Cold

(unnamed Creek at PP) 0.5 Sauger Warm

Sage Creek 3.78 Warm

Stillwater River 1 Cold

Willow Creek 1 Warm

Yellowstone River 18.25 Sauger/Pallid Warm/Cold

Note: 

Source: 

3.8.2 Warmwater Species 

Lower elevation streams across the planning area support a diverse population of warm water 

fish. Sauger, walleye, smallmouth bass, and channel catfish are the prized game fish of the 

system. Special status species include the BLM sensitive sauger, a rare occupant of the 

Yellowstone River and the Clarks Fork of the Yellowstone in the planning area. 

Due to the fragmented nature of BLM ownership in the planning area, fisheries management 

activities are limited to providing the best riparian conditions possible and maintaining high 

levels of aquatic and riparian protection from other resource uses, including recreation, grazing, 

and fuels extraction. State water quality laws dictate planning in these disciplines, and the BLM 

adopted Standards and Guidelines for Livestock Grazing Management help to ensure riparian 

proper functioning condition (PFC). 

Riparian vegetation is an important factor in maintaining aquatic resource conditions. Riparian 

vegetation provides in stream habitat for fish, adds structure to the banks, reduces erosion, 

moderates water temperatures, and is a source of organic nutrients for the system. Riparian 

vegetation moderates flows by reducing runoff to the stream and stores water for later release. 

As riparian habitats degrade, erosion and sedimentation increase and streams widen and 

become shallower. Temperature fluctuations increase and oxygen content can reach critically 

low levels. These factors collectively reduce or degrade available fish habitat. Protecting 

riparian habitats and restricting water quality degradation on BLM lands does not ensure 

aquatic health, because the majority of the streams are flowing through multiple ownerships 

before they reach BLM parcels. 
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The BiFO has limited aquatic resources. Fish bearing streams, lakes, and reservoirs are rare, 

with only 15 perennial fish bearing streams and no lakes or reservoirs on public lands that 

support game fish (Montana Fish Information System [MFISH] website). There are only a 

handful of reservoirs, with partial BLM ownership, that support populations of non-game fish; 

however, the Montana Fisheries Information System reports no lakes or reservoirs in the 

decision area that support sport fisheries. The small, unnamed reservoirs that support small 

non-game fish populations are not listed in Table 3-33 because they are impoundments of the 

streams that are listed. However, the importance of these resources does not diminish due to 

their limited stature, but actually increases due to the rarity. Aquatic resources (fisheries or nonfisheries related) are important natural resources, especially in the arid or semi-arid 

environments found in the planning area. Wildlife, livestock grazing, and farming are all 

dependent on water or riparian habitat, which make up a small percentage of the landscape. 

Therefore, the limiting factors of these land uses are riparian and aquatic resources. 

3.8.3 Fisheries Management 

Management of fish species and populations is regulated and overseen by MTFWP. The BiFO 

is charged with conserving and/or enhancing aquatic habitat and riparian areas as well as 

protecting water quality necessary to support fish and aquatic wildlife populations (amphibians 

and aquatic insects). Management guidance for enhancing riparian and wetland ecosystems has 

contributed to fisheries management, just as riparian health and water quality are directly 

related to fisheries health. 

Water quality is a key indicator of environmental conditions for fish and aquatic habitats. Other 

elements critical to aquatic habitat and suitable fish habitat, including riparian habitat, are water 

volume, water temperature, and the presence/absence of non-native competitors. The BLM uses 

its surveys and those done by DEQ and MTFWP to assess the abundance, distribution, and 

health of fish populations and aquatic habitat in the planning area. 

Some native fish species populations and habitats have declined in the past due to natural 

disturbances (drought), habitat alteration, poor water quality, lack of water quantity, and 

hybridization with or competition from with non-native species. 

3.8.4 Non-Native Invasive (Nuisance) Aquatic Species 

Aquatic Nuisance Species (ANS) are non-indigenous plant or animal species that threaten 

diversity and abundance of native species, the ecological stability of aquatic systems, or 

commercial, agricultural, and recreational activities dependent on said systems. 

MTFWP has assembled and prioritized a list of aquatic nuisance species that are either 

established in Montana or have a high potential to invade Montana waters. MTFWP has also 

developed the Aquatic Nuisance Species Management Plan (2002) which addresses prevention 

of invasion, mitigation of impacts for species already present, and other measures to control 

ANS. There are currently 26 species of plants and animals on the MTFWP ANS list (Table 

3-34) with only 7 listed as present in Montana. Priority classes are defined below. 
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 Priority Class 1 – These species are not known to be present in Montana, but 

have a high potential to invade and there are limited or no known management 

strategies for these species. Appropriate action for this class includes prevention 

of introductions and eradication of pioneering populations. 

 Priority Class 2 – These species are present and established in Montana and 

have the potential to spread further and there are limited or no known 

management strategies for these species. These species can be managed through 

actions that involve mitigation of impact, control of population size, and 

prevention of dispersal to other water bodies. 

 Priority Class 3 – These species are not known to be established in Montana 

and have a high potential for invasion and appropriate management techniques 

are available. Appropriate management for this class includes prevention of 

introductions and eradication of pioneering populations. 

 Priority Class 4 – These species are present and have the potential to spread in 

Montana but there are management strategies available for these species. These 

species can be managed through actions that involve mitigation of impact, 

control of population size, and prevention of dispersal to other water bodies. 

Table 3-34 Aquatic Nuisance Species in the Planning Area 

Species

Common Name Scientific Name Priority Class

Fish

Big Head Carp Hypophthalmichthys nobilis 1

Grass Carp Ctenoparyngodon idella 1

Black Carp Mylopharyngodon piceus 1

Silver Carp Hypophthalmichthys molitrix 1

Round Goby Neogobius melanostomus 1

Ruffe Gymnocephalus cernuus 1

Tench Tinca tinca 1

Zander Sander lucioperca 1

Northern Snakehead Channa argus 1

Crustaceans

Rusty Crayfish Orconectes rusticus 1

Spiny Waterflea Bythotrephes cederstroemi 1

Molluscs

Zebra Mussel Dreissena polymorpha 1

New Zealand Mud Snail Potamopyrgus antipodarum 2

Mammals

Nutria Myocastor coypus 1

Parasites / Pathogens

Whirling disease Myxobolus cerebralis 2

Heterosporosis 1

IHN Virus 1

Asian Tapeworm Bothriocephalus acheilognathi 3

Plants
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3-108 Chapter 3: Affected Environment

Species

Common Name Scientific Name Priority Class

Egeria Egeria densa 1

Hydrilla Hydrilla verticillata 1

Eurasian Watermilfoil Myriopyllum spicatum 3

Curley Pondweed Potamogeton crispus 4

Flowering Rush Butomus umbellatus 4

Purple Loosestrife Lythrum salicaria 4

Salt Cedar Tamaricaceae spp. 4

Yellow Flag Iris Iris pseudacorus 4

Note: 

Source: MTFW; (http://fwp.mt.gov/fishing/guide/ANS/priorityClasses.html)

All the species listed above can have profound ecological impacts, generally disrupting the 

natural food chain or impairing ecosystem and native species health. Riparian systems and 

water bodies are vulnerable to nuisance species invasion due to the transport of boats, road 

runoff, human associated activities, and other mechanisms. The spread of nuisance species is 

usually rapid and hard to control because of the connectivity and movement associated with 

rivers and aquatic systems in general. 

3.8.5 Fisheries Special Status Species 

Special status species are species listed as threatened or endangered under the Endangered 

Species Act (ESA), species proposed or candidates for listing, species designated as sensitive 

by BLM, and state listed species. These species require particular management attention due to 

population or habitat concerns. Rules and regulations describing BLM requirements in 

managing Special Status Species are described in Section3.7.3.3 (Wildlife Special Status 

Species) page 3-74. 

The BiFO is responsible for managing fisheries habitat in the decision area, while management 

of fish species is overseen by state and federal wildlife management agencies. The MFWP 

manages resident fish populations. The USFWS provides regulatory guidance for all fish 

species that are listed or proposed for listing under the ESA. 

Fisheries habitat includes perennial and intermittent streams, lakes, and reservoirs that support 

fish through at least a portion of the year. Fisheries habitats in the planning area encompass 

portions of six large watersheds: the Bighorn River, Boulder River, Clark’s Fork of the 

Yellowstone River, Musselshell River, Yellowstone River, and the Stillwater River. 

Special status species are native taxa that are at risk due to declining population trends, habitat 

threats, restricted distribution, and other factors. Three special status fish species have been 

identified in the planning area, the Northern Redbelly X Finescale Dace, the sauger, and the 

YCT. 
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3.8.5.1 Northern Redbelly X Finescale Dace (BLM Sensitive) 

This fish was placed on the special status species list due to its rarity and unusual form of 

genetic reproduction (MFISH). In Montana, northern redbelly dace are fairly widespread east 

of the Continental Divide. Finescale dace have been found in the Milk River drainage in the 

Cypress Hills, just north the Canadian border, well removed from the planning area (MFISH). 

Further inventory is needed to better define Phoxinus spp. distribution in Montana. Due to 

difficulties of field differentiation, it is likely that some waters thought to contain only northern 

redbelly dace may also have the hybrid. Phoxinus spp. is not extremely common in Montana. 

Dr. Robert Bramblett (MFISH) has conducted surveys on 43 prairie streams of the Missouri 

and Yellowstone rivers and identified Phoxinus spp. at just three sites, one of which contained 

the hybrid. Few prairie streams in Montana have the clear pool-type habitat preferred by this 

hybrid. Due to the limited distribution and knowledge of this species, it is important to reduce 

impacts to its known habitat. In the Billings Field office decision area, eight streams have been 

identified with populations of this species. The streams do not fall in the decision area, however 

drainage from BLM administered lands do contribute to some of the streams. Managing for 

healthy riparian areas and quality water resources on BLM managed public lands will help to 

reduce impacts on the Northern Redbelly X Finescale Dace populations should they occur in 

the decision area (www.fisheriessociety.org/AFSmontana/RedbellyHybrid.html).

3.8.5.2 Sauger (BLM Sensitive)

Sauger populations throughout Montana have fallen dramatically. In the main stem of the 

Yellowstone River, distribution is now considered limited to downstream of Rosebud Creek 

and is rare or absent in other portions of the river and its major tributaries. 

Sauger, known to be a migratory species, is heavily dependent on unimpeded access to the 

wide diversity of physical habitats present in large river systems. The Yellowstone River 

system has many barriers impeding fish passage, some in the main stem and many throughout 

the tributaries. The need to travel throughout a system to find suitable habitats for various life 

stages, coupled with competition from non-native walleye (Sander vitreum), are likely the two 

dominating factors in the sauger’s decline. BLM ownership and influence on the main stem 

Yellowstone and Clarks Fork of the Yellowstone rivers is fragmented. For example, of 147 

Yellowstone river miles in the planning area, BLM manages 18.55 miles, the majority of which 

is limited to small stretches of a single river bank. The Billing Field Office has little influence 

over the factors that impact sauger viability, with managing for overall watershed health being 

the primary objective to provide functioning riparian conditions and quality water resources 

(www.fisheriessociety.org/AFSmontana/Sauger.html).

3.8.5.3 Yellowstone Cutthroat Trout (BLM Sensitive) 

In its historical range, this subspecies is considered a species of special concern or a sensitive 

species by many state and federal agencies and organizations. In 1998, it was petitioned for 

listing as a threatened species under the ESA; however this petition was rejected in February 

2001 (Maps 27 and 28). 
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YCT numbers have declined in distribution and abundance throughout its range. A survey of 

biologists (AUTHOR 1996) concluded that in Montana, YCT occupied 32 percent of their 

historical range. Most remaining indigenous populations in Montana inhabit headwater streams 

and the upper Yellowstone River. It is also estimated that only 10 percent of the historically 

occupied fluvial habitat still contains genetically pure populations (May 1998). 

(www.fisheriessociety.org/AFSmontana/Yellowstone.html) 

Non-native fish species are generally considered the greatest threat to the persistence of YCT. 

Displacement of native fish species by brown trout, brook trout, and hybridization with 

rainbow trout have been thoroughly documented in the region. Habitat fragmentation from 

irrigation diversion, culvert barriers, and other manmade obstacles has also contributed to the 

downfall of YCT. 

In the past decade, several projects have been designed to specifically enhance sensitive fish 

species populations on public lands in the planning area. 

3.8.5.3.1 Bad Canyon Creek 

The BLM partnered with MTFWP and the Custer NF to stabilize and enhance a fish barrier on 

Bad Canyon Creek. The barrier would isolate a genetically pure YCT population in BLM and 

FS waters, blocking the upstream passage of non-native brown trout that thrive in lower Bad 

Canyon Creek and the Stillwater River. 

3.8.5.3.2 Crooked Creek 

In 2007, the BLM partnered with MTFWP and the Custer NF to protect eight miles of pristine 

YCT habitat from invasion by non-native brown trout which are present in the lower reaches of 

Crooked Creek. The project included an engineered barrier designed to block fish passage and 

withstand 100 year flood events for an indefinite time. A subsequent MTFWP project removed 

all brown trout from the isolated reach, allowing the aboriginal YCT population to expand 

uninhibited from non-native competition. 

3.8.5.3.3 Piney Creek 

The MTFWP and BLM began planning a project on the BLM administered Piney Creek waters 

to enhance pool and over wintering habitat for an imperiled, isolated population of YCT. This 

population is limited to approximately 11⁄4 miles of cold, clean spring water that runs from the 

Custer NF through BLM and private land and then onto state land, where it is diverted into an 

irrigation system. Barring dewatering and upstream pollution sources, riparian health is the 

most significant limiting factor to aquatic resources and good water quality. 

To manage fish and special status fish species habitat, the Bureau of Land Management follows 

guidelines from land planning efforts and regulatory plans and guidance established: 

Best management practices, state, and federal guidance concentrate on protecting riparian 

habitat and function as well as water quality. A clear establishment of the importance of 

riparian health is critical in understanding the connectivity between riparian vegetation, water 

quality and quantity and fisheries resources. 
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3.9 Wild Horses and Pryor Mountain Wild Horse Range 

The wild horse and burro program is unique to the BLM as it is the only program where the 

BLM is responsible for both the land resources and the animal. Perhaps no other program 

within the BLM receives as much public interest and scrutiny than the wild horse and burro 

program. The health, nutrition, and well-being of the animals are closely watched and criticized 

by numerous individuals and organizations interested in wild horses. These groups present 

unique opportunities for cooperative and collaborative partnerships as well as manufacturing 

controversy. 

The Billings Field Office is home to one herd of wild horses located within the Pryor Mountain 

Wild Horse Range (PMWHR). The PMWHR is located approximately 50 air miles south of 

Billings, Montana and nine air miles northeast of Lovell, Wyoming. It occupies an area of 

37,494 acres in northern Big Horn County, Wyoming and southeastern Carbon County, 

Montana. 

The exact origin of the wild horses within the PMWHR is not entirely known, though there is 

much supposition. Many claim the horses are descendants of animals the Crow or Shoshone 

Indians got from the Spanish or other tribes in contact with the Spanish. The Crow had horses 

in the early 1700s and inhabited the Pryor Mountains before European settlement. Others claim 

the horses have been there forever. Wild horses within the Bighorn Basin were well 

documented by the early 1900s. Most likely, the wild free-roaming horses inhabiting the 

PMWHR are descendants of numerous founding stock. 

Genetic tests conducted between 1992 and 2009 by Dr. Gus Cothran identified the Pryor horses 

as descendants of New World “Spanish” breeds (saddle type horses) descendent from light 

riding and racing breeds and related to European Iberian breeds. The Pryor horses carry a rare 

allele variant Qac that is traced back to original New World “Spanish” type horses that were 

developed from the original Spanish and Portuguese (Iberian) horses that were brought to the 

Americas. This has resulted in confirmation by many members of the public that this is a 

unique herd of wild horses and fears that this herd and its genetic make-up could be lost. Wild 

horses from other wild horse herds were periodically introduced, but this practiced ended in the 

early 1990s. 

Generally, wild horse use tends to shift with forage and water availability and elevation 

accessibility. Wild horses tend to live in bands or older horses may live solitary. The typical 

band is led by one dominant mare that controls the day to day activities, unless the stallion feels 

threatened and moves the band out of an area. A band can range in size from one mare and one 

stallion to numerous mares and one stallion with their progeny. A bachelor band is typically 

comprised of young males (though older males may join which have lost their band) that are 

not yet mature enough to build a band and defeat rival stallions for mares or steal a mare. 

Typically but not exclusively young males tend to be displaced from the family band upon 

reaching breeding age. 

The PMWHR (Map 29 – Pryor Mountain Wild Horse Range) is a diverse and complex area; 

topographically, geologically, ecologically and land tenure. It varies in environment and 

elevation from a sagebrush/salt-shrub dominated cold desert at about 3,850 feet in the 

Wyoming portion, to a subalpine setting with subalpine fir and open meadows in at the 
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northernmost portion within Montana at about 8,750 feet. The majority of the range within 

Montana is a semi-arid cold desert. The area is composed of private, United States Forest 

Service, National Park Service, and BLM administered lands (see Appendix Q regarding 

Montana administration of the Wyoming portion of the PMWHR). There are several 

overlapping designations, including all or portions of three BLM WSAs, one NPS WSA, and 

one Forest Service recommended wilderness. The other designations are the East Pryor ACEC 

and the Crooked Creek Natural Area. There are numerous sensitive plants and animals, rare 

geologic formations, numerous caves, vertebrate and invertebrate fossil beds, high occurrence 

of archeological resources and American Indian spiritual sites. The area is highly prized for 

(non-wild horse related) recreational activities. As a result, special management considerations 

are required to address resource conflicts, be consistent with other agencies’ policies or plans, 

and conform to regulations and laws. 

The PMWHR was initially designated by order of the Secretary of the Interior in 1968 

(Appendix Q). At that time, the PMWHR encompassed BLM and NPS lands only within 

Montana. In 1969, another Secretarial Order added approximately 6,400 acres of lands (both 

BLM and NPS) in Wyoming to the PMWHR. In December 1971, the Wild Free-Roaming 

Horses and Burros Act became law. The management and protection of all unclaimed wild 

horses and burros was delegated to the secretaries of the Interior and Agriculture. The BLM 

and USFS were charged with administration of the Act. In 1974 and 1975, the range was 

expanded pursuant to authority contained in the Wild and Free-Roaming Horses and Burros 

Act which directed the BLM and Forest Service to manage wild horses “where presently 

found.” (Map 30 – Herd Area Map) 

Adjustment to the range occurred once again in 1984 with the temporary inclusion of the 

Sorenson Extension (using two five year special use permits) from the Bighorn Canyon 

National Recreation Area (BCNRA) and closure of the administrative pastures for gathering 

purposes. 

In 1990, the last adjustment occurred when the Sorenson Extension was not reauthorized by 

BCNRA. This resulted in the present boundary that encompasses 37,494 acres (24,595 acres of 

this area is BLM administered lands). 

3.9.1 Population and Resource Management 

The BiFO protects, manages, and controls wild horses within the PMWHR under the authority 

of the 1971 Wild Free-Roaming Horses and Burros Act (as amended by Congress in 1976, 

1978, and 2004). One of the BLM’s key responsibilities under the Wild and Free-Roaming 

Horse and Burro Act (as amended) is to manage for a “thriving natural ecological balance”

(TNEB). This mandate is typically achieved by balancing the wild horse population within the 

available resources through the appropriate management level (AML) to protect the range from 

deterioration while maintaining multiple-use relationships.

The long term average population of wild horses has been 159 wild horses. The population has 

varied from 87 wild horses to 195 wild horses. In 1978 an ice storm and limited forage 

resources resulted in a large die-off resulting in the lowest documented population wild horses. 

Gathers and removals have been the most widely used tool to achieve a TNEB. Removals 

historically have occurred on average every other year. Over 600 wild horses have been 
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removed from the PMWHR since its establishment. Once an animal is removed it is typically 

offered for adoption. Every wild horse removed from the PMWHR has been placed. 

Since 2001 fertility control has been utilized. Fertility control vaccine has been applied from a 

total of 5 mares in a year to currently 70-80% of the mare population. In 2003 and 2004 there 

was a loss of the nearly the entire foal crops. This has been attributed to predation and to poor 

forage production from drought that may have resulted in low milk production of lactating 

mares. The absolute cause was not definitively determined. 

The Pryor Mountain Herd Management Plan (HMAP) (HMAP, BLM-MT-PT-84-019-

4321/June 1984) and the Billings Resource Area Management Plan (September 28, 1984) 

established an initial stocking rate (appropriate management level) for the range at 115-127 

wild horses. The 1984 HMAP also identified managing for “Pryor characteristics”, which 

include aspects such as selection for a younger herd or even sex ratio. The HMAP was revised 

in July 1992 and re-established the appropriate management level (AML) at 85-105 adult 

horses (MT-025-2-18). 

The PMWHR HMAP and Environmental Assessment issued May 2009 made a management 

shift to focus on habitat enhancement through range projects (waters, fences and riparian), and 

management of vegetative communities. The population management would utilize gathers, 

fertility control, and natural controls to maintain an appropriate management level (AML) of 

90-120 wild horses (excluding foal crop). Within the population itself the management focus is 

to conserve traits, genetic diversity, maintaining Spanish characteristics, and bloodlines within 

the herd. 

A wild horse population above the appropriate management level (AML) resulted in the same 

areas of the PMWHR being over-utilized annually. The result is deterioration of range 

resources and reduced carrying capacity of the land. Conversely mid-slope areas, within the 

PMWHR have remained relatively un-impacted by wild horse grazing. Many areas of the 

PMWHR are unavailable for grazing due to slope (cliffs) or provide little or no forage due to 

the type of ecological site potential such as the mountain mahogany belt and the Douglas-fir 

forest. If the PMWHR had uniform use the potential carrying capacity in 1984 was determined 

to be 179 wild horses. Since that time in 2004 the potential carrying capacity was determined to 

be 142 wild horses a reduction in potential capacity of 37 wild horses or 444 animal unit 

months. (Map 29 – Pryor Mountain Wild Horse Range) 

3.10 Cultural and Heritage Resources 

Cultural resources are definite locations 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 may include definite locations (sites or places) of traditional, cultural, or 

religious importance to specified social and/or cultural groups. Cultural resources are concrete, 

material places and things that are located, classified, ranked, and managed through the system 

of identification, protection, and utilization for public benefit. 

Cultural resources are assessed for integrity or as having unique qualities that make the 

resources eligible for the National Register of Historic Places (NRHP), which provides for 
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management and protection of these resources. There are three main standards that a cultural 

resource must meet to qualify for listing on the NRHP: age, integrity, and significance. To meet 

the age criteria, the resource generally must be at least 50 years old. To meet the integrity 

criteria, the resources must possess integrity of location, design, setting, materials, 

workmanship, feeling, and association. Finally, the resources must be significant according to 

one or more of the following criteria: 

 Criterion A – Be associated with events that have made a significant 

contribution to the broad patterns of our history; or 

 Criterion B – Be associated with the lives of persons significant in our history; 

 Criterion C – Embody the distinctive characteristics of a type, period, or 

method of construction, or represent the work of a master, or possess high 

artistic values, or represent a significant and distinguishable entity whose 

components may lack individual distinction; or 

 Criterion D – Have yielded, or may be likely to yield, information important in 

prehistory or history. 

3.10.1Cultural History Overview 

The Billings Field Office planning area is situated within the area known as the Northwestern 

Plains, although portions of the area also include the eastern slope of the Rocky Mountains 

(Beartooth Range) and several island mountain ranges, including the Pryor Mountains, Crazy 

Mountains, Big Snowy Mountains, Little Snow Mountains, and Bull Mountains. The prehistory 

and history of the Northwestern Plains generally include five cultural periods: Paleoindian, 

Middle Prehistoric, Late Prehistoric, Protohistoric, and Historic. Within the prehistoric periods 

are various complexes, phases, and sub-phases. 

3.10.1.1 Paleoindian (11,500 B.P. to 7,500 Before Present [B.P.]) 

Paleoindian groups were nomadic and traveled over large areas to hunt big game (e.g., 

mammoth) using heavy thrusting or throwing spears tipped with stone points. Climatic 

conditions during the early part of the period were cooler than today, but became warmer and 

possibly drier towards the end of the period. Populations were small and sites were occupied on 

a short-term basis. Dominant projectile point styles appear to have been a number of large, 

concave-based, lanceolate forms. Some of the points were fluted. Several point types have been 

named (Clovis, Folsom, Goshen, Midland, Plainview), and cultural complexes or phases often 

have been named on the basis of the point style. During the end of the Paleoindian period, the 

development of two separate economic strategies begins to appear on the Northwestern Plains. 

One included broad-spectrum hunting and gathering in the mountains while the other was a 

communal bison hunting pattern on the open plains. 

3.10.1.2 Middle Prehistoric (7,500 B.P. to 1,800 B.P.) 

The early part of the Middle Prehistoric (8,000 to 5,500 B.P.) occurred during a relatively dry 

climatic episode referred to as the Altithermal. Early Middle Prehistoric populations moved 
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into mountain, foothill, and river valley regions where resources were abundant and tended to 

concentrate in areas with dependable water sources. Subsistence strategies generally are similar 

to late Paleoindian groups, with an emphasis on big game hunting. Projectile point styles 

generally are smaller than Paleoindian forms and often incorporated broad side notches. A 

significant technological innovation, the spear thrower or atlatl, replaced thrusting spears 

during the early Middle Prehistoric. 

During the middle of the period (5,500 B.P. to 3,000 B.P.) groups began to adopt increasingly 

specialized subsistence and settlement strategies. The regional climate shifted from the hot and 

dry conditions of the Altithermal to the Sub-boreal climatic episode of cool and moist 

conditions. The improved climatic conditions led to increased resource availability, which in 

turn led to increases in the number of sites and an expansion in geographical distribution to 

access seasonal resources. Prehistoric people of this time exploited big game such as bison, elk, 

and bighorn sheep, and smaller animals such as foxes, birds, and rabbits. Grinding slabs and 

manos, in addition to roasting pits and cooking hearths, indicate an increase in plant resources. 

Projectile points take on a range of forms from the un-notched McKean lanceolate to sidenotched, corner-notched, and corner-removed Duncan and Hanna variants. 

Cool and wet conditions associated with the Sub-altithermal climatic episode occurred during 

the transition to the late Middle Prehistoric (3,000 B.P. to 1,800 B.P.). Settlement and 

subsistence strategies are similar to the middle period, with bison as the main focus of hunting. 

The atlatl and dart remain as the weapon of choice, but McKean complex points are replaced 

by several varieties of corner-notched styles associated with the Pelican Lake complex. Near 

the end of the late Middle Prehistoric, medium to large side-notched projectile points associated 

with the Besant complex begin to replace Pelican Lake forms. Besant people developed highly 

specialized communal hunting techniques and also were the first cultural group to have 

constructed and used ceramic vessels. Groups continued to occupy river valley and foothill 

settings, while also devoting more time and attention to the prairies. This change of focus is 

illustrated by the adoption of communal hunting techniques and development of the tipi. 

3.10.1.3 Late Prehistoric Period (1,800 B.P. to 200 B.P.)

The Late Prehistoric Period is characterized by an increased specialization toward upland living 

and utilization of open prairie resources, including bison and pronghorn. Prehistoric 

populations lived in the upland areas for most of the year, specifically on bluff edges and high 

terraces overlooking river or creek valleys. Smaller social groups or family units used lowlands 

and forested areas for shorter intervals to collect plants and gather wood for tipi poles, and for 

quarrying and seasonal hunting. At this time, the introduction of the bow and arrow occurs, as 

well as a more widespread though still relatively rare use of pottery. 

Cultural complexes associated with this period are Avonlea and Old Womens. During the 

Avonlea (1,450 B.P. to 950 B.P.), the use of the bow and arrow became more widespread, with 

an increased focus on bison as a primary resource. Communal bison hunting was the main 

economic pursuit of Avonlea people, and bison trapping in thaws, breaks, and corrals were 

favored strategies. Avonlea points have low and very shallow side notches and typically have 

concave bases. 
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The basic adaptation of the Old Womens phase (1,050 B.P. to 200 B.P) was an extreme 

specialization on upland living and communal hunting of upland game animals, principally 

bison. Old Womens points are side notched, but corner-notched, tri-notched, and un-notched 

styles also are present. Groups using Old Womens points still carried out special purposes and 

activities in lowland resources and locations; but the vast majority of sites are in open upland 

spots, which indicate a commitment to year-round occupation. The use of tipis is more common 

during this phase compared to the Avonlea phase. 

3.10.1.4 Protohistoric Period (200 B.P. to 50 B.P.)

The Protohistoric Period is characterized by non-Indian immigration, trade of European items 

(e.g., glass beads, brass pendants, musket balls), and the introduction of the horse and guns. Of 

all the trade items, the horse had the greatest impact on Native American cultures. With 

acquisition of the horse, groups were not tied to upland living for their main subsistence, which 

led to larger winter villages in lowland valleys. The increased opportunity to chase bison herds 

on horseback also led to a decline in communal bison drives. 

The main subsistence strategy during this period still was bison hunting, but other options were 

available. Trading for goods and transporting goods by horse allowed for economic 

opportunities not previously possible to the tribes. Trapping and fur trading also became a 

subsistence alternative for some tribal groups. Guns were available through the trading posts 

established along many of the major rivers; however, a muzzle-loading firearm was difficult to 

reload on horseback, so the bow and arrow was used more often for hunting. During this time, 

metal points replaced many of the previous stone projectile points. 

3.10.1.5 Historic Period (A.D. 1700 to the present)

The Historic Period distinguishes itself from previous periods with the introduction of mining, 

railroads, homesteading, farming, and ranching. A relatively large influx of people to the area 

also occurred during this time, as well as a concentrated land use that initially involved 

agricultural activity. Early expeditions and campaigns that mapped the land did so in order to 

provide a guide for land expansion and to expand communication and commerce to the Pacific 

Coast. Early missionaries and the Lewis and Clark expedition were followed by trappers, 

traders, pioneers, miners, and homesteaders. This focus on land ownership and intensive use of 

the environment dramatically changed the landscape. Consequently, the native populations 

became displaced and eventually were moved onto reservations. 

The Homestead Act of 1862 offered free government land to all American citizens and 

provided farmers with 160 acres of land for a filing fee after fulfilling a five-year period of 

“proving-up.” Contrary to the advertisements, the soil was poor and the seasons were dry. As a 

result, irrigation was necessary. New techniques for dry farming allowed for some farming and 

ranching success; however, most ranches and farms required large amounts of water, which 

resulted in the development of dams and diversions to supply water for these industries. 

Various phases of homesteading acts and land offerings continued to draw people into the area. 

In 1869, the first transcontinental line (Union Pacific-Central Pacific) traveled over the old 

Oregon-California Trail. The rail line facilitated movement west and transport of goods east; it 

also put more pressure on the land to provide goods for markets. A total of 44 million acres 
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were granted to the railroad. Of those, 17 million were in Montana territory, making the 

railroad the second largest landowner in the state after the federal government. Since railroads 

were granted large tracts of land for construction purposes, the railroad companies sold these 

tracts off to businesses and individuals interested in settling the area. Many banks and land 

holding companies bought large tracts of railroad land, and in turn sold them to prospective 

farmers. In September 1877, five bands of Nez Perce fleeing the U.S. Army passed through the 

planning area followed by several elements of the U.S. Calvary. 

The need for oil and gas soon developed, and in Montana many of the earliest discoveries did 

not result from drilling, but rather by witnessing natural oil seeps. The first significant oil field 

in the planning area was discovered in 1915. In addition, small coal mines and fields were 

opened in the area to accommodate mining industries, and then later for the coal-fired, steampowered railroads. Coal is now Montana’s leading energy resource. Currently, these industries 

are the primary users of the land, along with growing tourism and residential use. 

3.10.2 Site Types 

Cultural resources in the planning area have been classified according to one or more site types. 

Site types are groupings of sites with similar physical or cultural characteristics. Complete 

information may not be readily available during the original recordation to determine the 

functional or cultural site type. Consequently, some sites may be re-categorized after additional 

research. Sites fitting into more than one category usually are more complex and have more 

information potential than do single-category sites. At the broadest level, cultural resources are 

categorized as either prehistoric or historic. 

3.10.2.1 Prehistoric Site Types

Prehistoric sites can be associated with one or more broad thematic periods: Paleoindian, 

Middle Prehistoric, Late Prehistoric, and Protohistoric. There are prehistoric sites within the 

planning area from each period. Table 3-35 lists the prehistoric site types documented in the 

planning area. 

Table 3-35 Prehistoric Site Types

Site Type Description

Tipi Ring, Stone Circles, 

and Ring Sites

This is a relatively common site type in the planning area and includes circles of stones 

interpreted as having been used to hold down tipi lodge covers. Tipi rings are conjoining stones 

in circular to ovoid configurations. Some large circles or ovals, which may not actually represent 

domestic lodges, may be evidence of medicine lodges, dance lodges, and other ceremonial or 

specialized structures. 

Conical Timber Lodge Conical timber lodges are often stand-alone structures made of a ring of upright poles around a 

central post with wood and bark inlayed between the uprights. Few artifacts typically are 

associated with the lodge and the use of the lodge is unknown. 

Lithic Scatters/Chipping 

Stations

The term “lithic scatter” is very broadly applied to a range of sites containing stone cultural 

material. These may be sites representing the remains of limited chipped stone tool 

manufacture or repair, generally viewed as having temporary or short-term use and low 

information value, or sites with a greater variety of artifacts, features, and attributes, as well as 

unknown depositional characteristics. 
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Table 3-35 Prehistoric Site Types

Site Type Description

Fire Hearths, Roasting 

Pits, and Fire-cracked 

Rock

Those sites with any combination of these features include lithic scatters and tipi ring sites. 

Hearths are remains of a feature where humans purposely used fire. This includes clay or rocklined fire pits, ash pits, roasting pits, ash stains, and fire-cracked rock concentrations or 

scatters.

Cairns and Rockpiles This site type includes piles of rocks ranging in size from a few stones to larger cairns up to 

three meters in diameter. The function of cairns and rockpiles has not been clearly 

demonstrated; however, some argue that larger cairns may have served as ceremonial or other 

important functions such as burials and trail markers, and to commemorate people or events. 

Functions of smaller cairns are even less apparent, though clusters of cairns may represent 

effigies. 

Rock Alignments Rock alignments generally are linear, straight to curving arrangements of piled stone and of 

various lengths. Some alignments are known to be part of communal animal kill sites and are 

referred to as drive lines which were used to steer animals in the direction of the kill site. The 

function of other shorter linear alignments is not clear. 

Communal Kill Sites These sites are noted as ambush game drives, buffalo jumps, bison pounds or traps, or other 

kill sites including processing areas. The sites primarily are defined by the occurrence of high 

numbers of animal bone, generally in a bone bed, and a high density of hunting and butchering 

tools in the artifact assemblages. 

Vision Quest Structures 

and Medicine Wheels

Vision quest sites and medicine wheel sites are considered linked to ceremonial and religious 

activities. The sites typically are a u-shaped or oval stone feature forming low enclosures. 

Vision quest sites often are found on prominent parts of the landscape, such as mountains, 

bluffs, hills, cliffs, rock outcrops, and buttes. Medicine wheels also are structures constructed of 

piled and placed stones and have at least two of the three general elements: 1) a central stone 

cairn; 2) one or more concentric stone circles; and/or, 3) two or more stone lines radiating 

outward from a central point. 

Eagle Catching Pits/Traps, 

Battle Pits, Other Pits, 

Lookouts, and 

Fortifications

These site types are defined by reference to the ethnographic and ethnohistoric record, which 

constitutes the basis of their inferred function. Descriptions of eagle-catching techniques also 

are recorded in ethnographies and ethnohistoric documents, and their descriptions often are 

used to infer function of some features based on form and location. 

Lithic Procurement 

Sites/Quarries

Lithic procurement sites are classified under the site type headings of bedrock or surface 

quarry. Bedrock quarries are defined by the existence of bedrock exposures at the sites; 

whereas, surface quarries are defined by areas where lithic material occurs as “free rock” in 

cobble, nodular, or pebble form. Primary chert quarries tend to be located along the sides of 

mountains where the material is found in outcrops. Any material that was carried into an area by 

a natural agent is a secondary quarry, such as basalt found in ancient and present-day river 

beds. 

Rockshelters/Caves Rockshelters consist of a rock outcrop or large boulder that provides shelter from wind, sun, 

rain, and other elements. 

Rock Art Sites Aboriginal rock art sites include petroglyphs (incised or pecked images) and pictographs 

(painted images). Rock art is found on rock outcrops, cliffs, or rock shelters, but also is found on 

irregular boulders that range in size from a half meter to several meters in diameter. 

Other Rock Structures,

Circular Walls

Piled, stacked, or placed stone features described as unusual or unlike known feature types are 

included in this category. Features described as possible rings, circles, or vision quests also are 

included in this category. 

Trails Documentation of actual use of a trail or trail system during prehistoric time is difficult, and 

evidence used to support such use is often circumstantial. Documented use of a trail during 

historic times often is used to argue use during the prehistoric times. Some linear arrangements 

of cairns may mark trail systems. Linear clusters or concentrations of archaeological sites along 
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Table 3-35 Prehistoric Site Types

Site Type Description

prominent landforms (e.g., high ridges, river valleys) may indicate prehistoric trail use. 

3.10.2.2 Historic Site Types 

Historic sites are cultural resources with a period of significance between approximately 

A.D.1700 to the present. Since features such as ditches, fences, and houses cannot be 

understood or interpreted outside the functional complex of which they are a part, historic 

resources are grouped into several themes. Table 3-36 lists the historic site types documented in 

the planning area. 

Table 3-36 Historic Site Types 

Site Type Description

Ranching The ranching theme includes features resulting from the raising of domestic livestock, such as 

fences, water developments, cabins, corrals, outbuildings, roads, foundations, cattle camps, and 

sheepherder monuments. 

Farming The farming theme includes features resulting from raising crops, such as wells, windmills, 

barns, sheds, cisterns, farm implements, canals, ditches, and residences.

Mining The mining theme includes features resulting from exploration and extraction of mineral 

resources such as shafts and adits, drill sites, prospect holes, tailing dumps, waste rock piles, 

ore bins, loading chutes, residences, and other buildings.

Transportation The transportation theme includes features resulting from attempts to transport people or goods, 

such as abandoned rail lines, railroad grades, construction camps, bridges, roads, trails, and 

remains of river navigation.

Government Management The government management theme includes features resulting from government attempts to 

manage the land and its resources. Many of these features are the result of Civilian 

Conservation Corps activities in the 1930s. These include dams, fences, land treatments or 

manipulations, spring developments, roads, fire lookouts, culverts, and bridges.

Military The military theme includes features resulting from increased conflicts with native populations 

and trafficking of trade goods, such as military fort sites, supply depots, and fur trading posts.

3.10.3 Cultural Resource Existing Conditions 

A total of 1,072 cultural resources inventories have been conducted within the planning area 

covering 335,363 acres (approximately 4.5 percent of the planning area). These inventories 

include Class I (files search) and Class III (pedestrian) inventories, site testing, evaluation of 

NRHP eligibility, and mitigation of adverse effects through data recovery or other forms of 

mitigation. Most recently, the BLM completed a Class I overview of the planning area that 

reviewed and summarized past cultural resources investigations, the numbers and kinds of 

recorded resources, and cultural resources management directions (Harris et al. 2009). The 

information presented in this section is primarily derived from the Class I overview. 

Investigations to date have recorded a total of 3,255 cultural resource sites within the planning 

area. This results in an average of 0.009 total sites for approximately every acre inventoried or 
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6.3 sites per square mile for all inventoried acres in the planning area. Of the 3,255 sites, 1,440 

are prehistoric and 1,775 are historic. The distribution of the prehistoric sites recorded in the 

planning area averages 0.004 sites per every acre surveyed or 2.8 sites per square mile 

inventoried. Lithic scatters are the most numerous prehistoric site type followed by tipi ring 

sites and then petroglyphs. For historic sites, the average is 0.005 sites per acre inventoried or 

3.4 sites per square mile inventoried. The most common historic site types include residences 

followed by homesteads/farmsteads, railroads/stage routes, and Euroamerican sites. 

Of the 3,255 cultural resources sites recorded in the planning area, a total of 846 sites are 

located on BLM-administered lands. Site density is 5 sites per square mile. The dominant 

historic site types include homesteads/farmsteads, followed by Euroamerican sites, 

railroads/stage routes, and residences. For prehistoric sites, lithic scatters are the dominant site 

type with petroglyphs a distant second. 

3.10.3.1 Cultural Resource Condition and Trend 

The condition and trend of cultural resources in the decision area vary considerably as a result 

of the diversity of terrain, geomorphology, access and visibility, and past and current land use 

patterns. Since recorded sites are manifested by discovery of exposed artifacts, features, and/or 

structures, they are easily disturbed by natural elements such as wind and water erosion, natural 

deterioration and decay, as well as animal and human intrusion, and development and 

maintenance activities. Based on limited site monitoring, the site conditions in the decision area 

are considered to be trending downward. Indications of active vandalism or collecting (i.e., 

unauthorized digging and “pothunting”) have been observed in limited instances. 

Archaeological and historic sites are known to be deteriorating from a variety of causes. Many 

sites are deteriorating from natural causes and many others from the illegal activities of artifact 

collectors. Inadvertent damage from construction projects also impacts resources. Collectively, 

these agents have adversely affected and continue to adversely affect many known cultural 

resources. 

3.10.3.2 Cultural Resource Consultation and Current Management

Section 106 of the National Historic Preservation Act (NHPA) of 1966, as amended, requires 

BLM and other federal agencies to take into account the effects of their undertakings on 

historic properties (i.e., cultural resources listed or eligible for listing on the NRHP), and afford 

the Advisory Council on Historic Preservation (ACHP) a reasonable opportunity to comment. 

The historic preservation review process mandated by Section 106 is outlined in regulations 

issued by the ACHP. The BLM first determines whether an action is an undertaking, which is 

defined in Section 106 as a type of activity that could affect historic properties. If the 

undertaking has the potential to affect historic properties, the BLM must consult with the State 

Historic Preservation Office (SHPO) to determine the effects and develop appropriate 

mitigation. If BLM determines that the undertaking would not affect historic properties, then 

the agency has no further Section 106 obligations. 

The BLM National Programmatic Agreement (NPA) among the BLM, ACHP, and National 

Conference of SHPOs defines the manner in which the BLM will meet its responsibilities under 

the NHPA. Day-to-day operations are based on the protocols that local BLM offices develop in 
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each state. In Montana, the State Protocol Agreement between the BLM and Montana SHPO 

defines how the BLM and SHPO will interact and cooperate under the NPA and provides 

direction for implementing the NHPA. The BLM 8140 Manual also provides direction for 

protecting cultural resources from natural or human-caused deterioration and for recovering 

significant cultural resource data to mitigate adverse effects of proposed undertakings, in 

accordance with the State Protocol Agreement. 

3.10.4 Native American Concerns 

Ethnographic resources are associated with the cultural practices, beliefs, and traditional history 

of a community. Examples of ethnographic resources include places in oral histories or myths, 

such as particular rock formations, the confluence of two rivers, or a rock cairn; large areas, 

such as landscapes and viewscapes; sacred sites and places used for religious practices; social 

or traditional gathering areas, such as dance areas; natural resources, such as plant materials or 

clay deposits used for arts, crafts, or ceremonies; and places and natural resources traditionally 

used for non-ceremonial uses, such as trails or camping locations. 

3.10.5 Ethnographic Overview 

Tribes that historically occupied the planning area are believed to have entered the area during 

the Protohistoric Period. American Indian tribes likely present in the planning area during this 

period include the Cheyenne, who had reached the Black Hills by about 1780 and continued to 

move westward into eastern Montana. The Cheyenne originally were woodland dwellers and 

later became semi-sedentary agricultural people associated with the ancestors of the Mandan, 

Arikara, and Hidatsa. Later, the Cheyenne moved westward and became nomadic buffalo 

hunters on the plains. In the mid-1830s, the Cheyenne divided into northern and southern 

groups. The Southern Cheyenne split off to trade European goods with whites at Bent’s Fort in 

southeast Colorado, while the Northern Cheyenne formed an alliance with the Sioux and 

engaged in battles against the Shoshone and Crow. 

Other American Indian groups at times occupied portions of the planning area during the 

Protohistoric Period including the Eastern Shoshone, who occupied eastern Montana during the 

1600s and 1700s. By the 1700s, the Gros Ventre and Arapaho were in western North Dakota 

and likely ranged through extreme eastern Montana. By the 1750s, the Gros Ventre and 

Blackfeet acquired the horse and guns and began pushing the Eastern Shoshone southward. 

With acquisition of the horse, the Blackfeet also ventured into the northern part of the planning 

area. The Kiowa were present in the Black Hills area in the 1500s, but eventually were 

pressured southward and westward by the Cheyenne, Arapaho, and Lakota Sioux. By 1790, the 

Kiowa had moved well south of the planning area into the Arkansas River area. 

The Crow tribe has the strongest association with the planning area, which lies within their 

traditional homeland. In the 1500s, the Crow and their close relatives, the Hidatsa, moved west 

to the Missouri River in present-day North Dakota. Around 1600, the Crow separated from the 

Hidatsa and entered into what is now Montana. The Crow occupied the Powder and Tongue 

River valleys, as well as the Yellowstone valley as far west as present-day Livingston. By the 

1800s, the Crow were divided into the River Crow, who lived north of the Yellowstone River 
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in the Musselshell and Judith basins, and the Mountain Crow, who occupied the area south of 

the Yellowstone, particularly the Absaroka and Big Horn mountains. 

One reservation, the Crow Indian Reservation, is adjacent to the planning area. Most members 

of the Crow tribe live on or near the reservation. The Crow Indian Reservation covers 2.2 

million acres between the Wolf, Bighorn, and Pryor Mountains. U.S. Census and Tribal 

Enrollment records indicate there are 11,357 enrolled tribal members. Of these tribal members, 

8,143 live on the reservation. Area schools, the tribal administration, the Bureau of Indian 

Affairs, Crow/Northern Cheyenne Indian Health Services, and private business are the primary 

employers on the reservation. The tribe itself owns a number of stakes in natural resources, 

including land, sand, gravel, water, timber, coal, oil, and methane gas. 

3.10.6 Traditional Cultural Properties 

3.10.6.1 Background 

This plan differentiates among prehistoric cultural resources, historic cultural resources, and 

tribal heritage resources. Planning for historic and prehistoric cultural resources is discussed in 

other sections of this plan. This section deals with tribal heritage resources as defined under 

various authorities, including but not limited to the Federal Land Policy Management Act, the 

American Indian Religious Freedom Act, Executive Order 13007, the Native American Graves 

Protection and Repatriation Act, and the National Historic Preservation Act. Under these 

authorities, the BLM has the responsibility for managing tribal heritage resources, in part, by 

considering them in land use planning and environmental documentation, and mitigating, 

where possible, impacts to places or resources important to contemporary American Indians 

and federally recognized tribes. 

Slight differences in definitions among the authorities notwithstanding, these resources can be 

generally defined as places or resources associated with cultural practices or beliefs of a living 

community that are rooted in a tribal community’s oral traditions or history, and are important 

in maintaining the continuing cultural identity of the community. In practice, this means 

identifying, evaluating, and managing: a) ethnohistoric sites, b) traditional use areas, c) sacred 

sites and ceremonial sites, and d) traditional cultural properties. 

Since tribal heritage resources are defined culturally by the people and groups that value them, 

these resources can only be identified and managed in consultation with the people infusing 

them with cultural value. In the final analysis and decision making, BLM has the legal 

authority to determine how these resources will be managed and what, if any, mitigation will be 

used to avoid unnecessary or undue impacts to these resources. 

3.10.6.2 Tribal Consultation

As defined in BLM Manual section 8120, Tribal Consultation is a process of 1) identifying and 

seeking input from appropriate tribal governing bodies, 2) considering their issues and 

concerns, and 3) documenting the manner in which the input affects the specific management 

decision(s) at issue. Federally recognized tribal governments with interests in the planning area 

include the Blackfeet Nation, the Chippewa Cree Tribe, the Comanchee Tribe, the Crow Tribe, 
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the Fort Belknap Indian Community (Assiniboine and Gros Ventre), the Fort Peck Tribes 

(Sioux and Assiniboine), The Kiowa Tribe, the Northern Cheyenne Tribe, the Three Affiliated 

Tribes: Mandan, Hidatsa, and Arikara, the Spirit Lake Sioux Tribe, the Standing Rock Sioux 

Tribe, the Turtle Mountain Band of Chippewa, the Lower Brule Sioux Tribe, the Rosebud 

Sioux Tribe of Indians, the Oglala Sioux Tribe, the Eastern Shoshone Tribe, and the Northern 

Arapahoe Nation. In areas near the Nez Perce (Nee-Me-Poo) National Historic Trail 

(NPNHT), the following three tribes associated with the Nez Perce have interests in the 

planning area; Nez Perce, Confederated Tribes of the Umatilla Indian Reservation, and the 

Confederated Tribes of the Colville Indian Reservation.

It is important to note that consultation is a good faith effort to identify tribal issues, seek tribal 

input, and consider the result. There is no requirement for the Billings Field Office to do more 

than this and no requirement for tribes to respond to Billings Field Office’s consultation efforts. 

The legal requirements of NEPA and other authorities seek information on many areas of tribal 

knowledge (cultural, religious, or traditional) that are highly confidential and not readily 

revealed to outsiders. At the land use planning level, tribes are reluctant to share information 

when they cannot see a direct threat to places and resources they value. These, and other 

factors, limit the available information on specific locations that could benefit from 

management attention. As a result, the Billings Field Office must base management on limited 

information, resulting in a more programmatic approach to prescribing management actions on 

the basis of sites and resource types. 

3.10.6.3 Traditional Cultural Properties

The concept of traditional cultural property has created confusion when dealing with tribal 

heritage resources because it is commonly used to refer to all types of tribal heritage sites in all 

legal contexts. The term traditional cultural property was coined in National Register Bulletin 

38 to refer to a property that may be eligible for inclusion in the National Register because of 

its association with cultural practices or beliefs of a living community that: a) are rooted in that 

community’s history, and b) are important in maintaining the continuing cultural identity of the 

community (Parker and King 1989). Places that may be of traditional cultural importance 

include, but are not limited to: a rural community whose organization, buildings and structures, 

or patterns of land use reflect the cultural traditions valued by its long-term residents; locations 

associated with the traditional beliefs of an American Indian group about its origins, cultural 

history, or the nature of the world; or locations where American Indian religious practitioners 

go, either in the past or the present, to perform ceremonial activities based on traditional 

cultural rules or practice (Parker and King 1989) and 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. 

Bulletin 38 has been interpreted to mean that all tribal heritage sites are traditional cultural 

properties and by definition eligible for the National Register. However, the Bulletin does not 

assert that all traditional cultural properties are eligible and it describes a process by which they 

can be determined to be eligible. In fact, the 1992 amendment to the National Historic 

Preservation Act clarified policy so that “properties of traditional religious and cultural 

importance to an Indian tribe may be determined to be eligible for inclusion on the National 

Register.” Although the term traditional cultural property is not found in the National Historic 
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Preservation Act, or its implementing regulations, it has become important for determining 

eligibility for compliance with Section 106 of the National Historic Preservation Act. 

There are regulatory limitations on the National Register eligibility (such as the requirement 

that a property be a definite location of human activity; with discernible exact boundaries; and 

be at least 50 years old) that limit its value in a general planning context. Because of this, the 

concept of traditional cultural properties will be used here only when tribes have specifically 

identified a resource as a traditional cultural property. This is not to say that the resources 

discussed here are not eligible for the National Register and thus not subject to Section 106 of 

the National Historic Preservation Act. They may well be eligible even if not identified as a 

traditional cultural property by a tribe and subject to Section 106 as a traditional cultural 

property. 

Within the decision area, several locations that are of traditional religious and cultural interest 

to tribes have been identified through coordination with tribal governments and American 

Indian individuals with cultural affinity to the decision area. None of the locations were 

specifically identified as traditional cultural properties and none have been determined eligible 

for the National Register as traditional cultural properties through consultation with the State 

Historic Preservation Office. These same locations may meet other criteria as significant 

ethnohistoric sites, or they may deserve consideration under the American Indian Religious 

Freedom Act, Native American Graves Protection and Repatriation Act, or Executive Order 

13007. No traditional cultural properties have been nominated but the lack of nomination does 

not preclude such nominations being advanced in the future. 

Properties that have achieved significance only within the 50 years preceding their evaluation 

are not eligible for inclusion in the NRHP unless “sufficient historical perspective exists to 

determine that the property is exceptionally important and will continue to retain that 

distinction in the future.” This is an extremely important criteria consideration with respect to 

traditional cultural values. The fact that a property may have gone unused for a lengthy period 

of time, with use beginning again only recently, does not make the property ineligible for the 

NRHP. 

A Traditional Cultural Property is eligible for the NRHP only if it meets one or more of the 

National Register criteria. However, traditional cultural properties are usually listed under 

Criterion A or occasionally Criterion B for their association with historical events or broad 

patterns of events. Recognizing a place as eligible for the NRHP as a Traditional Cultural 

Property or as anything else, does not change its significance, it merely requires that the 

significance and value of the property be systematically considered in planning and in 

consultation with those who value it. 

No extensive search was made to identify traditional communities other than American Indian; 

however, no Traditional Cultural Properties have been identified from other communities. 

3.10.6.4 Traditional Cultural Properties Existing Conditions

Within the decision area, several geographic locations have been identified through 

coordination with tribal governments; however, the geographical locations either do not meet 

the NRHP eligibility criteria for Traditional Cultural Properties or they have not been 
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evaluated. These geographic locations may meet other criteria as significant ethnohistoric sites, 

or they may deserve consideration under the American Indian Religious Freedom Act, Native 

American Graves Protection and Repatriation Act, or Executive Order 13007 (Sacred Sites). 

No Traditional Cultural Properties have been formally documented and/or evaluated within the 

decision area. 

3.10.6.5 Traditional Cultural Properties Condition and Trend 

Since there are no Traditional Cultural Properties formally documented and/or evaluated within 

the decision area, no information on condition or trend of such properties is available. 

3.11 Paleontological Resources

The BLM has authority to manage and protect paleontological resources under the 

Paleontological Resources Preservation Act (PRPA) of 2009 (P.L. 111-011 Title VI Subtitle 

D). PRPA directs the BLM to manage, protect, and preserve paleontological resources using 

scientific principles and expertise as well as provide for public education and awareness, 

scientific research, curation, and other proactive efforts. 

With the passage of PRPA, the BLM now has official direction from Congress to manage 

paleontological resources. Prior to this, the BLM’s Paleontological Resource Management 

policy was guided by internal policies and directives (that were subject to change) and 

governed by vague language in NEPA (1969) and FLPMA (1976). The BLM’s Paleontological 

Resource Management policy, which pre-dates PRPA, is outlined in Manual Section 8270 and 

Handbook H-8270-1. Some portions of the documentation are superseded by BLM Instruction 

Memorandums: specifically IM 2008-009 supersedes Handbook section II.A.2 and IM 2009-

011 supersedes Handbook sections III.A and III.B. 

Paleontological resources are defined in the Paleontological Resources Preservation act as “any 

fossilized remains, traces, or imprints or 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...,”

excluding archaeological and cultural resources (P.L. 111-011, Title VI, Subtitle D, Section 

6301 et. seq.). The distribution of paleontological resources is directly related to the distribution 

of sedimentary geologic units exposed on the ground surface, and this relationship allows 

prediction of fossil potential on a formation-wide scale. 

The term “fossil” refers to the remains of traces of an organism preserved by natural forces in 

the earth’s crust. It does not include what are commonly known as “fossil fuels” such as coal, 

bitumen, lignite, or tar sands. Fossils are integrally associated with specific geologic formations 

and may occur throughout those formations. For this reason, the condition of paleontological 

resources is directly linked to soil and landform stability. 

A 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 2: 

Paleontological Resources (Hanna 2009) was written as part of this RMP/EIS. This Class I 

overview of paleontological resources reviewed published literature and museum records forms 

as the primary foundation for the paleontological overview. 
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3.11.1Paleontological Overview 

Paleontological resources consist of fossil-bearing rock formations containing information that 

can be interpreted to provide a further understanding about Montana’s past. Fossil-bearing rock 

units underlie the entire planning area. While fossils are relatively rare in most rock layers, 

there are seven geologic rock units within the planning area that do contain significant fossil 

material. Rock units that are known to contain fossils are the Tullock and Ludlow Members of 

the Fort Union Formation, the Judith River, Hell Creek, Morrison and Cloverly Formations, the 

Lakota Sandstone Formation, and the White River Group. 

The Morrison, Hell Creek, Cloverly, and Lakota Sandstone formations are noted for the 

occurrence of dinosaur fossils. The Bridger Fossil Area ACEC, a 575-acre site located in 

Carbon County on BLM administered surface, contains outcrops of both the Cretaceous Period 

Cloverly Formation and the Jurassic Period Morrison Formation. Outcrops of the Morrison 

Formation within the Bridger Fossil Area ACEC have yielded the fossil remains of numerous 

juvenile and subadult sauropods. The Bridger Fossil Area ACEC is one of two listed National 

Natural Landmarks within the Billings Field Office area. 

The Judith River Formation preserves the fossil record from ancient environments including 

shallow oceans, deltas, rivers, freshwater swamps and lakes. The Judith River Formation 

contains the fossil remains of plants as well as many animal species including mollusks, fish, 

amphibians, lizards, small mammals, dinosaurs, and other reptiles. 

The Cretaceous Period Hell Creek Formation preserves the fossil record of a subtropical to 

tropical environment that was characterized by low plains interrupted by broad swampy 

bottoms and deltaic areas. Fossil remains from the Hell Creek Formation include a wide variety 

of plants, mollusks, fish, amphibians, reptiles, birds, small mammals, and dinosaurs. Fossil 

dinosaur remains include Triceratops, Anatosaurus, and Tyrannosaurus. The fossil record of 

plant and animal communities found within the Hell Creek Formation varies between low 

moist areas and the drier, upland plains environments that were present in the past. The Castle 

Butte ACEC, located in Yellowstone County within the Billings RMP area, contains outcrops 

of the Hell Creek Formation, which are noted for their paleontological resources. 

The contact between the Cretaceous Period Hell Creek Formation and the Paleocene 

Tullock/Ludlow Member of the Fort Union Formation marks an important event in time. This 

contact represents a time of worldwide extinction for many animals, most notably the 

dinosaurs, and the beginning of the rapid evolution of mammals. The fossil record from the 

Fort Union Formation contains evidence of ancient environments that include streamside 

swamps, bottomlands, and well-established river courses. Fill within ancient river channels 

contains fossils of fresh water clams and snails. The Tullock/Ludlow Member is the primary 

fossil-bearing unit of the Fort Union Formation and contains fossils of turtles, fish, reptiles and 

mammals. 

The Tertiary Period White River Group is considered an important source of fossil mammals. 

Although the White River Group outcrops in the planning area, the majority of the fossilbearing areas are in the Dakotas. 
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3.11.2The Fossil Record 

A fossil is defined as the remains, trace, or imprint of a plant or animal that has been preserved 

in a geologic context. With proper collection and study, paleontological resources allow the 

reconstruction of past life on Earth. Fossilization is the exception rather than the rule, and 

fossils are inherently rare. 

3.11.2.1 Vertebrate Fossils

Vertebrate fossils can occur as isolated elements, bonebeds, or individual skeletons. Isolated 

elements are by far the most common and include complete to partial bones and teeth. 

Bonebeds are concentrations of vertebrate remains (bones and teeth) in a discrete geologic 

layer. They can contain a wide variety of species or predominantly one species, and remains 

can be disarticulated, partially articulated, or fully articulated. 

Microvertebrate concentrations are also called vertebrate microfossil localities or “microsites.”

Microsites are concentrations of small pieces of disarticulated material that are usually more 

resistant to weathering and transport (e.g. teeth, scales, scutes, and compact bone). 

3.11.2.1.1 Vertebrate Trace Fossils 

According to BLM definitions, vertebrate trace fossils are considered to be vertebrate remains: 

“Vertebrate Fossil remains and traces include bone, scales, scutes, skin impressions, burrows, 

tracks, tail drag marks, vertebrate coprolites, gastroliths (stomach stones), or other physical 

evidence of past vertebrate life or activities.” Eggshells and eggs have also been classified as 

vertebrate trace fossils. 

3.11.2.2 Nonvertebrate Fossils 

Nonvertebrate fossils can occur alone or in association with vertebrate remains, and include 

invertebrates, plants (paleobotanicals), and nonvertebrate trace fossils. Plant fossils occur as 

leaf compressions and impressions, petrified wood, seeds, cones, spores, pollen, and amber. 

Nonvertebrate trace fossils include plant casts and molds (e.g. root casts, seed molds) and 

invertebrate traces. 

3.11.2.3 Paleontological Localities 

A total of 501 paleontological localities are documented to occur in the Billings Field Office 

planning area. The paleontological resources occur in all counties, and the 501 documented 

localities are distributed as follows: 
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 Big Horn, Montana = 3 

 Big Horn, Wyoming = 31 

 Carbon = 240 

 Golden Valley = 15 

 Musselshell = 45 

 Stillwater = 8 

 Sweet Grass = 65 

 Wheatland = 69 

 Yellowstone = 25 

Land ownership is known for 446 of the 501 documented paleontological localities, which is as 

follows: 

 BLM = 184 

 BLM/private = 13 

 State = 17 

 State/private = 5 

 Private = 227 

Legal descriptions for the remaining 55 localities were either unavailable, unknown, or could 

not be determined. The majority of paleontological documented in the Billings Field Office 

planning area for which land ownership is known occur on private surface ownership. 

Of the 501documented paleontological localities, 380 are vertebrate fossil localities and 121 are 

nonvertebrate (invertebrate or paleobotanical) localities. Some vertebrate localities may also 

contain invertebrate, paleobotanical, or trace fossil material. 

3.11.2.4 Potential Fossil Yield Classification

The Potential Fossil Yield Classification (PFYC) system (WO-IM-2008-009) is used to classify 

paleontological resource potential on public lands in order to assess possible resource impacts 

and mitigation needs for federal actions involving surface disturbance, land tenure adjustments, 

and land-use planning. This classification system is based on the potential for the occurrence of 

significant paleontological resources in a geologic unit and the associated risk for impacts to 

the resource based on federal management actions. It uses geologic units as base data. 

The PFYC system predicts the potential occurrence of paleontological resources based on the 

distribution of geologic units. This is possible because the potential for paleontological 

resources is directly related to the distribution of sedimentary geologic units exposed on the 

ground surface. Consequently, this relationship allows the prediction of fossil potential on a 

formation –wide scale. Each formation contains its own suite of fossil types, and can be 

classified according to its potential fossil yield as Class 1, Class 2, Class 3, Class 4, or Class 5 

(Table 3-37). 
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Table 3-37 Potential Fossil Yield Classification 

PFYC Class Potential

Class 1 Very Low Potential for Paleontological Resources

Class 2 Low Potential for Paleontological Resources

Class 3 Moderate (3a) or Unknown Potential (3b) for Paleontological Resources

Class 4 High Potential for Paleontological Resources

Class 5 Very High Potential for Paleontological Resources

Assignment of these classes provides a foundation for general management decisions and new 

project planning, by indicating what level of management concern is warranted. The PFYC 

system can also be used to predict if proposed projects should include paleontological resource 

assessment or mitigation. Table 3-38 breaks out the PFYC acres for the planning area, BLM 

administered surface, and BLM administered federal mineral estate (also see Map 35). 

Table 3-38 Potential Fossil Yield Classification Acres 

Class 1 Class 2 Class 3a Class 3b Class 4 Class 5

PFYC Acres Billings Field Office 

Planning Area 582,841.7 2,814,621.8 2,463467.0 399,230.5 162,746.4 4,207,664.2

PFYC Acres BLM Administered Surface 8,349.4 110,430.9 62,696.4 20,421.7 10,941.5 216,910.6

PFYC Acres BLM Administered Federal 

Mineral Estate 46,754.5 143,442.5 125,503.2 37,115.3 18,939.4 297,154.5

The potential for paleontological resources is directly related to the distribution of sedimentary 

geologic units exposed on the ground surface, and this relationship allows prediction of fossil 

potential on a formation-wide scale. Sedimentary geological deposits of Precambrian 

(Proterozoic Period), Paleozoic (Cambrian, Ordovician, Devonian, Mississippian, 

Pennsylvanian, and Permian periods), Mesozoic (Triassic, Jurassic, and Cretaceous periods), 

and Cenozoic (Tertiary and Quaternary periods) age occur within the BLM Billings Field 

Office planning area boundaries. Each geologic unit contains it own suite of fossil types, and is 

classified according to its paleontological potential using the BLM’s Potential Fossil Yield 

Classification (PFYC) system. These classes provide a foundation for general management 

decisions, and new project planning, by indicating what level of management concern is 

warranted (Table 3-39).
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Table 3-39 Geologic Formations Present in the Planning Area

Formation Age Formation Name

Management 

Concern

Potential Fossil Yield 

Classification

Precambrian Belt 

Supergroup

Helena Formation Moderate Class 3

Wallace Formation Very low Class 1

Cambrian

Flathead Formation Low Class 2

Wolsey Formation Moderate Class 3

Meagher Formation Moderate Class 3

Park Formation Moderate Class 3

Pilgrim Formation Moderate Class 3

Snowy Range Formation Moderate Class 3

Grove Creek Formation Moderate Class 3

Ordovician Bighorn Dolomite Moderate Class 3(b)

Devonian

Maywood Formation High Class 4

Three Forks Formation Moderate Class 3

Beartooth Butte Formation High Class 4

Jefferson Limestone Moderate Class 3(b)

Mississippian

Charles Formation Low Class 2

Kibby Formation Low Class 2

Mission Canyon Formation Moderate Class 3

Lodgepole Formation Moderate Class 3

Otter Formation Moderate Class 3

Heath Formation Very High Class 5

Pennsylvanian

Amsden Group Moderate Class 3

Alaska Bench Formation Moderate Class 3(b)

Devils Pocket Formation Low Class 2

Quadrant (Tensleep) Formation Low Class 2

Permian Phosphoria Formation High Class 4

Triassic

Chugwater Formation Low Class 2

Dinwoody Formation Moderate Class 3

Jurassic

Ellis Group (undivided) High Class 4

Piper (Gypsum Spring) Formation Moderate Class 3

Rierdon (lower Sundance) Formation High Class 4

Swift (upper Sundance) Formation Moderate Class 3(b)

Morrison Formation Very High Class 5

Cretaceous

Cloverly/Kootenai Formation Very High Class 5

Fall River Sandstone Moderate Class 3(a)

Greenhorn Formation Low Class 2
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Proposed Resource Management Plan and Final Environmental Impact Statement 

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Table 3-39 Geologic Formations Present in the Planning Area

Formation Age Formation Name

Management 

Concern

Potential Fossil Yield 

Classification

Carlile Formation Moderate Class 3

Thermopolis Shale High Class 4

Mowry Shale Moderate Class 3(a)

Telegraph Creek Formation Moderate Class 3(b)

Livingston Group Moderate Class 3

Belle Fourche Shale Moderate Class 3(a)

Cretaceous

(continued)

Frontier Formation Moderate Class 3

Niobrara Formation Moderate Class 3(a)

Eagle Sandstone Moderate Class 3(a)

Claggett Shale Moderate Class 3(a)

Judith River Formation Very High Class 5

Bearpaw Shale Moderate Class 3(a)

Hell Creek (Lance) Formation Very High Class 5

Lennep Formation Moderate Class 3

Tertiary

Sedimentary deposits High Class 4

Wasatch Formation Moderate Class 3(a)

Fort Union Formation High Class 4

Quaternary-Tertiary Terrace deposits Moderate Class 3

Quaternary

Alluvium Moderate Class 3

Glacial deposits Low Class 2

Glacial lake deposits Moderate Class 3(a)

Cave deposits High Class 4

3.11.2.5 Paleontological Resource Condition and Trend

Paleontological localities are areas of known paleontological resources with defined 

boundaries, usually associated with excavation and data recovery efforts (e.g., Mother’s Day 

Site, Crooked Creek Natural Area, Crooked Creek Natural Area National Natural Landmark, 

Bridger Fossil Area ACEC, and Bridger Fossil Area National Natural Landmark). A 

comprehensive paleontological inventory has not been carried out for the decision area; 

nevertheless, academic and private industry personnel have studied paleontological resources in 

various contexts. At least 40 groups and institutions from the 1850s to present have collected 

fossils in the planning area. Fossils recovered from these localities represent a diverse array of 

paleobotanicals, invertebrates, and vertebrates. Scientific activity has occurred during the past 

several years, and there are currently active paleontological use permits issued for the public 

lands in the planning area. 
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The BLM identifies the following use or value categories for paleontological sites: scientific, 

educational, and recreational. BLM permit requirements emphasize the scientific value of 

vertebrate remains, and a permit is required for collection of vertebrate remains and trace 

fossils. In addition, a permit is required for the collection of scientifically significant 

invertebrate and plant paleontological resources. In conjunction with their scientific use, some 

educational uses of vertebrate fossils are appropriate. For example, many BLM Paleontological 

Resources Use Permit holders involve students during data collection, specimen recovery, and 

preparation. Federally owned fossils can also be used in exhibits or as teaching aids. All 

paleontological resources remain federal property whether in situ or in a museum collection. 

Collection of any paleontological resources on BLM managed public lands cannot occur 

without a permit. The exception is for casual collecting of common invertebrate and plant 

paleontological resources on BLM managed lands for recreational purposes. Casual collecting 

is defined by the PRPA as the collecting of a reasonable amount of common invertebrate and 

plant paleontological resources for non-commercial personal use, either by surface collection or 

the use of non-powered hand tools resulting in only negligible disturbance to the earth’s surface 

and other resources. However, some fossilized nonvertebrates and plants are rare or 

exceptionally preserved and require a permit for collection. 

Potential threats to paleontological resources include natural erosion, and various 

anthropogenic activities, such as ground disturbance and illegal collection/excavation. 

3.11.2.6 Paleontological Resource Management on Public Lands

The increasing economic value of fossils puts paleontological resources on public lands at risk, 

and unauthorized collection of vertebrate fossils is becoming more common. The badlands of 

Montana are remote and rugged, and public lands in these areas are often targeted by 

unauthorized collectors. The scientific integrity of paleontology is compromised more every 

year, as specimens are often hastily excavated and permanently removed from the scientific 

realm, ending up in private collections. As the sale of fossils continues and their economic 

value increases, there is a heightened urgency for protection and management of 

paleontological resources on public lands. Fines for theft of public property ($500) have not 

been much of a deterrent for illegal collection activities on public lands. However, recent 

passage of the PRPA should help deter such activities, as it standardizes and significantly 

increases criminal penalties for theft of fossils from federally owned lands and provides for 

civil penalties concurrently. 

3.12 Visual Resources 

The management system for visual resources begins with a process which evaluates landscapes 

according to three factors: scenic quality/visual appeal, sensitivity/public concern for scenic 

quality, and distance from the observer. 

It is important to note that Visual Resource Management (VRM) is based on human 

perceptions and expectations in the context of the existing landscape. In order to meet its 

responsibility to maintain the scenic values of the public lands, BLM has developed a VRM 

system that addresses the following: 
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Chapter 3: Affected Environment 3-133

 Different levels of scenic values require different levels of management. For example, 

management of an area with high scenic value might be focused on preserving the 

existing character of the landscape, and management of an area with little scenic value 

might allow for major modifications to the landscape. Determining how an area should 

be managed first requires an assessment of the area’s scenic values. 

 Assessing scenic values and determining visual impacts can be a subjective process. 

Objectivity and consistency can be greatly increased by using the basic design elements 

of form, line, color, and texture, which have often been used to describe and evaluate 

landscapes, to also describe proposed projects. Projects that repeat these design 

elements are usually in harmony with their surroundings; those that don’t create 

contrast. By adjusting project designs so the elements are repeated, visual impacts can 

be minimized. 

While there are BLM guidelines for the visual resource inventory (BLM Manual H-8410-1) 

and determining visual contrast ratings (BLM Manual 8431), the guidance provided is general 

in nature in order to enable application to different ecosystems and social climates. The 

inventory and management of visual resources addresses BLM Administered Surface Lands 

only. 

3.12.1Visual Resources Management 

Once inventoried, Landscapes are then placed into one of four VRM classes to determine 

appropriate techniques and strategies for maintaining visual quality, each of which has its own 

management objectives: 

Class I Objective: The objective of this class is to preserve the existing character of the 

landscape. This class provides for natural ecological changes; however, it does not preclude 

very limited management activity. The level of change to the characteristic landscape should be 

very low and must not attract attention. It would be very difficult to get a new project approved 

in this class, unless it is completely shielded from view. 

Class II Objective: The objective of this class is to retain the existing character of the 

landscape. The level of change to the characteristic landscape should be low. Management 

activities may be seen, but should not attract the attention of the casual observer. Any changes 

must repeat the basic elements of form, line, color, and texture found in the predominant 

natural features of the characteristic landscape. New projects can be approved if they blend in 

with the existing surroundings and don’t attract attention (i.e., small-scale picnic area or 

primitive campground in valley shielded from view that blends with natural appearance). 

Class III Objective: The objective of this class is to partially retain the existing character of the 

landscape. The level of change to the characteristic landscape should be moderate. 

Management activities may attract attention but should not dominate the view of the casual 

observer. Changes should repeat the basic elements found in the predominant natural features 

of the characteristic landscape. New projects can be approved that are not large scale, 

dominating features (i.e., geothermal powerplant or major mining operation would not be 

approved). 
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3-134 Chapter 3: Affected Environment

Class IV Objective: The objective of this class is to provide for management activities which 

require major modifications of the existing character of the landscape. The level of change to 

the characteristic landscape can be high. These management activities may dominate the view 

and be the major focus of viewer attention. However, every attempt should be made to 

minimize the impact of these activities through careful location, minimal disturbance, and 

repeating the basic elements. Most new projects would likely be approved in regards to a VRM 

perspective. 

Scenic quality is an essential component of most recreation activities. A recent survey of out of 

state visitors conducted by The University of Montana’s Institute for Tourism and Recreation 

Research (ITRR) indicated the majority of respondents (over 50 percent) visited Montana for 

its uncrowded, wide open spaces, and mountains and streams. Additionally, of those surveyed, 

driving for pleasure (45 percent) was the primary attraction, and wildlife viewing was close 

behind at 30 percent. 

There are many areas in the BiFO decision area that possess a high degree of scenic quality and 

a high level of visual sensitivity. In general, high scenic quality in the BiFO occurs in locations 

where the area has varied topography, unique geology, and striking vistas. High visual 

sensitivity areas are those with a high degree of visitor interest and public concern for an area’s 

visual resources, an area’s high degree of public visibility, and the level and type of public use. 

The BiFO conducted an inventory of the scenic quality of much of the individual land parcels it 

manages in 2007, but does not have a complete landscape wide inventory. Table 3-40 displays 

current VRI classes, associated objectives, and the number of BLM administered surface acres 

for each class. This information represents findings from the VRI; VRM classes will be 

(re)assigned through the RMP process. 

Table 3-40 VRM Classes and Acreage 

Current VRM Classes and Acreage

VRM Class I (includes Special Areas – WSAs) 28,714 acres

VRM Class II 13,507 acres

VRM Class III 391,113 acres

VRM Class IV 816 acres

By policy, VRM Class I areas are designated for all WSAs in the decision area. These areas are 

remote with limited access and have no developed facilities. For areas rated VRM Class I, 

modifications to the landscape should not be evident or attract attention, and the landscape’s 

natural appearance should be preserved. 

Some areas adjacent to the WSAs in the Pryor Mountains maintain a VRM Class II 

management class. These areas are typically rated high in the inventory process because of 

their scenic qualities. The Weatherman Draw and Meeteetse Spires ACECs and Bad Canyon 

are also managed at the VRM Class II level for their unique scenic quality. The VRM Class II 

areas are managed to retain the landscape’s existing character. Activities or modifications to the 

area should not be evident or attract attention from the casual observer. Changes should repeat 

the basic elements of form, line, color, and texture found in the predominant natural features of 

the characteristic landscape. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-135

Most of the BiFO decision area landscape transitions from largely grass and sage covered 

rolling hills to more rugged sandstone outcrop features. These areas are scattered among 

private, local, state, and federally owned lands. Ponderosa pine and junipers break up the 

landscape. While these areas possess some natural beauty, they are not unique and are managed 

as VRM Class III. Levels of change in VRM Class III areas should be moderate, and 

management activities may attract attention but should not dominate a casual observer’s view 

or detract from the existing landscape. 

The Bridger Fossil Area ACEC and Petroglyph Canyon ACEC are currently managed as VRM 

Class IV. AVRM Class IV rating is generally reserved for areas where the visual intrusions 

dominate the viewshed, but are in character with the surrounding landscape (areas such as rural 

communities, multiple subdivisions, and mining developments) not as in this case, landscapes 

in a generally natural condition being managed for fragile and rare resources. 

3.12.2Visual Resource Management Analysis Process 

To properly assess the contrasts between a proposed and the existing Landscape situation, it is 

necessary to break each down into the basic features (i.e., landform/water, vegetation, and 

structures) and basic elements (i.e., form, line, color, and texture) so that the specific features 

and elements of a project that cause contrast on a landscape can be accurately identified. 

The following general criteria and factors are used when rating the degree of contrast: 

Degree of Contrast Criteria 

None The element contrast is not visible or perceived. 

Weak The element contrast can be seen but does not attract 

attention. 

Moderate The element contrast begins to attract attention and begins 

to dominate the characteristic landscape. 

Strong The element contrast demands attention, will not be 

overlooked, and is dominant in the landscape. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

3-136 Chapter 3: Affected Environment

The following factors apply when applying the criteria: 

1. Distance. The contrast created by a project usually is less as viewing distance increases. 

2. Angle of Observation. The apparent size of a project is directly related to the angle 

between the viewer’s line-of-sight and the slope upon which the project is to take place. 

As this angle nears 90 degrees (vertical and horizontal), the maximum area is viewable. 

3. Length of Time the Project Is In View. If the viewer has only a brief glimpse of the 

project, the contrast may not be of great concern. If, however, the project is subject to 

view for a long period, as from an overlook, the contrast may be very significant. 

4. Relative Size or Scale. The contrast created by the project is directly related to its size 

and scale as compared to the surroundings in which it is place. 

5. Season of Use. Contrast ratings should consider the physical conditions that exist during 

the heaviest or most critical visitor use season, such as snow cover and tree defoliation 

during the winter, leaf color in the fall, and lush vegetation and flowering in the spring. 

6. Light Conditions. The amount of contrast can be substantially affected by the light 

conditions. The direction and angle of lighting can affect color intensity, reflection, 

shadow, from, texture, and many other visual aspects of the landscape. Light conditions 

during heavy periods must be a consideration in contrast ratings. 

7. Recovery Time. The amount of time required for successful revegetation should be 

considered. Few projects meet the VRM management objectives during construction 

activities. Recovery usually takes several years and goes through several phrases (e.g., 

bare ground to grasses, to shrubs, to trees, etc.). 

8. Spatial Relationships. The spatial relationship within a landscape is a major factor in 

determining the degree of contrast. 

9. Atmospheric Conditions. The visibility of projects due to atmospheric conditions such 

as air pollution or natural haze should be considered. 

10. Motion. Movement such as waterfalls, vehicles, or plumes draws attention to a project. 

The level of contrast is compared to the objectives for the approved VRM Class. For 

comparative purposes, the four levels of contrast (i.e., none, weak, moderate, and strong) 

roughly correspond with VRM Classes I, II, III, and IV, respectively. This means that a 

“strong” contrast rating may be acceptable in a Class IV area but probably would not meet the 

VRM objectives for a Class III area. In making these comparisons, the cumulative effect of all 

the contrast ratings must be considered. Certain combinations of ratings may indicate there is a 

stronger overall contrast that the individual ratings show. For example, several “moderate” 

ratings when viewed in combination may warrant an overall “strong” rating. This is a judgment 

call that is made by resource specialists. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-137

3.13 Fire Ecology and Management 

Fire is a natural phenomenon. Vegetation communities in the planning area have adapted to the 

presence or absence of wildfire over several thousand years. Geographic, topographic, 

elevational, and climatic variances throughout the planning area provide a range of conditions 

in which fire has historically (from 200 to 400 years ago) affected vegetation differently. 

Consequently forests, woodlands, and rangelands throughout the planning area have adapted to 

fire. 

Wildfire risk is predicted to increase due to a combination of climate change effects on 

temperature, precipitation, and wind. Together, these climate characteristics affect fuel 

availability and fuel moisture content. In Montana, the increase in median annual area burned is 

predicted to be an increase of 241 percent to 515 percent (Climate Change Supplementary 

Information Report for the Montana, North Dakota and South Dakota Bureau of Land 

Management, 2010). 

3.13.1Wildfire Occurrence 

Yearly fire occurrence data for the BiFO is available from 1984 to 2010 (Map 36 – Wildland 

Fire Locations). Between 1984 and 2010, 336 fires occurred on public lands in the planning 

area. Approximately 60 percent of the fires were lightning caused, and 40 percent were human 

caused. These fires typically occurred between May and August. Human caused fires were 

usually associated with main travel corridors and occurred year round at various intensities. 

Multiple fires have also occurred on the same day. 

The number of fires in the planning area varies from year to year and is dependent on the 

amount of moisture associated with lightning producing thunderstorms. Natural fire return 

intervals for lower to middle elevation communities comprise approximately 84 percent of the 

BiFO planning area, and high elevation communities make up another 16 percent of the area. 

Fire size fluctuates from year to year depending on the availability of the primary fire carrier. 

Annual grasses and brush are the primary fire carriers in the lower to middle elevations, and 

their growth is dependent upon precipitation received during the late winter and spring months. 

At higher elevations, primary fire carriers are pine needles and litter. Table 3-41 identifies only 

fires that occurred on BLM lands. While the majority of the planning area experiences 

primarily Class A, B, and C fires, the area has a history of large fire activity. Ten Class E and F 

fires ranging from 300 to 54,000 acres have been recorded. Table 3-42 shows causes of fires 

between 1894 and 2010, and Table 3-43 provides information on large-scale fire activity in the 

planning area from 1999-2010.
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Proposed Resource Management Plan and Final Environmental Impact Statement 

3-138 Chapter 3: Affected Environment

Table 3-41 Fires by Class Size 

Fires by Class Size 1984-2010

Class Size Number of Fires

A <.25 acres 63

B .25 – 10 acres 115

C 10 – 100 acres 77

D 100 – 300 acres 32

E 300 – 1,000 acres 18

F 1,000 – 5,000 acres 13

G > 5,000 acres 7

Control No control acres reported 11

TOTAL 336

Note: 

Source: https://www.nifc.blm.gov/cgi/WfmiHome.cgi

Table 3-42 Fires by Cause

Fires by Cause

Number of Fires 

1984-2010

Human 159

Natural 177

TOTAL 336

Note: 

Source: 

Table 3-43 Fire Activity in the Planning Area Since 2000 

Year Fire Name

Acres

(all ownerships)

2000 Twin Coulee 3,000

2002 Steamboat Butte 3,000

2002 Cow Creek 5,500

2002 Red Waffle 6,000

2003 Hobble 36,180

2004 Pine Hill 2,022

2005 Cottonwood Creek 3,485

2006 Bundy Railroad 91,897

2006 Suanders 3,150

2006 Emerald Hills 3,900

2006 Pine Ridge 121,687

2006 Jungle 36,000

2006 Derby 199,500
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-139

Year Fire Name

Acres

(all ownerships)

2007 Chi Chi 17,954

2008 Dunn Mountain 102,383

2010 Stump Gulch 9,870

Note: 

Statistics from http://dnrc.mt.gov/FireReports and https://www.nifc.blm.gov/cgi/nsdu/FireReporting.cgi

3.13.2 Fuels Treatments 

Fuels treatments such as prescribed burns are developed to reduce fuels and meet resource 

objectives in wildland urban interface (WUI) areas and non-WUI areas. A combination of 

mechanical, hand, and fire treatments are used to accomplish these objectives. The principle 

objective is to reduce risk from wildfire to life, property, critical infrastructure, and natural 

resources in wildland urban interface areas. Priority of fire management activities would be 

placed on fuels reduction in WUI areas in conjunction with completed county wildfire 

protection plans (CWPPs). All counties within the planning area have developed CWPPs. The 

principal objective of these CWPPs is to reduce the risk from wildfire to life, property, critical 

infrastructure, and natural resources in the WUI areas. As directed by the Healthy Forests 

Restoration Act of 2003 (HFRA), these plans identify and prioritize areas for hazardous fuel 

reduction treatments. This legislation allows the BLM to work cooperatively with counties to 

consider the priorities of local communities as hazardous fuel reduction and forest management 

projects are being developed and implemented. Table 3-44 summarizes fuels reduction work in 

the decision area. 

Table 3-44 Fuels Treatments from 2003-2010 

Treatment Type

Acres/year

(2003-2010) Contract/Federal Cost/Acre Totals/Year

Mechanical Treatment 

(WUI & Non-WUI) 651 50% Contract50% Federal

$400/acre

$300/acre

$130,200

$ 97,650

Prescribed Fire WUI 395 Federal $15/acre $ 5,925

Prescribed Fire Non-WUI 1,095 Federal $20/acre $ 21,900

TOTAL 2,141 $255,675

3.13.3 Fire Regimes and Condition Causes 

Fire regimes address the nature of disturbance by fire by describing historic intensity, 

frequency, and effect on vegetation. Knowledge of fire regimes is a critical component in 

managing landscapes and analyzing changes in fire frequencies and intensities. Table 3-45 lists 

the natural fire regimes by which vegetation is classified in the BiFO. Natural fire return 

intervals for lower-to-middle elevation communities’ compose approximately 84 percent of the 

field office and high elevation communities make up 16 percent of the field office. 

Categorization of vegetation types by fire regimes was based on information provided in 

Section 3.3.5 – Vegetative Communities and Section 3.4.5 - Forestry. 
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Table 3-45 Fire Regime Classifications and BiFO Estimated Acreage 

Fire Regime Fire Return Interval Severity Level BiFO

I 0 – 35 Years Common Surface Fire

68,366 acres or 16%

II 0 – 35 Years Stand Replacement Fires High Severity

III 35 – 100+ Years Mixed Severity Fires

IV 35 – 100+ Years Stand Replacement Fires High Severity 358,924 acres or 84%

V 200+ Years High Ratio of Stand Replacement Fires

Note: 

Source: BLM BiFO Fire Management Plan (2004) 

3.13.4 Frequency Fire Intensity Estimated 

Related to fire, vegetation conditions are evaluated by the degree of departure from fire regimes 

that a specific vegetation community demonstrates. Departure from fire regimes is indicated by 

changes to key ecosystem components (species composition, structural stage, stand age, canopy 

closure, and fuel loadings). Degree of departure is ranked using three condition classes that 

categorize vegetation communities by evaluating the difference between their historic fire 

regime and related indicating characteristics, and their current condition and its indicating 

characteristics. Basically, fire regime “condition classes are a qualitative measure describing 

the degree of departure from historical fire regimes” (Schmidt K.M. et al. 2002). Table 3-46

illustrates the estimated acreage of vegetation in the planning area in each condition class. 

Table 3-46 Fire Regime Condition Class Description and BiFO Estimated Acreage 

Condition Class

Percent Deviation

from Natural

BiFO Area

(estimated acres)

I 0 – 33% 21,879 acres or 5%

II 34 – 66% 109,825 acres or 26 %

III 67 – 100% 295,586 acres or 69%

Note: 

Source: BLM BiFO Fire Management Plan (2004) 

3.13.5 Condition 

Areas in Condition Classes 2 and 3 are of most concern because they often need management 

intervention before allowing fire to return naturally. 

3.14 Wilderness Characteristics 

Pursuant to the section 201 of the Federal Land Policy and Management Act of 1976 

(FLPMA), 43 U.S.C. § 1712(c), the BLM, does have the authority to conduct inventories for 

characteristics associated with the concept of wilderness and to consider management of these 

values in its land use planning process. 
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Chapter 3: Affected Environment 3-141

Some key points to this management direction are: 

 Protection of wilderness characteristics is a high priority for BLM and is an 

integral component of the BLM’s multiple use mission 

 BLM can establish management prescriptions to protect wilderness 

characteristics and manage these lands through the planning process unless it is 

determined that impairment is appropriate and consistent with other laws and 

other resource considerations 

 The BLM has an obligation to maintain wilderness resource inventories and 

must keep them current 

Thus, this section addresses lands outside existing WSAs that have been identified as having 

wilderness characteristics. 

Non-WSA lands with wilderness characteristics are those that have the appearance of 

naturalness and outstanding opportunities for solitude or primitive and unconfined recreation, 

and also comprise an area of 5,000 acres, or areas less than 5,000 acres that are contiguous to 

designated wilderness, WSAs, or other administratively endorsed for wilderness management 

lands, or, in accordance with the Wilderness Act’s language, areas “of sufficient size as to make 

practicable its preservation and use in an unimpaired condition, including roadless islands.”

BLM used the same criteria for determining wilderness characteristics as in the 1979 

wilderness inventory. The 5,000-acre value was helpful to BLM in making preliminary 

judgments, but it was not considered a limiting factor. The size criterion of 5,000 acres was 

applied only to standalone units, that is, units not contiguous with other federal lands 

previously determined to possess wilderness characteristics (e.g., WSAs and NPS and USFS 

lands that are administratively endorsed for wilderness). 

Units contiguous with federal lands with wilderness characteristics were evaluated for all 

wilderness characteristics found in the inventoried area. The presence of outstanding levels for 

opportunities for solitude or primitive recreation was evaluated as well. Detailed information 

about non-WSA lands with wilderness characteristics is part of the administrative record for 

this Draft RMP/EIS (See Appendix K for details). 

The wilderness characteristics review process involved a BLM interdisciplinary team that 

reviewed available information and followed up with field trips where necessary. The BLM 

interdisciplinary team evaluated information provided by the public about these areas, their onthe-ground knowledge of these areas, information in case files and field files, master title plats, 

aerial photos, GIS data layers, and field inspections, and determined that all or parts of several 

areas have wilderness characteristics. 

In summary, the BiFO does not manage any congressionally designated wilderness areas and 

does manage four WSAs. Beyond these, currently, the BiFO manages five tracts as non-WSA 

lands with wilderness characteristics (Map 42). 

In the Wilderness Review, there were several areas greater than 5,000 contiguous acres of 

BLM-administered lands that met the Lands with Wilderness Character evaluation criteria. 

Tracts of public lands adjacent to the Bighorn Tack-on, the Burnt Timber, and the Pryor 
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Mountain WSAs were analyzed and found to possess wilderness character. An area including 

recently acquired lands adjacent to and including the Meeteetse Spires ACEC, also met the 

criteria, as did a parcel adjacent to the Gallatin/Custer National Forest known as the Bad 

Canyon Unit. A stand-alone land tract, the Weatherman Draw Unit, most of which is currently 

designated as an ACEC was also found to possess wilderness characteristics. Summarized 

below is a description of each inventory unit. 

3.14.1Pryor Mountain Unit 

Much of the lands were initially inventoried as portions of what became two separate WSAs, 

the Pryor Mountain and the Big Horn Tack-On WSAs. At the time human impacts were 

recorded which eliminated them from consideration. Other lands were acquired after the initial 

inventory was concluded: 

A portion of Tract 1 was previously inventoried and found to possess wilderness values, but 

another portion of this Tract (T. 8 S., R., 28 E., Section 16 – 640 acres) was acquired after the 

inventory and had not been previously evaluated. Some lands (154 acres) in Section 1 have also 

never been inventoried since they were previously isolated by the acquired lands. This parcel is 

approximately 2,873 acres in size. This parcel is separated from The Pryor Mountain WSA by 

an established road (Sykes Ridge Road) but is adjacent to the Big Horn Tack-On WSA to the 

south and lands administratively endorsed for wilderness designation by the NPS in the 

Bighorn Canyon National Recreation Area to the southeast. Private lands form the northern 

boundary and the west boundary is a combination of a vehicle road, private lands, and Custer 

National Forest lands. 

Tracts 2 and 3 (T., 9 S., R 28 E., Section 16 - 640 acres) were not previously inventoried for 

wilderness character since they were acquired after the inventory effort. They were 

subsequently recommended for potential wilderness designation in the Montana Statewide 

Wilderness Study Report (1991) and were noted as being outside the WSA. Tract 2 is 

approximately 497 acres in size. It is adjacent to the Pryor Mountain WSA to the west, south 

and north, while the Sykes Ridge road forms the boundary to the east. Tract 3 is approximately 

143 acres in size. It is adjacent to the Big Horn Tack-On WSA on the north, east, and south 

sides. The west side is the Sykes Ridge road. 

Tracts 4, 5 and 7 were recommended for wilderness designation in the Montana Statewide 

Wilderness Study Report (1991) and were noted as being outside the WSAs. However, they 

were not inventoried for wilderness character. 

Tract 4 is approximately 445 acres in size. The parcel boundary is formed by vehicle routes on 

all sides. It was initially unclear whether the two boundary routes were roads, trails or a 

combination of both. If either vehicle route were found not to be a road, then the tract would be 

adjacent to the Pryor Mountains WSA or the Big Horn Tack-On WSA. 

Tract 5 is an irregular shape and the boundary is formed by a combination of vehicle routes and 

a ROW. It is approximately 512 acres in size with 224 acres in Wyoming and 288 acres in 

Montana. The Pryor Mountain WSA is located to the west and the Big Horn Tack-on WSA is 

located to the east. It was initially unclear whether the two routes were roads or trails or a 

combination of both. If either one of the two boundary vehicle routes were determined to be a 
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way, then the tract would be adjacent to the Pryor Mountains WSA or the Big Horn Tack-On 

WSA. BLM has determined that the vehicle route to the east is not a road and that the Tract is 

adjacent to the Big Horn Tack-On WSA. 

Tract 7 is located adjacent to the Pryor Mountains WSA on the north, east, and south. The west 

side boundary is a county road (Burnt Timber Road). It is approximately 327 acres in size. 

Tracts 6 and 8 were previously inventoried by BLM and found to lack wilderness character. It 

was noted in the Final Decision, Montana Wilderness Inventory, (1980), that the lands now in 

Tract 6 had a power line, a portion of a stock trail, a vehicle routes used to view wild horses, 

and some small uranium mining scars. Tract 6 is located adjacent to the Pryor Mountains WSA 

to its north. It is approximately 1,074 acres in size and is completely within Wyoming. The 

boundary is either a county maintained road or a powerline ROW to the south, east, and west. 

The lands now in Tract 8 were noted as having extensive uranium mining scars and other 

development impacts. Tract 8 is located adjacent to the Pryor Mountains WSA on the north, 

east, and south. The western boundary is a county road (Burnt Timber Road). The Tract is 

approximately 269 acres in size. 

In this effort, BLM determined that the lands, with the exception of Tract 4, taken together with 

the adjacent and contiguous BLM WSA lands and NPS lands recommended for wilderness 

designation, meet the size exception criteria. The lands have minimal intrusions, as noted 

above, and are substantially in a natural condition, with the exception of small portions of 

Tracts 1 and 5, which have been excluded from the Inventory Unit. All of Tract 8 still has 

extensive mineral development and exploration impacts and lacks naturalness. 

There is abundant vegetation screening and topographical aspects which taken together with 

minimal vehicle use, which is also restricted to designated routes outside of the inventory 

tracts, and general low use numbers offers challenging recreational opportunities for hiking, 

climbing, wildlife viewing, and hunting. There are numerous natural limestone caves and karsts 

which offer a range of caving opportunities and which are advertised. 

The tracts, especially when considered with the adjacent WSAs and NPS lands, offer 

expansiveness and sequestration of an outstanding level. The lands possess the following 

significant resources documented in the Billings RMP and the Montana Statewide Wilderness 

Report (1991): wildlife, plant, geology, scenery and cultural. 

The wild horse herd is a significant attractant and is known internationally. All wild horse 

management operations conducted on the PMWHR have been analyzed for potential impacts to 

wilderness values through the development of NEPA documents. None have caused 

detrimental effects. The occasional removal of the wild horses occurs when the population 

exceeds its carrying capacity and begins to damage the natural condition so the operation is 

considered to have beneficial aspects for the wilderness values. Similarly, the construction of 

the localized water developments spreads the wild horse population throughout the area and 

reduces potential adverse impacts throughout the range. 
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3.14.2 Burnt Timber Canyon Unit 

The initial study area in the 1979 effort included public lands in Wyoming as well as public 

lands in Montana. Initially the entire area was found to be lacking wilderness characteristics, 

but upon appeal it was revaluated and a central core area was eventually designated as the 

Burnt Timber Canyon WSA in 1991. 

The new inventory addressed the public lands adjacent to the WSA, which were the lands in 

Montana, found to be lacking wilderness values in the earlier effort. The adjacent public lands 

in Wyoming were not re-inventoried. 

Tract 1, approximately 1,816 acres in size, is adjacent to the Burnt Timber Canyon WSA on its 

west side, separated from it by a very primitive vehicle route which is mostly unused, except on 

a random basis by OHVs. This route is naturally rehabbing but can be found and followed. The 

rest of the west side boundary is a combination of private/public lands. The east side boundary 

is formed by the Burnt Timber Road. Tract 1 is less than 5,000 acres in size but is adjacent to 

the WSA and thus qualifies for evaluation under the size exception at BLM Manual 6310. 

Tract 2, approximately 5,388 acres in size, has the Cottonwood Creek road as its western 

boundary, while the east side is adjacent to the Burnt Timber Canyon WSA. This boundary is a 

combination of a primitive vehicle route which is mostly unused, except by OHVs and which is 

naturally rehabbing, and private/public lands. The southern boundary is the Montana/Wyoming 

state line. Tract 2 is more than 5,000 acres in size and is also adjacent to the WSA and thus 

qualifies for evaluation under BLM Manual 6310. 3.1.4. 

Tract 1 has less vehicle use on the previously identified vehicle routes, with the exception of 

the portion of the vehicle route which BLM has chosen to continue to use for its administrative 

access to the water development. This vehicle route also forms a portion of the southeastern 

boundary of the Burnt Timber Canyon WSA, and with its continued use effectively bisects the 

Inventory Tract into two (2) separate parcels. 

The northern portion of Tract 1 has residual human impacts from the historical mining 

operations on it as well, which are still visible since they are located along the foreground of 

the Burnt Timber road and from many points within the local area. Although the northeastern 

boundary of the WSA (a vehicle route) is naturally rehabbing it still serves as a definable 

boundary. This parcel of 1,113 acres lacks wilderness characteristics, while the remaining 703

acres located south of the WSA, east of the private lands of the Tillett Ranch, and west of Burnt 

Timber Road does possess wilderness characteristics. (An exception is the small portion 

isolated by the Road ROW in the southwestern corner which lacks wilderness characteristics.) 

These 898 acres possess the same wilderness values found on the adjacent WSA lands to its 

north and are in essentially a natural condition, have outstanding opportunities for solitude and 

primitive recreation, and have significant supplemental resources present. 

With exception of the small portion isolated by the ROW powerline running to Tillett Ranch 

(12 acres), all of Tract 2 was found to be in essentially a natural condition, have outstanding 

opportunities for solitude and primitive recreation, and have significant supplemental resources 

present. The vehicle routes identified in the earlier inventory have much less usage and are 

naturally rehabbing to the extent that they do not impair wilderness resources and do not cut the 
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Tract into smaller pieces and thus eliminate it from further consideration, as they did 

previously. The conditions have changed from the previous inventory for this Tract. This area 

totals 5,375 acres. 

3.14.3 Meeteetse Unit 

The lands have not been previously evaluated; when the prior inventory was conducted the 

private/public land ownership was more broken up, and several roads were more routinely 

used. Since then some additional private lands have been acquired and several roads have fallen 

into disuse and are naturally rehabbing. The result is that a block of public lands was analyzed 

for their wilderness characteristics. 

During initial Wilderness Inventory a preliminary staff review identified these lands as meeting 

the size requirement (over 5,000 acres) but probably mostly lacking naturalness due to the 

presence of roads, and lacking opportunity for solitude and primitive recreation on most of the 

lands due to lack of topography and vegetation screening. However, it was noted that a small 

portion of the area did have potential for further in-depth evaluation, if some private lands were 

acquired. 

Subsequent to private land acquisition in 2009, this land was acquired and it and the larger 

BLM lands are the area which is the subject of the following formal review and analysis as a 

Wilderness Character Inventory Unit. The boundaries are as follows: The western boundary is a 

combination of private lands and National Forest Service; the southern and northern boundaries 

are private lands and Montana State lands, and the eastern boundary is private lands. The 

southern boundary is also the Wyoming/Montana State line. 

The Meeteetse Spires Trail and several other vehicle routes which have been determined to be 

roads bisect portions of the unit into separate parcels. These are identified on the field map, in 

the road inventory files, and described here: 

Tract 1: 23.4 acres in size. Isolated from the rest of unit by Meeteetse Trail, less than 5,000 

acres in size and thus lack wilderness character. This parcel will not be considered further. 

Tract 2: 977 acres in size. Isolated from the rest of unit by Meeteetse Trail and a vehicle route 

determined to be a road, less than 5,000 acres in size and thus lack wilderness character. This 

parcel will not be considered further. 

Tract 3: 373 acres in size. Isolated from the rest of unit by Meeteetse Trail and a vehicle route 

determined to be a road, less than 5,000 acres in size and thus lack wilderness character. This 

parcel will not be considered further. 

Tract 4: 87 acres in size. Isolated from the rest of unit by a vehicle route determined to be a 

road, less than 5,000 acres in size and thus lacks wilderness character. This parcel will not be 

considered further. 

Tract 5: 3,841 acres in size. Isolated from the rest of unit by a vehicle route determined to be a 

road, less than 5,000 acres in size and thus lacks wilderness character. Additionally, the parcel 

has a number of other vehicle determined to be roads or vehicle routes which receive routine 

use, lacks vegetation and topographical screening. This parcel will not be considered further. 
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Tract 6: 356 acres in size. Isolated from the rest of unit by a vehicle route determined to be a 

road, less than 5,000 acres in size and thus lacks wilderness character. This parcel will not be 

considered further. 

Tract 7: A very small parcel of 0.6 acres in size in a corner of the unit isolated by Meeteetse 

Road from the rest of the public lands. It is less than 5,000 acres in size. This parcel will not be 

considered further. 

Tract 8: Approximately 2.9 acres in size in a corner of the unit and isolated from the rest of the 

unit by a vehicle roué determined to be a road. It is less than 5,000 acres in size and lack 

wilderness character. This parcel will not be considered further. 

Tract 9: Approximately 10,809 acres in size. This large, central region of the unit has a number 

of vehicle routes which are somewhat noticeable and used on at least an occasional basis, as 

well as most of the private land inholdings. Several range developments and their access routes 

are also visible from a distance due to topography and lack of vegetation screening. This parcel 

will not be considered further. 

Tract 10: The remainder of the unit, approximately 2,149 acres along the west side of the unit, 

has man-made facilities and structures which are substantially unnoticeable and which do not 

detract from the surrounding environment. Vehicle routes #2 and #3 are minor, naturally 

rehabbing, and do not substantially attract casual attention. Vehicle route #1, the route to the 

cabin, is not open to the public except as a non-motorized trail. It is visible within the view 

shed of the canyon which it goes up, however. 

Of the entire Unit, only the lands in Tract 10 are considered to have wilderness characteristics, 

and these do not meet the size criteria. However, the boundary does provide the opportunity to 

manage it as a separate unit, so the staff feels that the exemption criteria apply. The boundary is 

set as being the Forest Service/BLM on the west, private lands on the south, and the east has a 

combination of Montana State lands and the Meeteetse Road, vehicle the north boundary is 

private lands. The lands have minimal intrusions, as noted above, and are substantially in a 

natural condition. There is abundant vegetation screening and topographical aspects which 

taken together with minimal vehicle use and general low use numbers offers challenging 

recreational opportunities for hiking, climbing, and hunting. The lands possess the following 

significant resources: wildlife, plant, geology, scenery and possibly cultural. 

Note: the vehicle route leading to the BLM cabin (vehicle route #1) and the immediate area 

surrounding the cabin (approximately 3 acres in size) will be cherry-stemmed from the unit as 

well, for administrative purposes and since they are existing intrusive impacts. This will further 

enhance the wilderness character of the unit by removing the major human intrusion in the unit 

3.14.4 Bad Canyon Unit 

The unit is bordered by private lands on all sides except the west, which are National Forest 

lands of the Custer National Forest. These lands are not recommended by the Forest Service for 

designation as a Wilderness Area. The lands in the unit are less than the minimum size criteria 

(approximately 2,036 acres), and although the unit is configured in a long and relatively narrow 

shape which by itself may not usually lend itself to wilderness management, in this case the 
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canyon within the unit can be managed by itself, or the entire unit including the canyon and 

some other lands along private/public land boundaries. 

The lands are located in all or portions of T. 4 S., R. 16 E., sections 4, 5, 6, 7, 8, 9, 10, 11, 13, 

14, 15. All are public lands. There are no private land in-holdings present. 

There is no motorized access to this parcel. The BLM does have a non-motorized ROW across 

private lands and there is an undeveloped and primitive non-motorized trailhead located on the 

south side of the unit. 

The area has been extensively timbered with scenic geological formations. 

The riparian corridor is in a natural condition, with few invasive species present. A portion of 

the river segment has had a natural barrier slightly modified for protection of natural resources 

(fish Species) but this is substantially un-noticeable (see attached photos). 

Bad Creek contains a stable population of Yellowstone Cut-throat trout, which is a native 

species, listed as endangered, and is a supplemental feature for the unit. The lands are important 

habitat for Grizzly Bear. The riparian corridor serves as an important wildlife migration 

corridor. 

The trout, and the natural scenery, attract an unknown number of casual recreationists, mostly 

from the local communities, but the location is advertised as a destination in several 

publications regionally. There are no known commercial recreation operators. All recreational 

use is primitive in nature. The surrounding private lands have strictly restricted access as well. 

A portion of the unit was previously burned in a wild fire, but is naturally rehabbing. Evidence 

of fire suppression activities is minimal. 

There is abandoned motorized vehicle route which enters the unit from the west across Forest 

lands. It is naturally rehabbing and is not open for use and has not been for some time. There is 

one vehicle route which accesses the lands from the south. It is maintained only by the passage 

of vehicles and is not open to general use across private lands. This route has received only 

occasional use related to grazing in the past. 

There is plentiful vegetation and topographical screening for an outstanding level of solitude. 

The area has significant geological, riparian, wildlife, and scenery resources which provide an 

outstanding level of primitive recreation attractions and experiences. The opportunity for this 

kind of recreation is further enhanced by the administrative lack of motorized access across the 

private lands. 

3.14.5 Weatherman Draw Unit 

The lands are bordered by a combination of roads including Cottonwood Creek Road, a 

railroad line, private lands, and Montana State lands. This inventory boundary was slightly 

different than the initial inventory effort due to land acquisition and some change in use 

patterns recognized by staff as altering the area. This also resulted in two private land parcels 

being established as inholdings. These two inholdings are not included in this analysis. 
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Weatherman Draw contains significant historic, cultural, and scenic values. There is currently 

a Weatherman Draw Archaeological District in place within the ACEC, but this archaeological 

district is only for the rock art. This district consists of 80 separate rock art sites. The ACEC 

currently covers approximately 4,365 acres. In addition to the rock art and prehistoric 

habitation sites, the Weatherman Draw ACEC and surrounding area contain historic coal mines 

(found both in and outside of the ACEC), historic homesteads, evidence of native American 

(Crow) horse traps/corrals, vision quest and sacred sites (which are still in use) and historic 

graffiti. 

The unit meets the size criteria (11,603 acres), but the current conditions on the ground do not 

support the earlier decision that the unit lacks naturalness. The lands have been closed to 

motorized vehicle use. The visual impacts do not attract the notice of a casual observer. The 

vehicle routes are not being used except for non-motorized primitive recreation and are 

naturally rehabbing. The area does offer a high level of solitude and primitive recreation. There 

are supplemental resources present. The unit does meet the conditions for further consideration 

for Wilderness Character. 

3.14.6 Yellowstone River Islands Unit 

The Yellowstone River flows northeast through Montana from its source in the southern 

Absaroka range in Wyoming to its junction with the Missouri River in North Dakota. The 

Billings Field Office includes approximately 150 miles of this river between Springdale and 

Custer, Montana. The inventory identified and evaluated 10 individual islands or groupings of 

small islands which are partially or wholly administered public land islands on the Yellowstone 

River. 

Island 1: Located in T. 1 S., R. 13 E., Section 8, found west of the community of Big Timber. 

The island is approximately 3.8 acres in size and is composed of all public lands. The lands are 

located adjacent to the southern bank of the river and it appears to be essentially a sand bar with 

limited low-lying vegetation scattered on it. There are no trees. 

Island 2: Located in T. 1 N., R. 14 E., Section 19, found just west of the community of Big 

Timber. It is a total of 113 acres in size, of which approximately 77 acres are public lands. This 

island is dominated by a mature cottonwood gallery with an understory of willows and wetland 

communities. The island is noted for its mature subspecies (or possible separate species) of 

mature willows. These trees are under review by the “Champion Tree Project” for potential 

cloning. 

The island has been used occasionally by a commercial fishing guide operation under permit by 

BLM and it also receives casual recreational visitation. Both types of recreational activity 

groups use it regularly as a camping destination. 

There are no vehicle routes on the island and the only access is by boat. The BLM review 

located some two-track vehicle use accessing the island from a southwestern point (private 

lands) and the staff believes it may have been associated with the range operation on private 

lands which has driven onto the public lands as required. This does not appear to be a regular 

occurrence. There are no range developments. 
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On private lands there is a historic cabin (unused) which is known locally as French’s Cabin 

after a previous owner. Its construction and use dates are unknown. The vegetation community 

is in good condition due to the system of range operations and has very little invasive species 

present. There has been no agriculture. 

Island 3: Located in T. 3 S., R. 21 E., Section 9. Four small islands grouped together, all with 

similar vegetation: mature cottonwoods and wetland plant communities (sedges, grasses, etc.) 

Anecdotal evidence of Invasive Tamarisk species present as well. The islands are located just 

west of the community of Columbus and approximately 45 miles west of Billings. 

Island A is approximately 2.3 acres total size – all public lands managed by BLM. 

Island B is approximately 2: 3.8 acres total size – 2.5 acres BLM and 1.3 acres private. 

Island C is approximately 3.4 acres total size – 1.8 acres BLM and 1.6 acres private. 

Island D is approximately 10.1 acres total size – 8.2 acres of BLM and 1.9 acres private. 

Island 4: located in T. 2 S., R 24 E., Section 13. This parcel is adjacent to the Sundance 

Recreation Area and is near the junction point of the Clarks Fork of the Yellowstone River and 

the main course of the Yellowstone River. It is a total of 81 acres, of which 34 acres are BLM. 

The vegetation is mature cottonwoods and wetland plant communities. The island is situated 

between BLM Recreation Area and a developed Montana State Fishing Aces site. The 

Sundance Recreation Area is a popular year-round destination for the local community and 

there is a developed parking lot with a restroom and walking trails which lead to the river. 

Island 5: Located in T. 1 S., R. 25 E., Section 25. This parcel is a small portion of a larger 

island and is the western point (upstream side) of the island. The total island size is 

approximately 313 acres of which 9 acres are BLM. 

Island 6: Located in T. 1 S., R 26 E., Section 2. This island is part of the Four Dances Natural 

Area ACEC managed by the BLM. It is located in mid channel in the downtown section of 

Billings and is in close proximity to an oil refinery, a powerhouse, and Interstate Highway 90. 

The total size is 23 acres, of which 12 acres are BLM. The island is dominated by a cottonwood 

gallery with a wetland community understory of willows, sedges and lush grasses. There is a 

powerline which bisects the island and which has two tower pylons, a large amount of rip rap 

along the river bank for bank protection. A large amount of vegetation has been removed along 

the course of the power line as well. 

Island 7: Located in T. 1 N., R 27 E., Section 8. This island has two separate BLM parcels. It is 

located east of Billings by the community of Lockwood. The approximate total size of the 

island is 152 acres, of which the two BLM parcels are 16 acres and 28 acres. The island is 

dominated by a cottonwood gallery with wetland plant community understory, including 

willows, sedge, rush and other riparian obligate species. 

Island 8: Located in T. 3 N., R. 30 E., Sections 19 and 20. This island is known locally as 

Bundy Island. A portion of the island has an old and naturally rehabbing agricultural field on it. 

This field is readily apparent and is not in a natural condition. The approximate total BLM 
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lands are 80 acres and 24 acres. Besides the agricultural area, the island is dominated by a 

mature cottonwood gallery and wetland communities. There is a fishing access site, 

administered by MT FWP, on the eastern tip of the island that receives high levels of use. 

There is a camp site and a vault toilet at the site. 

Island 9: Located in T. 3 N., R 30 E., Sections 21 and 22. This island is known locally as 

Pompeys Pillar Island. It is just downstream from the Pompeys Pillar National Monument. The 

approximate size of the island is 165 acres, of which 105 acres are managed by BLM. This 

island is dominated by a grassy field surrounded by a mature cottonwood gallery and wetland 

plant communities. The immediate area, including Pompeys Pillar National Monument, is well 

known as a birding mecca. There is a bald eagle nest on this island and it is used extensively by 

hikers and hunters, accessed through PPNM and by river boat. 

Island 10: Located in T. 4 N., R33 E., Section 7. This island is located just west of the 

community of Custer and is near 7 Mile Flat. The total size of the island is approximately 84 

acres, of which 19 acres are BLM. Vegetation comprises willows, tamarisk, and immature 

cottonwoods on BLM, but there is a mature cottonwood gallery on the privately owned portion 

of the island. 

Determination: 

Islands 1, 5 and 7 were determined to not be islands due to course changes by the Yellowstone 

River. These units were determined not to meet the criteria for further evaluation. 

Island 6 was found to have a number of significant man-made disturbances and it is considered 

not to be in a natural condition. IT also has no ort little opportunity for solitude and no natural 

features. It does have primitive recreation opportunities. This unit does not have wilderness 

characteristics. 

Island 8 was determined to have significant man-made impacts on it which have reduced the 

natural condition. It does have primitive recreation occurring on it, but has limited opportunity 

for solitude. No special features were identified. The island does not possess wilderness 

characteristics. 

Island 9 was found to have a number of human impacts, while it offers high values primitive 

recreation opportunities. The lands do have some but not an outstanding level for solitude. 

There are special features present and these have been recognized and protected through the 

ACEC designation. The island does not possess wilderness characteristics. 

Islands 3 and 4 were determined to have natural conditions, and offer, by their geographic 

location and vegetation screening, both an outstanding opportunity for solitude and primitive 

recreation opportunities. This unit does have wilderness characteristics. 

Island 2 was found to be in a natural condition, have opportunity for primitive recreation and 

solitude, and possess special features. The island possesses wilderness characteristics. 
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3.14.7Clark’s Fork of the Yellowstone River Islands Unit 

The Clark’s Fork of the Yellowstone River (sometimes called the Clark’s Fork River) is a 

tributary of the Yellowstone River and is approximately 150 miles (241 Km) long in the U.S. 

states of Wyoming and Montana. 

It rises in the southern Montana, in the Beartooth mountains of the Gallatin National Forest, 

approximately 4 miles (6 Km) northeast of the community of Cooke City and southwest of 

Granite Peak. It flows southeast into the Shoshone Nation al Forest in northwest Wyoming, east 

of Yellowstone National Park, then northeasterly back into Montana. The river passes the 

communities of Belfry, Bridger, Fromberg and Edgar, and joins the Yellowstone River 

approximately 2 miles (3 Km) southeast of the town of Laurel, Montana. 

The inventory identified and evaluated 4 individual islands or groupings of small islands which 

are partially or wholly administered public land islands on the Clark’s Fork of the Yellowstone 

River. 

Island 1: located near the community of Bridger, Montana in T. 7 S., R. 23 E., Section 4. The 

island is approximately 2 acres in size. The island is adjacent to property owned and managed 

by the State of Montana as a Fishing Access Site (FAS). The State has improved access and 

has installed a developed parking area and boat launch. There was anecdotal evidence that with 

fluctuating water levels, human access along the shoreline expands and contracts, with some 

motorized uses possible during low levels. There is no evidence of overnight camping on the 

lands. 

There is no commercial grazing occurring on the island. The main vegetation is an over story of 

Russian Olive, cottonwood and willow. 

The channel separating the island from the Montana State property is in the process of silting 

up and it is uncertain that the property still constitutes an island. 

Island 2: Located in T. 3 S., R 24 E., Section 18. There are two islands located in close 

proximity to each other and they are found just downstream (north) of the community of 

Bridger, Montana. The southern island is approximately 6 acres in size and the north island is 

approximately 8 acres in size. Both islands are located adjacent to property along the west bank 

of the river which is owned by the United States Fish and Wildlife Service and managed as a 

Wildlife Production Area. There is no motorized access. 

There is no commercial grazing under permit occurring on either island. 

Both islands have had invasive weed treatments conducted in the past and will continue to have 

retreatments if necessary. The vegetation currently comprises a Cottonwood, Russian olive, and 

willow complex. 

It does have a high level of wildlife diversity due to the wetland management practices of the 

Fish and Wildlife Service on the adjacent property. 
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Island 3: Located in T. 2 S., R 24 E., Section 23. The island, which is approximately 30 acres in 

size, is located south east of the junction of State Highway 310 and State Highway 212 at the 

community of Rockvale, Montana. The public lands are on the north half of the island and 

comprise approximately 13 acres in size. 

The entire island burned during a wildland fire event in FY 2012. There was a major 

suppression effort involving the use of mechanized equipment and although much of the visible 

impacts were rehabbed post fire there are still visible effects readily apparent over the entire 

island. 

Domestic goats were brought to the island in FY 2012 and FY 2013 to control an infestation of 

leafy spurge. Russian olive dominates the over story with some cottonwood and wetland plant 

communities in the understory. 

A large man-made structure, the east side of a major water diversion structure (the Rockvale 

Ditch) which provides agricultural water to surrounding farms and ranches, is anchored on the 

northern side of the island. 

There are nesting sand hill cranes present. The other wildlife species known to be located there 

are common to the riverine corridor. 

Island 4: Located at T. 1 S., R 23 E., Section 4, this island is located in the Sundance Lodge 

Recreation Area and is just upstream from the junction of the Clark’s Fork of the Yellowstone 

River and the Yellowstone River. The island was estimated as having a total of 5 acres, of 

which 2 acres are lands managed by the BLM. The vegetation is mature cottonwoods and 

wetland plant communities. Sundance Lodge Recreation Area is a popular year-round 

destination for the local community. There are developed recreation facilities including a 

parking lot, trails, signage, and a restroom. There are the remnants of expensive farmland 

operations found throughout the land parcel. The Recreation Area is also the intersection of the 

congressionally designated Nez Perce National Historic Trail and the Lewis and Clark National 

Historic Trail. 

Determination: 

The BLM staff review concluded that Island 1 of the Clark’s Fork of the Yellowstone River 

was not separated from the river banks due to silting in of the channel. (While it was also 

agreed by the staff that conditions may change with river events in the future). This unit does 

not meet the criteria for evaluation and is not evaluated further. 

The BLM staff review has determined that island 4 in the Clark’s Fork of the Yellowstone 

River is no longer separated from the reminder of the public land (Sundance Lodge Recreation 

Area) since this original river channel has changed course. This unit does not meet the criteria 

for evaluation and is not evaluated further. 

The BLM staff also determined that Island 3 in the Clark’s Fork of the Yellowstone River had 

substantive man-made impacts resulting from the recent fire, the rehab efforts, and the water 

diversion structure with its associated structures and access needs, which taken together has 
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cumulatively reduced the naturalness level throughout the island. There is a level of 

opportunity for solitude and primitive recreation, but not of an outsizing level. There are 

special features present. This unit does not have wilderness characteristics. 

Island 2 was determined to have had a substantive impact from human management actions and 

was not is an essentially natural condition. There is a high but not outstanding level of 

primitive recreation and opportunity for solitude. This unit does not have wilderness 

characteristics. 

3.14.8 Bear Creek Unit 

From generally flat prairie on the west and north, the Bear Creek unit rises to low bentonite 

domes and ridges in the center section. There is a north-south running canyon (petroglyph 

canyon) in the eastern region of the unit. This area is designated as an Area of Critical 

Environmental Concern (ACEC) for its significant cultural resources. 

Vegetation is sparse and composes mostly common range grasses, sagebrush species and some 

very scattered scrub timber. The lands are managed as Visual Resource Management (VRM) 

Class III and were inventoried as having a scenic quality rating of Class C, the lowest rated 

quality class. 

Much of the unit does appear to be in a natural condition, especially the rougher terrain of the 

central and south eastern sections. However there are previously operated, existing and 

proposed mineral operations all along the southern boundary and this area is not in a natural 

condition. 

There is some screening provided by terrain but little or none is provided by vegetation. 

Although human use levels appear to be very low through most of the year in the unit, with the 

exception of localized areas like the ACEC, the opportunity for solitude is not of an outstanding 

level in most parts of the unit, but is present in other portions. Sights and sounds of human use 

can be readily observed for some distance in much of the unit due to lack of topography and 

vegetation screening, as well as the existence and use on some of the vehicle routes. 

There are outstanding opportunities for primitive recreation due to the presence of prehistoric 

carving on the cliffs of Petroglyph Canyon ACEC in the eastern portion of the unit. Although 

not well known or advertised, this region does have primitive recreation (exclusively day-use 

hiking) currently occurring on it and users appear to come from local, regional, and possibly 

national regions. There are commercial outfitters offering guided tours of the area and there 

may be unauthorized guide services operating as well. The BLM has not, but may in the future, 

be required to actively manage this activity if use levels continue to increase. 

The BLM has eliminated the active mining areas along the southern boundary of the unit, as 

these impacts are visible and are not natural. The BLM has also adjusted the western boundary 

to exclude the areas and sites found there which are also not in a natural condition. 

The BLM staff then evaluated the practicality of two separate alternative boundaries; 
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The most western boundary being a point-to-point line from the southwestern 1⁄4 corner point of 

the Montana State lands (Section 16) in a southwesterly direction until it leaves public lands 

towards the corner point of Sections 19, 20, 29 and 30, T 9 S., R 26 E, and the other being a 

combination of a little used vehicle route (PM 1063), and fence lines which run southwesterly 

and then southerly until they reach the edge of the mining disturbance in Section 28. The staff 

chose the more westerly boundary because although it is a more difficult boundary, it includes 

approximately 1050 acres of relatively undisturbed lands. 

The revised unit meets the size criteria (5,659 acres in size) 

Within this new boundary, the staff evaluation revealed that current conditions have changed 

since the initial inventory in 1979. The lands have been either closed to all use or restricted to 

administrative OHV use since 2001. The visual impacts of human disturbance can sometimes 

attract the attention of the casual observer but do not dominate the view. The majority of the 

designated vehicle routes in this area are not being used on a regular basis, only occasionally, 

and are in some cases already naturally rehabbing due to lack of any recent use. There are 

supplemental values present. 

The entire unit does not meet the conditions for consideration as possessing Wilderness 

Characteristics. There are approximately 5,659 acres which possess wilderness character, while 

approximately 3,271 acres do not. The portion of the unit which does possess wilderness 

character will be considered in the RMP. 

3.15 Cave and Karsts Resources 

The BLM has not conducted a formal inventory of cave resources; however, inventories by 

other individuals and entities identified numerous caves, principally in the Pryor Mountains. 

These inventories provide general locations, physical descriptions, and low detail maps 

(Campbell 1978 and Elliot 1963). The BLM does not promote, publish, or release information 

on cave locations to the general public. 

Caves administered by the BiFO include Mystery Cave, Sykes Cave, Four-Eared Bat Cave, 

Frogg’s Fault Cave, Royce Cave, Salt Lick Cave, Snow Drift Cave, and Four by Four Cave. 

While Mystery Cave is generally recognized as meeting the definition of a significant cave 

(below), the other caves have not been inventoried to evaluate significance. Currently there are 

no cave management plans for significant caves in the decision area. 

The Federal Cave Resources Protection Act of 1988 provided for protection of cave resources 

on federally managed lands. Provisions in the act charge the DOI to issue regulations that 

define what constitutes significant caves and identify and list significant caves on federally 

managed lands. The legislation also defines prohibited acts and criminal penalties for violation 

of the law. 

Caves may be found in a variety of geological formations including sedimentary rocks and 

volcanic lavas. Karst landforms, including sinkholes, sinking streams, resurgences, and other 
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features develop in association with limestone and dolomite. Carbonate rock outcrops like these 

are prominent in the planning area, primarily in the Pryor Mountains of Carbon County and the 

Snowy Mountains in Golden Valley County. Karst features are likely in the narrow band of 

upturned Madison Group limestone beds that flank the east and north face of the Beartooth 

Mountains. There is potential for caves in this narrow band, however, if cave development 

occurred prior to the uplift of the Beartooth Plateau the subsequent tectonic activity probably 

collapsed any caves. There is a potential for redevelopment of caves in the limestone “palisades 

area” in the vicinity of the community of Red Lodge, Montana. Numerous caves have been 

described in the Pryor Mountains of Carbon County. See Map 46 for Cave and Karst locations. 

The Pryor Mountains have several distinct fault bounded blocks dipping to the south or 

southwest with elevations ranging from 4,000 to above 8,000 feet. The Lodgepole, Mission 

Canyon, and Upper Madison formation carbonates outcrop in the middle and upper elevations. 

Elliot (1963) describes all caves forming in the Upper Madison limestone. Campbell (1978) 

describes, “Nearly every cave ... is in the upper 100 feet of the Mission Canyon Formation.”

More than 40 Caves have been found in the Pryor-Bighorn area, with at least eight of these 

located on public lands. Some caves may have been developed in the Upper Madison 

limestones beneath a cap of Pennsylvanian Tensleep sandstone. These caves may only be 

revealed as a consequence of mining in the area. 

Mystery Cave is located in the PMWHR in Carbon County, Montana. The 1984 RMP stated, 

“The BLM’s cave management policies do not allow indiscriminate entrance into Mystery 

Cave without a BLM guide” (BLM 1984). During the 1990s, access restrictions for Mystery 

Cave were relaxed, and currently access is permitted to limited groups who provide personal 

identification information and a responsible group leader. Between November and May bats 

hibernate in the cave and, consequently, access is restricted during this time of year. No other 

caves in the BiFO decision area currently receive active management. 

The 1984 RMP EIS provided minimal guidance for cave management or the protection of karst 

resources. Guidance was restricted to the policy of limiting access to Mystery Cave without a 

BLM guide and limiting access to a season from June through October, ostensibly because this 

was the period when weather and road conditions allowed guides to access to the cave. No 

mention was made of protection of bat hibernacula or any other reason for limiting access by 

season. 

The Federal Cave Protection Act of 1988 (FRCPA, PL 100-691) directed that Federal lands be 

managed in a manner which protects and maintains, to the extent practical, significant caves. 

The objectives of the BLM Cave and Karst Resources Management program found in Manual 

Section 8300 are to: 

 Carry out the direction provided by the Federal Cave Resources Protection Act 

of 1988 (FCRPA, PL 100-691) and the FCRPA Implementation Regulations at 

43 CFR, Part 37, Cave Management. 

 Manage cave and karst systems to protect and maintain their biologic, geologic, 

mineralogic, paleontologic, hydrologic, cultural, educational, scientific, 
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recreational values and other cave values from damage; and ensure that they are 

maintained for the use of the public, both now and in the future. 

 Establish surface and subsurface management practices and policies that are 

adequate to ensure long-term protection for cave and karst systems. Address 

cave and karst resources and issues in all appropriate management plans 

including recreation, wildlife, watershed, or other multi-resource activity plans 

and, as applicable, in NEPA documents. 

 Ensure the listing of caves meeting the significance criteria and the 

confidentiality of cave locations. 

 Promote consistency among Federal agencies with cave management 

responsibilities, where appropriate; and facilitate the efficient and effective 

exchange of information between Federal, State, and local agencies, private 

organizations, research institutions, and individuals concerned with the 

management, protection, or scientific investigation of cave resources. 

It is current BLM policy, as articulated by the “stay out, stay alive” campaign, to discourage the 

public from entering underground features (caves, karsts, and abandoned mines) on public 

lands, as they risk injury or death, as well as potentially increase the risk of transferring White 

Nose Syndrome among vulnerable bat populations. Despite the high risk, a number of the local 

caves are known, some are advertised as specialty destinations for cavers, and some do receive 

use by cavers and casual users. 

3.16 Resource Uses 

This section provides information on the current condition of resource uses that could be 

affected by the revised RMP alternatives described in Chapter 2. Resource uses discussed in 

this RMP include: 

 Energy and mineral resources 

► Coal 

► Fluid minerals (oil, gas, geothermal) 

► Locatable minerals (gold, silver, copper, etc.) 

► Mineral materials (sand and gravel) 

 Forestry and woodland products 

 Realty, Cadastral Survey, and Lands 

► Land tenure, adjustment, and access 

► Rights-of-way, leases, and permits 

► Withdrawals 

 Livestock grazing 

 Recreation and visitor services 

 Trails and travel management 

 Renewable energy 
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 Transportation and facilities 

3.17 Energy and Mineral Resources 

Mineral resources managed by the federal government are categorized by statute, and the 

mineral categories below are used to manage mineral resources on federally administered 

lands. 

Leasable minerals are those leased to individuals for exploration and development. They are 

acquired by applying to the federal government for a lease to explore and develop the minerals. 

Leasable minerals are subdivided into two classes, fluid and solid. Fluid minerals include 

geothermal resources and associated by-products, oil and gas, oil shale, native asphalt, oil 

impregnated sands, and any other material where oil is recoverable by special treatment after 

the deposit is mined or quarried. Solid leasable minerals are specific minerals such as coal and 

phosphates. These minerals are acquired through the following: the Mineral Leasing Act of 

1920, as amended and supplemented, Mineral Leasing Act for Acquired Lands of 1947, as 

amended, and the Geothermal Steam Act of 1970, as amended (AGI 1997). 

Saleable Minerals or Mineral Materials are common variety minerals that may be obtained 

through a free use permit by federal, state, and local governments and qualified nonprofit 

groups. Sales for common variety minerals must be obtained by commercial and private 

entities. Examples include sand, gravel, pumice, petrified wood, and common dimension stone. 

Saleable minerals are regulated by the Federal Materials Act of 1947 and the Multiple Surface 

Act of 1955. 

Locatable Minerals are all minerals subject to exploration, development, and production under 

provisions of the Mining Law of 1872. Locatable minerals include both metallic and nonmetallic minerals such as gold, silver, specialty clays, and zeolites. 

3.17.1Solid Leasable Minerals 

BLM considers proposals for developing federal leasable minerals (coal, phosphate, sodium, 

potash, sulfur, oil shale, native asphalt, and solid and semisolid bituminous rock) on a case by 

case basis. Site specific environmental analysis is required to lease these minerals. While 

occurrences of solid leasable minerals are present in the decision area, no significant production 

of these minerals, with the exception of coal, is currently underway or anticipated. 

3.17.1.1 Coal

Coal beds are present at various stratigraphic intervals within the coal fields that are located in 

the planning area, including the Cretaceous Eagle, Judith River, Hell Creek and the Paleocene 

Fort Union Formations (Map 47). The Judith River and Hell Creek Formations contain coal 

which is generally thin (less than 2 feet thick) and often has a high content of volcanic ash, 

lowering its quality. These formations crop out (are present at the surface) in western 

Musselshell and Yellowstone counties and in northern Carbon County. Due to the lack of 

geologic data, the development potential for coal beds occurring in these two formations is 

unknown. 
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Within the planning area, coal has been historically mined from beds occurring in the Eagle and 

Fort Union Formations. The only coal that is currently being produced in the planning area is 

from the Fort Union Formation in the Bull Mountain coal field near Roundup, Montana. 

Following, is a description of the geology, historical production, and coal resource 

development potential of the coal fields which occur in the planning area. The coal resource 

estimates stated in this document are just “estimates.”

3.17.1.1.1 Bridger and Joliet-Fromberg Coal Fields 

The coal-bearing Eagle Formation crops out over a large area in the planning area, forming 

rimrocks along the Yellow¬stone and Clarks Fork River valleys. In the southern part of the 

planning area (Carbon County), coal occurs in the middle (shale) member of the Eagle 

Formation. Coal resources occur in an area bounded on the north by Rock Creek and on the 

south and east by the Clarks Fork River (see Figure 3-18). Shale or “bone” (shaley coal) 

partings within the Eagle Formation coal horizon separate the coal into as many as three 

distinct beds. The position of these partings within the coal horizon influenced how the coal 

was mined and impacted its overall quality. 

The Fromberg fault offsets the Eagle Formation outcrop effectively divid¬ing the coal resource 

into two separate coalfields; the Bridger and Joliet/Fromberg (Cannon, 1986). Underground 

mines were opened in this area in the late 1800s. The primary coal bed crops out along an 

approximate north-south line from Joliet to a point about two miles southwest of Fromberg, 

where it has been displaced by the fault (Figure 3-18). The coal bed is subbituminous to 

bituminous in grade and ranges in thickness from 12 to 65 inches, with partings of shale or 

carbonaceous shale (Knappen and Moulton, 1931). The coal bed is locally called the Bridger 

coal because of past production of the coal from mines at Bridger, Montana. However, several 

small mines were opened west of Fromberg. The mines shut down in the 1930s. Although no 

total production figures are available, over 100,000 tons were produced in 1907. 

The coal resources for the Bridger coal field can only be estimated with a high degree of 

uncertainty. There has been no recent exploration in the coal field and the only production 

records are from coal mines that were abandoned nearly 100 years ago. The coal field 

encompasses approximately 13,720 acres, of which, 10,240 acres are federally owned (Figure 

3-18). If the measured thickness of 4 feet of coal is consistent throughout the coal field, the 

total estimated coal resource is approximately 100 million tons (75 million tons federal). If 

conventional (room and pillar) underground mining is employed, approximately 50%, or 38 

million tons of federal coal are recoverable. 

There has been some recent interest expressed in federal coal in the Joliet-Fromberg coalfield. 

A group of investors obtained leases on private mineral lands near the coal outcrop and lease 

options from some surface owners overlying federal coal resources. It was also reported that 

some exploratory drilling had occurred on private mineral lands. Federal coal ownership forms 

nearly a solid block of coal-bearing lands approximately 8 miles long and 3 to 4 miles wide 

located 0.5 mile inside the outcrop. 
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Figure 3-18 Location of the Bridger and Joliet-Fromberg Coal Fields 
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In 1982, the BLM conducted a Known Recoverable Coal Resource Area study in the JolietFromberg coalfield. These studies were conducted in areas where federal coal has high to 

moderate development potential through surface or underground mining methods. The area of 

prospective surface minable coal encompasses approximately 1,360 acres, of which 320 acres 

are federal. Coal resources within that area were estimated at 13 million tons (approximately 2 

million tons federally owned). Applying a 90% recovery rate, over 2 million tons of federal 

coal are potentially surface mineable. 

The area of prospective underground minable coal in the Joliet-Fromberg coal field is much 

larger. Approximately 8,680 acres of federally owned coal occurs in this area. Approximately 

69 million tons of coal has been identified (46 million tons federal coal). Assuming that room 

and pillar underground mining would be employed, 50% of the coal, or approximately 34 

million tons (23 million tons federal coal) would be potentially recoverable. 

3.17.1.1.2 Silvertip and Stillwater Coal Fields 

The Silvertip and Stillwater coal fields (Figure 3-19) are relatively small and are located in the 

extreme southern and southwestern part of the planning area. These coalfields also contain 

coal from the shale member of the Eagle Formation. The coal is fairly uniform, averaging 

approximately 4 feet thick in two or three beds, separated by shale partings. Only small 

quantities of coal were produced from either field, though many prospects were noted on older 

topographic maps, and some may still be visible on the surface. The only potential for renewed 

development in these fields would be small quantities for local domestic use, which is unlikely. 

Potential coal development in the Silvertip coalfield may conflict with production from the Elk 

Basin oil field, which also occupies a similar area. 

Federal ownership of coal is scattered in the Stillwater coal field. However, the coal outcrop in 

the Silvertip field occurs almost entirely within federal ownership. An accurate estimate of the 

recoverable coal resources within these coal fields has not been made. 
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Figure 3-19 Location of the Stillwater and Silvertip Coal Fields 
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3.17.1.1.3 Red Lodge-Bearcreek Coal Field 

The Red Lodge-Bearcreek coal field contains coal from the Fort Union Formation. Within the 

coal field, nine separate coal beds occur within an 825 foot stratigraphic interval of the middle 

member of the formation (Roberts and Rossi, 1999). Figure 3-20 provides a generalized 

stratigraphic column of the coal-bearing middle member of the Fort Union Formation in the 

Red Lodge-Bearcreek coal field. 

The coal field is approximately 16,320 acres in size and is located in southern Carbon County 

(Figure 3-21). The areal extent of the coal field is limited on the east and north by the line of 

outcrop, on the south by the gradual thinning of the coal beds, and on the southwest by the 

Beartooth thrust fault. West of Rock Creek, the coal lies in a narrow, steeply dipping zone 

which terminates against the Beartooth fault (Woodruff, 1909). Small geologic structures 

interrupt the general southwesterly dip of the strata. Several thin igneous dikes cut the strata, 

but they did not interfere with past coal production. The coal field includes the Red Lodge and 

Bearcreek mining districts, which are separated by a high topographic ridge. 

There is a long history of coal mining in the Red Lodge and Bearcreek areas. The first mine 

opened near Red Lodge just prior to 1882, but up to 1889, operations were conducted on a 

small scale (Woodruff, 1909). Production increased from 232,000 tons in 1886 to over 1 

million tons by 1917. Most of the coal was used by the Northern Pacific Railway, though some 

went to the Anaconda smelter near Butte, Montana. Around 1924, demand for this coal began 

to diminish due to competition from the open pit mine at Colstrip, Montana. In 1932, the mines 

closed. Over 11 million tons of coal had been produced, entirely by underground, room and 

pillar mining. Coal was also mined under the town of Red Lodge. 

Mining in the Bearcreek area progressed a little behind the Red Lodge area. Production was 

very limited until the railroad from Bridger to Bearcreek, Montana was completed in 1906. At 

least eight mining companies were operating in the area in the early 1900s. Production peaked 

in the early 1920s and began to decline in 1926 due to competition from oil and gas. World 

War II provided impetus for increased production, but after the war, production again declined. 

After abandonment of the Bearcreek-Belfry railroad spur in 1953, only small scale mining and 

trucking of coal to Red Lodge kept the field from closing entirely. Eventually, all mining 

activity ceased. Total production from the district was approximately 13 million tons. The 

Beartooth Coal Company, owned by Portland General Electric, reopened the Brophy 

underground mine in 1980. That year, over 7,000 tons of coal was produced. Due to labor 

problems and a soft coal market, the mine shut down. 

Federal coal ownership in the Red Lodge-Bearcreek coal field consists of approximately 

16,320 acres, primarily located in the south and southwestern portions of the coal field (Figure 

3-21). An accurate estimate of the federal coal resource in this area has not been made due to 

the lack of geologic data. However, in an evaluation of six coal beds, each greater than 4 feet 

thick in the Bearcreek district, Rawlins (1986) estimated that the total Fort Union Formation 

coal resources in this area may exceed 700 million tons. Approximately half of this estimate 

would be potentially recoverable by conventional underground mining methods. Should 

longwall mining be used, the potential coal recovery rate would be higher. Longwall mining is 

a form of underground coal mining that is more productive than conventional room and pillar 

mining. It involves the removal of a large block of coal in a series of slices. The longwall 
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panel (the block of coal that is being mined) is typically 0.25 miles in width and several 

thousand feet long. Mining large blocks of coal in this manner facilitates a higher recovery rate 

of the coal resource. 

In late 2013, it was reported by the Montana Department of Environmental Quality (MDEQ) 

that a private company completed an exploration drilling program on non-federal coal in the 

Bearcreek area. 

Figure 3-20 Generalized stratigraphic column showing Fort Union Formation coal beds in 

the Red Lodge-Bearcreek coalfield. Stratigraphy adapted from Woodruff 

1909, Rawlins 1986, and Roberts and Rossi 1999 
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Figure 3-21 Location of the Red Lodge-Bearcreek Coal Field 
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3.17.1.1.4 Bull Mountain Coal Field 

The Bull Mountain Coal Field occurs within the Bull Mountain Basin which is located in 

south-central Montana (Figure 3-22). The basin is an asymmetrical, shallow synclinal trough 

that trends generally 140° southeast and plunges approximately 0.8° toward the northwest. 

Regional dips of 1° to 4° inward toward the axis of the syncline are common. The area of coalbearing rocks is roughly elliptical in shape, about 50 miles long and 30 miles wide with its long 

axis oriented roughly east-west (Woolsey and others, 1917). 

The Bull Mountain Coal Field contains coals that occur in the upper portion of the Tongue 

River Member of the Fort Union Formation. Twenty-six coal beds have been mapped and 

named (Figure 3-23). Most of the beds are lenticular, showing a wide variation in thickness 

and areal extent (Woolsey and others, 1917). Coal beds may be thicker in some parts of the 

coal field, and either thinner, or absent in other parts of the coal field. Connor (1989) reported 

that coal in the Bull Mountain Coal Field ranges in apparent rank from subbituminous A to 

high volatile bituminous C. 

Coal mining in the Bull Mountain Coal Field came into prominence in 1906-1907 following the 

construction of the Pacific coast extension of the Chicago, Milwaukee & St. Paul Railway 

(Woolsey and others, 1917). Prior to that, there was only a small amount of coal being 

produced in the area primarily for local use. Soon after the railway was completed, mining 

began on a large scale in the Roundup bed in the northwest part of the coal field. Most of the 

40 million tons of coal produced from this bed was from underground mines located near 

Roundup and Klein, Montana. 

3.17.1.1.5 Mammoth Coal Bed 

The only coal currently being mined in the Bull Mountain Coal Field is from the Mammoth bed 

which occurs near the middle of the Tongue River Member of the Fort Union Formation 

(Figure 3-24). The Mammoth is probably the most consistent (thickness) and laterally 

extensive coal bed in the Bull Mountain Coal Field. The coal bed averages approximately 9 

feet thick. The Rehder bed (1.5 to 4 feet thick), which directly overlies the Mammoth bed, 

coalesces with the Mammoth in the central and eastern portion of the coal field. In these areas, 

the combined bed, also referred to as the Mammoth bed, averages 13 to 14 feet thick and can 

attain a thickness up to 16 feet. Along the outcrop of the Mammoth bed, the coal is often found 

burned due to natural causes such as spontaneous combustion, lightning strikes or wildfires. 

However, in some areas, it appears that the burning did not progress very far in from the 

outcrop. 

Due to its consistent thickness and significant areal extent, the Mammoth coal bed can be 

developed through both surface and underground mining methods. Since the structure of the 

coal bed in the coal field is relatively level, overburden depth on top of the coal, inward from 

the outcrop, increases as a direct function of topography. Therefore, in areas inside the 

Mammoth outcrop (Figure 3-25), where the overburden overlying the Mammoth bed is 

minimal due to subtle (flat) topography, it may be economic to mine the coal bed using surface 

mining methods a significant distance beyond the outcrop. However, other factors such as coal 

quality, market conditions, and the amount of coal burned at the outcrop may influence this 
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distance. Beyond the surface mining limit, additional coal could be recovered by employing 

coal auger or highwall mining methods. 

Figure 3-22 Location of the Bull Mountain Basin, south-central Montana. Basin extent is 

drawn at the Lance-Fort Union Formation boundary. “K” denotes Cretaceous 

rocks and “T” denotes Tertiary rocks (from Stricker, 1999)
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Figure 3-23 Generalized coal stratigraphy showing the principal coal beds in the Bull 

Mountain Basin. Stratigraphy modified from Woolsey and others 1917, 

Connor 1989; and Stricker 1999 
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Highwall mining is a method of surface coal mining that originated from auger mining. The 

method differs in that continuous miners, rather than augers, are used to bore an entry into the 

coal bed of a highwall left behind in a surface mine after coal removal has been completed. 

Screw conveyors positioned behind the continuous miner transport the cut coal from deep 

within the bed up to an outside stockpiling area. Another primary difference in a highwall 

mining operation is that it is carried out by remote control at the surface where an operator 

located in a cabin uses a television camera to monitor and control the progress of the 

continuous miner machine 

Using a 10:1 (overburden thickness to coal thickness) strip ratio cutoff, the area of potential 

surface minable Mammoth coal encompasses approximately 25,000 acres (11,000 acres 

federal) resulting in an estimated 580 million ton (250 million ton federal) coal resource (see 

Figure 3-25). Employing a 90% surface mining recovery rate, approximately 522 million tons 

(270 million tons federal) of Mammoth coal are recoverable in the Bull Mountain Coal Field. 

Figure 3-25 shows the approximate area of surface minable Mammoth coal in the Bull 

Mountain coalfield at a less than 10:1 strip ratio. Table 3-47 provides the surface minable 

Mammoth coal resource estimate: 

Table 3-47 Surface Minable Mammoth Coal Resource Estimate 

Surface Minable Mammoth Coal Resource Estimate*

Resource Ownership Non-Federal Federal Total

Acreage 14,000 11,000 25,000

Million Short Tons 330 250 580

* Coal thickness ˃ 2 feet thick considered minable (includes Rehder coal bed), assumes 12.5’ average coal 

thickness, coal density = 1,873 tons/acre-foot, acreage values are approximate. 

The area of potential underground minable Mammoth coal encompasses approximately 32,000 

acres resulting in an estimated 605 million ton coal resource. Federal coal ownership 

constitutes approximately 12,000 acres resulting in an estimated 228 million ton coal resource 

within the Bull Mountain Coal Field. Approximately 50% of this coal could be recoverable 

utilizing a conventional room and pillar mining technique. Utilizing a longwall mining 

technique, an additional 30% of the coal resource may be recovered. Data used in estimating 

the Mammoth coal bed resource were obtained from Burlington Northern Coal Company. 
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Figure 3-24 Outcrop of the Mammoth coal bed in the Bull Mountain Coal Field 
Billings and Pompeys Pillar National Monument 

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Figure 3-25 Mammoth coal bed – Approximate surface mining area ˂ 10:1 strip ratio 
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Table 3-48 Underground Minable Mammoth Coal Resource Estimate 

Underground Minable Mammoth Coal Resource Estimate*

Non-Federal Federal Total

Acreage 20,000 12,000 32,000

Million Short Tons 377 228 605

* Assumes 10 foot average coal thickness, coal density = 1,873 tons/acre-foot, acreage values are approximate. 

The total Mammoth coal resource estimate is shown in Table 3-49: 

Table 3-49 Mammoth Coal Resource Estimate 

Mammoth Coal Resource Estimate*

Non-Federal Federal Total

Acreage 34,000 23,000 57,000

Million Short Tons 707 478 1,185

* Include potential surface and underground mining areas 

Although the Mammoth coal bed was heavily prospected between 1910 and 1920, very little 

development occurred during the early part of the 20th century. The inaccessibility of the coal 

bed at that time may have limited its development. The PM Coal Company opened a small 

underground mine in the Mammoth bed in 1932 that produced Burlington Northern Railroadowned coal until 1973. In 1973, PM Coal Company opened the PM surface mine which 

produced 15,000 to 25,000 tons of coal per year from the Mammoth bed. 

The Divide Coal Company had operated an underground mine in the Mammoth bed for many 

years on privately owned coal (Table 3-48). In 1962, the company was issued a Federal lease 

(M-052647) and began mining federal coal. The mine was converted from an underground 

mine to a surface operation in 1972 (the company felt it could not economically comply with 

the Federal Coal Mine Health and Safety Act of 1969). The Divide Coal Company was mining 

in the direction of the abandoned underground mine. 

In the early 1970s, Consolidation Coal Company and the Montana Bureau of Mines and 

Geology completed various investigations on the quantity and quality of the Mammoth coal 

bed and a regional hydrology study in the Bull Mountain area. Consolidation Coal Company 

opened a test pit in the Mammoth bed in the northwestern part of the coal field in 1971 (Table 

3-49). To determine its suitability for generating electricity, approximately 50,000 tons of coal 

was mined as a pilot project. The company also wanted to test several reclamation techniques. 

Although the coal proved suitable for use in coal-fired utilities, no further coal development 

occurred. 

Louisiana Land and Exploration Company also conducted coal investigations in the Bull 

Mountain Coal Field and began undertaking environmental and economic feasibility studies in 

1979, with the hope of obtaining a permit to underground mine Burlington Northern-owned 
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coal. The company withdrew its application in late 1981 after determining that new 

development was economically unfeasible. 

Meridian Land and Minerals Company (a wholly owned subsidiary of Burlington Northern) 

had expressed interest in exchanging federal coal rights for Burlington Northern coal rights in 

the Bull Mountain Coal Field with the intention of consolidating their coal holdings. Two land 

exchanges occurred with the BLM, one in 1991 and the other in 1993. 

A stumbling block to coal mining in the Bull Mountain Coal Field was the lack of rail service. 

The Burlington Northern Railroad had purchased the Milwaukee Road right-of-way between 

Slayton and Gage, Montana. Therefore, the construction of a spur to that line would be 

required to provide access to the coal field. Other forms of transportation to carry large 

volumes of coal from the coalfield were impractical. 

In the late 1980s, Meridian Land and Minerals Company acquired the rights to mine the 

Mammoth bed in the area and also purchased the PM Mine. In 1989 and 1990, they permitted 

and mined a surface test pit adjacent to the underground mine (Bull Mountains Mine No. 1) and 

extracted approximately 180,000 tons of coal for test burn purposes. In 1990, they also 

submitted a permit application to the Montana Department of Environmental Quality (MDEQ) 

for reopening the existing Bull Mountains Mine No. 1 (Figure 3-24) and was issued a state 

mine permit in 1993. Since that time, the permit has been transferred to several ownership 

entities and was acquired by Signal Peak Energy (SPE) in 2008. In 2008, SPE also submitted 

an application to the BLM to acquire the federally-owned coal reserves on five lease tracts. 

The lease tracts, totaling 2,679.76 acres, contain an estimated 61.4 million tons of in-place coal 

reserves in the Mammoth coal bed. 

In 2009, SPE successfully amended their state mine permit to incorporate both continuous and 

longwall underground mining methods. A 35-mile rail line was constructed connecting the 

mine to the Burlington Northern/Santa Fe mainline track near Broadview, Montana. In 2012, 

the BLM conducted a lease sale for the federal coal tracts and SPE was the successful bidder 

for federal lease MTM 97988. In 2013, some of this federal coal was mined during longwall 

development work. The Bull Mountains Mine No. 1 is currently producing coal at a 10 million 

ton per year rate. In 2013, SPE also conducted exploration drilling to evaluate the surface mine 

development potential of the Mammoth bed in areas adjacent to their underground mining area. 

An application to explore for federal coal and private coal underlying federal surface lands was 

also submitted to the BLM that year. 

On December 19, 2014, the National Defense Authorization Act of 2015 was signed into law. 

Section 3077 of this act, the Northern Cheyenne Lands Act authorizes the conveyance of 

approximately 10,000 of federal coal located in Big Horn and Mussellshell counties to Great 

Northern Properties Limited Partnership (GNP). In turn, GNP will convey all of its coal and 

iron ore interests underlying the Northern Cheyenne Reservation to the Tribe. 

The eighteen federal coal tracts conveyed to GNP in Mussellshell County comprise 

approximately 7,952 acres located within the Bull Mountain Coal Field (Figure 3-26). The 

tracts contain approximately 41.4 million tons of saleable coal in the Mammoth coal bed 

(Norwest Corporation, 2014). Several of these tracts occur within SPE’s Bull Mountains Mine 

No. 1 mine plan area. 
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3.17.1.1.6 Carpenter and McCleary Coal Beds 

The Carpenter and the McCleary coal beds may also have the potential to be developed in the 

Bull Mountain Coal Field. The Carpenter bed occurs approximately 450 feet above the Lebo 

Shale Member of the Fort Union Formation (Figure 3-27). These coal beds have the potential 

to be developed in the northeastern part of the Bull Mountain Coal Field, in an area that is 

located south of Melstone, Montana. Between 1907 and 1909, these beds were mapped by the 

United States Geological Survey (USGS) and numerous outcrops were measured in the 

Carpenter and Lost Horse Creek drainages. An 8 foot 2 inch thick outcrop of the Carpenter bed 

was measured in the Carpenter Creek drainage (Woolsey and others, 1917). In this drainage, 

the McCleary bed occurs approximately 50 feet above the Carpenter bed and coal outcrops 

measured by the USGS in that area ranged between 3 to over 4 feet in thickness (Woolsey and 

others, 1917). 

 In 2006, Carpenter Creek, LLC began the process to permit and develop a surface mine that 

also considered highwall mining in the Carpenter Creek area. The company had indicated that 

there was sufficient resource present in the two coal beds to warrant development of a surface 

mine and possibly an underground mine. The company submitted a mine permit application to 

the MDEQ to develop a test pit in the McCleary and Carpenter coal beds on private coal within 

this area. The company also indicated that future development could possibly include federal 

coal using both surface and underground mining methods. In 2010, Great Northern Properties 

(GNP) assumed control of the mine permitting effort. It was reported by the MDEQ that GNP 

conducted exploration drilling in that area in 2011 and 2012. 

Although the BLM does not possess sufficient geologic data to provide a resource estimate for 

the Carpenter and McCleary coal beds in the Carpenter Creek drainage area, early USGS field 

mapping data and recent industry interest suggest that these two beds may constitute a resource 

that could be developed either by surface or underground mining methods. The size of the 

resource would be dependent upon the thickness and lateral continuity of the coal beds. 

The area located southeast of Carpenter Creek, on the south side of the divide that separates the 

Yellowstone and Musselshell drainages, may have the potential to support development of the 

McCleary bed coal bed. Early USGS field data indicated that the McCleary bed outcrops in T. 

8 N., R. 31 E. The bed crops out in the extreme northern part of the township above the head 

of Cabin Creek and continues down the creek approximately two miles to the southeast, and 

then turns southwest, extending through the head of Alkali Creek, and across the Weed Creek 

drainage (see Figure 3-26). Nine McCleary coal bed sections were measured which ranged in 

thickness between 2 feet 5 inches to 8 feet 8 inches (Woolsey and others, 1917). However, 

along the McCleary bed outcrop through the northern half of the township, the thickness ranges 

from almost 7 feet to over 8 feet. The underlying Carpenter coal bed in the northern portion of 

the township is significantly burned. The thickness and extent of the burn may indicate the 

presence of a relatively thick coal bed in this area, beyond the extent of the burn. 
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Figure 3-26 Location of Federal Coal Tracts Conveyed to Great Northern Properties 

Limited 
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Figure 3-27 McCleary Coal Bed Outcrop in the South Divide Resource Area, Bull 

Mountain Coal Field 
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In 1982, the BLM conducted a Known Recoverable Coal Resource Area study of the McCleary 

seam in this area, which is referred to as the South Divide Resource area. These studies were 

conducted in areas where federal coal has high to moderate development potential through surface or underground mining methods. At South Divide, the area of surface mineable coal totals 

approximately 5,640 acres, of which 1,280 acres are federally owned (see Figure 3-27). Coal 

resources within that area were estimated to be 43 million tons (9 million tons federal). At a 

90% recovery rate, over 8 million tons of federal coal in the McCleary coal bed is considered 

recoverable. The corresponding area of underground minable coal covers approximately 3,120 

acres, containing an estimated 26 million tons of coal. The federal ownership in this area is 

400 acres, resulting in approximately 2 million tons of mineable resource. Assuming the coal 

would be mined by room and pillar method, 50%, or 1 million tons would be recoverable. 

Should longwall mining be used, the coal recovery rate would be higher. 

3.17.1.1.7 Summary 

Future coal development will likely occur in the Bull Mountain Coal Field and may occur in 

the Red Lodge-Bearcreek Coal Field. The presence of coal processing and transportation 

facilities at SPE’s Bull Mountains Mine No. 1 may play a role in this increased development in 

this coal field. Coal from the Bull Mountain Coal Field will continue to be shipped to domestic 

power plants and exported overseas for electricity generation. Future coal development in the 

planning area may increase as a result of the completion of export facilities located on the west 

coast of the United States. In addition, transportation and coal quality advantages enhance the 

export marketability of coal in the planning area. It is also possible that future coal leasing 

activity could support coal conversion technologies such as in-situ gasification or coal-toliquids projects. 

Although recent coal exploration activities have been conducted in the Bull Mountain and Red 

Lodge-Bearcreek coal fields, additional exploration efforts will be required to further evaluate 

the development potential of the coal resource in these areas. Applications for federal coal 

exploration licenses and coal leasing will be evaluated by the Billings Field Office. 

3.17.1.1.8 Coal Resource Objectives and Planned Actions 

The Billings Field Office planning area will be open for federal coal exploration license 

applications. Licenses to mine federal coal for domestic use will be available as long as 

production does not annually exceed 20 tons. Federal coal leasing by application (LBA) will 

remain available for both underground and surface mining considerations. The unsuitability 

criteria will be applied to the lease application area and a plan amendment to the current RMP 

will be prepared if necessary. Prior to approving exploration licenses, licenses to mine 

(domestic), and coal lease applications, a project-specific environmental review document will 

be prepared to assess impacts and develop mitigation measures. 

The federal coal leasing decisions that were made in the previous RMP will be brought forward 

and adopted in this RMP: 

 All federal coal that is minable by underground methods is suitable for further 

consideration for leasing or exchange, pending further study. Within the planning area, 

potential coal resource underground mining development areas occur in the Bull 

Mountain Coal Field located in Musselshell and Yellowstone counties and in the Red 
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Chapter 3: Affected Environment 3-177

Lodge-Bearcreek Coal Field located in Carbon County. The coal unsuitability criteria 

will not be applied to the lands comprising the coal application area until a site-specific 

mine plan is filed that details the proposed locations of surface facilities. 

 Within the planning area, surface coal mining development areas occur within the Bull 

Mountain Coal Field and are suitable for further consideration for leasing or exchange, 

pending further study. Within this area, federal coal with a strip ratio less than 10:1, 

that can be mined by surface methods must first be screened to determine their 

development potential, surface owner opposition to mining, the presence of 

unacceptable environmental conflicts (unsuitability criteria), and multiple use conflicts 

in accordance with the four coal screens. The application of the coal screens also 

includes the consideration of the unsuitability criteria. 

In 1984, surface owners of land overlying federal coal in the Bull Mountain Coal Field in the 

Mammoth and McCleary beds (South Divide Resource Area) were consulted to determine their 

preference for or against leasing their land for surface mining. Due to the significant amount of 

time that has elapsed since the consultation was conducted, it was decided not to include that 

data in the RMP. 

Federal coal lease applications and exchange proposals will be considered on a case-by-case 

basis. The coal screening process will be applied to future lease application areas that have 

surface mine development potential. 

3.17.1.1.9 Decision Rationale 

This action was selected because it will enable the BLM to comply with the multiple use 

mandates established by FLPMA and the 43 CFR 1600 regulations governing multiple use 

planning. Furthermore, it will allow the BLM to comply fully with the Surface Mining Coal 

Reclamation Act (SMCRA) and the 43 CFR 3400 regulations established to govern the federal 

coal management program. Although development of federal coal resources by surface mining 

methods will be allowed in the Bull Mountain Coal Field, underground mining will be 

encouraged, because it is less environmentally disruptive. The decision to implement a 10:1 1 

(overburden thickness to coal thickness) stripping ratio cutoff limit was based on the premise 

that it may limit the size of the surface mine. 

3.17.2Fluid Minerals 

3.17.2.1 Geothermal Energy 

Geothermal energy is derived from heat in the earth’s crust that is released as hot water and 

steam. Due to a variety of geologic processes, geothermal resources underlie substantial 

portions of many western states, including lands in the BiFO planning area. However, there is 

presently only a very low level of interest in developing Montana’s federally owned geothermal 

resources. The US Geological Survey (Williams 2008) gave eastern Montana a low favorability 

rating for the occurrence of geothermal resources in the planning area. 

Geothermal resources in the planning area are classified as low temperature (less than 194oF); 

there are at least six known thermal springs or warm drill holes in and immediately adjacent to 
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the planning area with measured temperatures ranging from 103oF to 165oF (Montana DEQ 

2007). There are no geothermal power plants in Montana because there are no identified high 

temperature resources in the state. The BLM has received only two inquiries about 

development of federal geothermal resources in Montana (both in western Montana) since 

1979. There are no inventoried direct use facilities using geothermal heat in the planning area 

(Geo-Heat Center 2008). 

3.17.2.2 Oil and Gas

Oil and gas fields are scattered throughout the BiFO planning area with fields primarily 

concentrated in northern Musselshell County and southern Carbon County (Big Snowy uplift 

and Elk Basin areas). The only county in the planning area with no production is Wheatland 

County. Map 48 – identifies active oil and gas fields and development in the planning area. 

The first drilling in Montana occurred near the ‘Cruse’ oil seeps, in Carbon County, in about 

1890. Drilling occurred along strike (northwest-southeast) to the Beartooth Mountain front. 

Only small volumes of low gravity oil were reportedly produced. 

The Elk Basin area in Carbon County experienced early development as an extension of the 

Wyoming portion of the field. The first drilling occurred about 1915; this activity pre-dated the 

Mineral Leasing Act of 1920. At that time, oil was developed as a placer mineral on mining 

claims located under the General Mining Act of 1872, as amended by the Petroleum Placers 

Act of 1897. Many of these petroleum placers went to patent (became private land). 

Further drilling occurred as operators attempted to expand the known producing area along the 

axis of the Elk Basin anticline. Field limits were extended to the northwest, with the later 

discoveries at Elk Basin Northwest, Clarks Fork, the Clarks Fork North and Clarks Fork South 

fields. In the same time frame (1910s-1920s), exploration occurred at the Dry Creek Dome in 

central Carbon County. Natural gas was discovered there in 1919 and extended into Golden 

Dome in 1962. 

In Big Horn County, the Soap Creek Oil Field was discovered in 1920 and then expanded by 

new drilling as recent as 2005. The Hardin Gas Field was discovered in 1928 and expanded as a 

result of new drilling into the 1930s, with the most recent well drilled in 1975. 

Early prospecting for oil was concentrated around geologic structures that were exposed at the 

surface. These structures, often called “Sheepherder Anticlines”, were believed to be indicators 

of potential oil reservoirs in subsurface structures. Most of the early exploration and 

development occurred in proximity to these exposed anticlines and domes. Many O&G fields 

are still identified by these surface structures (i.e., Golden Dome, Gage Dome, and Dean 

Dome). Often, the earliest wells drilled in these structures were not drilled deep enough and did 

not achieve a discovery. 

Many other anticlines were ‘breached’ by erosion that exposed the reservoir rock leaving only 

stained or bleached rock as indications of the past presence of oil. This is the case on the east 

flank of Red Dome in Carbon County. Here, the Triassic Chugwater Formation red beds have 

zones of sandstones that are gray; the oil, while it was in the rock, prevented the oxidation of 

the iron in the rock matrix and cement. 
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The first drilling in Musselshell County was not successful; however by 1920, oil was 

discovered in the Heath Lime at Devil’s Basin field. By the end of 1921, oil had been 

discovered in the Soap Creek field in Big Horn County and the Lake Basin field in Stillwater 

County. Mosser Dome field in southwestern Yellowstone County opened in 1936. 

In the 1940s, additional oil fields were discovered in Musselshell County, including Gage 

Dome, Ragged Point, Big Wall, and Melstone. All were surface structures (‘Sheepherder 

Anticlines’) with the oil found in Mississippian carbonate rocks (Amsden, Kibbey, Heath, and 

Tyler Formations). New fields were discovered in surface structures (Ivanhoe, Stensvad, 

Delphia, Hawk Creek, Hiawatha, Keg Coulee, Pole Creek, Mason Lake), and existing fields 

were expanded into the 1960s. Similarly, exploration of the surface structure at Wolf Springs 

resulted in an oil discovery in Yellowstone County in 1955 and at Weed Creek in 1967. 

The first gas production in Sweet Grass County occurred when the Six Shooter Dome field was 

discovered in 1947. First production in Golden Valley County occurred with the discovery of 

gas in the Big Coulee field in 1948. Later that year oil was discovered in Golden Valley’s 

Woman’s Pocket and Devil’s Pocket fields. 

In 1953 the Ash Creek field in southern Big Horn County was discovered, with oil produced 

from the Upper Cretaceous Shannon-Formation. The Mackay Dome and Roscoe Dome fields, 

in southern Stillwater and Carbon Counties, respectively, were discovered in the late 1950s. 

Both produce from Lower Cretaceous sandstones. 

In the 1970s, the Rapelje gas field in Stillwater County was discovered. Two oil price shocks in 

the 1970s resulted in a quadrupling of the price of oil over a four year period from around 

$3.00 per barrel in mid-1973 to over $12.00 per barrel in 1977. The Islamic Revolution in Iran 

in 1979 sent oil prices still higher, with the price peaking at over $38.00 per barrel in 1981. 

The rapid increase in the price of oil resulted in a rush of new prospect generation. Even 

prospects that had a low probability of finding product were drilled. Conservation and new 

discoveries led to in an increased supply while demand was falling, resulting in a price 

collapse, with oil in Montana falling below $10.00 per barrel in early 1986. For the rest of the 

1980s, the BLM allowed operators to leave their wells ‘shut in’ (in a non-producing status). 

This policy allowed operators to maintain their wells without having to operate them at an 

economic loss. 

In 1992 the BLM terminated the shut in policy and issued new regulations that provided for a 

reduced royalty rate for oil properties that averaged less than 15 barrels of oil per well per day 

(so-called ‘stripper wells/properties’). The royalty rate reduction (RRR) was intended to reduce 

operators’ operating costs and encourage the greatest ultimate recovery of oil. The BLM 

anticipated that operators would take advantage of this incentive and work over existing wells 

to restore or increase production at these properties. The RRR would be recalculated every 

year, and could fall further if the average production rate continued to decrease. The regulation 

was in effect for about 14 years and terminated effective February 1, 2006 (when the oil price 

exceeded the threshold established in the regulation). 

In 2008, there were 48 active O&G fields in the planning area, as listed in Table 3-50. The 

earliest discovery date for a field presently producing is Elk Basin in 1915. The last new field 
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discovery was in 1991, when the Gray Blanket (Big Horn County) and Sixshooter Dome Fields 

(Stillwater and Sweet Grass counties) were established. 

Table 3-50 Active Oil and Gas Fields in the Planning Area

Field County Discovered Oil Gas

Gray Blanket Big Horn 1991 X

Lodge Grass Big Horn 1964 X

Soap Creek Big Horn 1921 X

Soap Creek, East Big Horn 1977 X

Toluca Big Horn 1983 X

Waddle Creek Big Horn 1983 X

Clarks Fork Carbon 1954 X X

Dry Creek Carbon 1929 X X

Dry Creek (Shallow Gas) Carbon 1975 X

Dry Creek, Middle Carbon 1958 X X

Dry Creek, West Carbon 1976 X X

Elk Basin Carbon 1915 X

Elk Basin, Northwest Carbon 1964 X

Golden Dome Carbon 1953 X X

Big Coulee Golden Valley 1954 X

Big Gully Musselshell 1976 X

Big Wall Musselshell 1948 X

Delphia Musselshell 1967 X

Devil’s Basin Musselshell 1920 X

Gage Musselshell 1944 X

Hiawatha Musselshell 1967 X

Howard Coulee Musselshell 1974 X

Ivanhoe Musselshell 1956 X

Jim Coulee Musselshell 1971 X

Keg Coulee Musselshell 1960 X

Keg Coulee, North Musselshell 1960 X

Kelley Musselshell 1966 X

Little Wall Creek Musselshell 1981 X

Little Wall Creek, South Musselshell 1975 X

Mason Lake Musselshell 1964 X

Melstone Musselshell 1948 X

Melstone, North Musselshell 1976 X

Ragged Point Musselshell 1956 X

Ragged Point, Southwest Musselshell 1973 X
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Table 3-50 Active Oil and Gas Fields in the Planning Area

Field County Discovered Oil Gas

Stensvad Musselshell 1958 X

Tinder Box Musselshell 1988 X

Willow Creek, North Musselshell 1970 X

Winnett Junction Musselshell 1973 X

Big Coulee Stillwater 1954 X

Dean Dome Stillwater 1966 X

Fiddler Creek Stillwater 1952 X

Lake Basin Stillwater 1924 X X

Sixshooter Dome Stillwater 1991 X

Sixshooter Dome Sweet Grass 1991 X

Crooked Creek Yellowstone 1985 X

Weed Creek Yellowstone 1966 X

Wolf Springs Yellowstone 1955 X

Wolf Springs, South Yellowstone 1984 X

Note 

Sources: Montana Board of Oil and Gas (2007), Tonneson (1985). 

On October 14, 2008, the Automated Fluid Mineral Support System (AFMSS) databases for 

the Miles City and Worland field offices were queried for the number of federal wells in the 

BiFO planning area boundaries. (Worland was queried because it has administrative control 

over certain wells in Carbon County). The AFMSS databases show the totals as referenced in 

Table 3-51. 

Table 3-51 Federal Wells in the BiFO Planning Area 

Type of Well Number of Wells

Drilling wells 1

Producing gas wells 9

Producing oil wells 59

Water injection wells 5

Shut in oil wells 1

Temporarily abandoned wells 7

In 2007, federal O&G production in the planning area totaled 277,532 barrels of oil and 

147,325 million cubic feet of gas. Table 3-52 provides a county by county breakdown of 

production. 
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Table 3-52 Federal Oil and Gas Production in the BiFO Planning Area 

County/Area

2007 Total 

Oil 

Production 

(Barrels)*

2007 Oil 

Production: 

Federal 

Minerals 

(Barrels)**

Percent of Total 

Oil Production 

from Federal 

Minerals

2007 Gas 

Production 

(mcf) a

2007 Natural Gas 

Production: 

Federal Minerals 

(mcf) b

Federal 

Percent of 

Total Gas 

Production

Federal 

Gas Plant 

Products 

(NGLs)

Fiscal Year 2008 

Disbursements b

BLM 

Leased 

Acres

Montana 34,857,704 3,838,294 11 120,768,222 32,161,818 0.27

BiFO Planning 

Area 686,221 277,523 40 15,768,779 147,325 1,743,058 158,544

Big Horn 61,559 0 13,062,106 3,934,325 0 3,934

Carbon 457,110 271,696 59 1,952,657 147,325 0.08 1,466,773 1,566,019 48,941

Golden Valley 0 0 94,673 0 24,222 17,903

Musselshell 144,731 4,995 3 6,601 0 122,513 54,842

Stillwater 0 0 583,553 0 24,133 21,612

Sweet Grass 0 0 69,189 0 0 4,309

Wheatland 0 0 0 0 707 1,023

Yellowstone 22,821 832 4 0 0 5,464 8,183

Note: 

a

 Source: Montana Board of Oil and Gas (2007) 

b

 Source: Mineral Management Service (2008) 
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3.17.3United States Geological Survey Oil and Gas Assessments 

The United States Geological Survey (USGS) completed nationwide assessments of O&G 

resources in 1995. Since then, it has issued a new assessment for a number of provinces 

including the Powder River Basin, Big Horn Basin, and North Central Montana Province. 

3.17.3.1 1995 USGS Assessment 

The planning area is located in the Rocky Mountains and Northern Great Plains Region, as 

defined by the USGS in its 1995 National Assessment of United States Oil and Gas Resources 

(USGS 1995). Portions of southwest Montana, north central Montana, Bighorn Basin, and 

Powder River Basin provinces are in the planning area (Map 167- USGS Oil and Gas Provinces 

1995 Boundaries). 

The Southwest Montana Province lies north and northwest of Yellowstone National Park and 

east and southeast of the Cordilleran Thrust Belt in the southwestern part of the Rocky 

Mountain Foreland in southwestern Montana. This province includes all of Sweet Grass and 

Stillwater counties and western Carbon County. All or portions of four conventional plays in 

this province are located in the planning area. The 1995 assessment defined a play 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. Conventional accumulations are discrete deposits, usually bounded by a 

downdip water contact, from which natural gas or oil can be extracted using conventional 

techniques (USGS Circular 1118 1995). 

A small portion of the North-Central Montana Province lies in the planning area. It includes all 

of Golden Valley, Musselshell, Wheatland, and Yellowstone counties and a small part of Big 

Horn County. The area of the province in the planning area is bounded by the Crazy Mountains 

Basin to the southwest and the Powder River Basin to the southeast. The province has been 

actively explored for oil since it was discovered in adjoining Alberta, Canada, in 1903. Portions 

of 10 conventional and unconventional plays are found in that portion of the Province in the 

planning area. Unconventional accumulations are a broad class of oil or gas deposits of a type 

(such as gas in “tight” sandstones, gas shales, and coal bed natural gas) that historically have 

not been produced using traditional development practices. Such accumulations include most 

continuous accumulations which are hydrocarbon accumulations pervasive throughout large 

areas that are not significantly affected by hydrodynamic influences (USGS Circular 1118 

1995). 

Portions of the Big Horn Basin Province extend north from Wyoming into Carbon County, 

Montana. The first fields in this Province were discovered in 1906 and 1907. As noted above, 

the first oil well drilled in the state was in the Elk Basin field in 1915 in Carbon County. 

Portions of 10 conventional plays associated with this province occur inside planning area 

boundaries. 

A portion of the Powder River Basin Province lies in Big Horn County, Montana, in the 

planning area. The Powder River Basin is a major inter-montane basin of Laramide origin in 

the northern Rocky Mountains that occupies northeastern Wyoming and a small portion of 
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southeastern Montana. The basin makes up the majority of the surrounding Province. The 

Powder River Basin is a deep, northerly trending, asymmetric, mildly deformed trough, 

approximately 250 miles long and 100 miles wide. Its structural axis is close to the western 

side. The thickness of the sedimentary section exceeds 18,000 feet along the basin axis. The 

basin is one of the richest petroleum provinces in the Rocky Mountains. The first discovery in 

the basin was in Wyoming in 1887. Portions of five conventional and one hypothetical 

conventional plays are found in that portion of the Province inside planning area boundaries. 

Portions of one unconventional (coal bed natural gas) play are found in the planning area. 

3.17.3.2 Subsequent USGS Assessments

Since completing the 1995 Assessment, the USGS has reassessed the Powder River Basin, the 

North-Central Montana, and the Big Horn Basin provinces that partially overlap the planning 

area. 

The existing assessment for the Powder River Basin Province was revisited in both 2002 and 

2006. In neither case did the boundaries of the Province change. The 2002 assessment 

addressed the potential for undiscovered resources in continuous O&G accumulations in the 

Powder River Basin. The assessment was based on geologic elements such as hydrocarbon 

source rocks, reservoir rocks, and hydrocarbon traps in four Total Petroleum Systems (TPS) 

identified in the basin by the USGS. In the original version of the assessment published in 

2002, the USGS identified portions of two assessment units (AUs) in the Tertiary-Upper 

Cretaceous Coal-Bed Methane TPS in the planning area. It also identified one AU, the Shallow 

Continuous Biogenic Gas AU in the Cretaceous Biogenic Gas TPS in the planning area (USGS 

Fact Sheet 146-02, 2002). The USGS reassessed the conventional resources of O&G in the 

Powder River Basin in 2006 (USGS Fact Sheet 2006-3135, 2006). A TPS consists of all 

genetically related petroleum generated by a pod or closely related pods of mature source rock. 

Particular emphasis is placed on similarities of the fluids of the petroleum accumulations. Plays 

as described in the 1995 Assessment are established primarily according to similarities of the 

rocks in which petroleum accumulations occur. The AUs are more closely associated with the 

generation and migration of petroleum than plays (USGS, DDS-69-D, 2005). 

In May 2008, the USGS finished a reassessment of the undiscovered biogenic gas resources in 

the North-Central Montana Province. For this assessment, it increased the area of the Province 

to include most of the eastern two-thirds of Montana including portions of the planning area. 

Work on this assessment began in 2000 as part of the national O&G assessment project. The 

assessment was based on the general geologic elements used to define a TPS. Using that 

geologic framework, the USGS defined the Cretaceous Judith River through Belle Fourche 

Biogenic Gas TPS with seven associated AUs (USGS Fact Sheet 2008-3036, 2008). 

In June 2008, the USGS released a new assessment of undiscovered O&G resources of the 

Bighorn Basin Province in Wyoming and Montana, covering about 6.7 million acres. Portions 

of two TPSs are in that portion of the Province in Montana. The first of these TPSs is the 

conventional Phosphoria TPS made up of one AU. The other is the Cretaceous-Tertiary 

Composite TPS. Parts of two AUs that contain coal bed natural gas occur in the Montana 

portion of the Bighorn Basin Province (USGS Fact Sheet 2008-3050, 2008). 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-185

3.17.4Federal Drilling Activity 

Federal drilling activity for the last 18 years is shown in Table 3-53. Total activity is 

consistently low in any one year. Total drilling activity on all ownerships in the planning area is 

shown in Table 3-54. Activity has remained stable on all ownerships since 1989. 

Table 3-53 Summary of Federal Wells Drilled in the Last 18 Years 

Year Drilled Producing Well Drilled Dry Hole

2007 1 0

2006 0 0

2005 0 0

2004 0 1

2003 0 1

2002 0 0

2001 5 5

2000 3 2

1999 1 1

1998 0 0

1997 0 0

1996 0 2

1995 0 2

1994 0 1

1993 0 2

1992 0 0

1991 2 1

1990 2 6

TOTALS 14 24

Note: 

Source: AFMSS 2009
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3-186 Chapter 3: Affected Environment

Table 3-54 All Well Types, All Ownerships in the Planning Area 

Table 3-53 and Table 3-54 were copied from the reasonably foreseeable development (RFD) 

scenario for the Billings RMP depict the drilling history for BiFO. 

3.17.4.1 Existing Federal Leases

There are a total of 235 active leases in the planning area covering 145,988.55 acres. This is 

approximately 16 percent of the federal O&G estate in the planning area. 

3.17.4.2 Well Spacing 

Before development drilling begins, a well spacing pattern must be established. The State of 

Montana establishes well spacing patterns for both exploratory and development wells (field 

spacing) which the BLM generally adopts after (the BLM participates in all hearing of the 

Montana Board of Oil and Gas Conservation). Spacing unit size is established to provide for 

the most efficient and economic recovery of O&G from a reservoir. Normal well spacing 

statewide ranges from 40 to 640 acres, depending on discovery well characteristics such as 

porosity, permeability, pressure, composition, depth of formations, etc. 

3.17.4.3 Unitization and Communitization

Unit and communitization agreements can be formed in the interest of conservation and to 

allow for the orderly development of O&G reserves. An exploratory unit is used for the 

discovery and development of the field in an organized and efficient manner. A unit agreement 

provides for the recovery of O&G from the land as a single consolidated entity without regard 

to separate lease ownerships. A unitization agreement provides for the allocation of production 

among all interest owners. No exploratory units are located in the planning area. Five 

secondary units are located in the planning area boundary. 

0

20

40

60

80

100

120

140

160

197819791980198119821983198419851986198719881989199019911992199319941995199619971998199920002001200220032004200520062007

Number of Wells

Year

Number of All Well Types Drilled Per Year, BFO

(All Ownerships)
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-187

A communitization agreement combines two or more leases (federal, state, or fee) that 

otherwise could not be independently developed in conformity with established well spacing 

patterns. The leases in a spacing unit share in the costs and benefits of the well drilled in the 

spacing unit. Fifteen communitization agreements covering 3,654 acres are located in the 

planning area. 

3.17.4.4 Projected Reasonably Foreseeable Development for Oil and Gas 

The following information is summarized from the Reasonable Foreseeable Development 

(RFD) Scenario for oil and Gas for the Billings Field Office (Montana/Dakotas Bureau of Land 

Management, 2010). Map 49 identifies the areas with Low or Moderate levels of forecasted 

drilling activity. There are no identified areas of High forecasted drilling activity (greater than 5 

wells drilled per year). Areas of Low Drilling activity are forecasted to have no more than one 

well drilled per township per year. Areas of Moderate Drilling activity are forecasted to have 

between one and five wells drilled per township per year. The ‘Moderate’ potential areas were 

delineated from the extent of existing O&G fields and the resource plays that may encourage 

further drilling activity. The ‘Low’ potential areas are lands that have been sparsely explored, 

have no established production, and are not in identified geological structures (especially 

surface-exposed structures that have drawn past drilling activity). Map 167 shows the RFD for 

the Billings Field Office overlaid with the federal mineral estate. 

It is likely that forecast drilling activity levels will be somewhat higher than the levels of the 

past 20 years. For the 20 year forecast period of the RMP, the BLM anticipates an average of 

20 wells to be drilled per year (versus 17 wells drilled per year from 1989-2008). Some of the 

new drilling will be in wildcat areas in the Crazy Mountains Basin play. There are fewer 

Federal minerals in Sweet Grass and Wheatland Counties than in the other counties in the 

BiFO. Federal conventional and unconventional, including coalbed natural gas (CBNG) wells 

will average three to four wells per year. 

CBNG development in the BiFO is forecast to occur in either the Bull Mountain Basin or in the 

Bighorn Basin. The BLM does not anticipate that CBNG exploration and development in the 

BiFO would have the same intensity as does the CBNG development in the Powder River 

Basin. Compared to the Powder River Basin, coals in the above-described fields are: 

 Thinner 

 Higher rank, with likely higher adsorbed gas levels 

 More deeply buried 

 Drilling and development likely would have a lower well density 

 There would likely be a single well per spacing unit (no thick, stacked coals) 

 The coals are generally too deep below the surface to supply groundwater for 

most domestic and agricultural purposes 

 Groundwater in the coals likely has higher salinities and would not be suitable 

for domestic or agricultural purposes 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

3-188 Chapter 3: Affected Environment

In contrast to the Powder River Basin CBNG development, the BLM expects that produced 

water volumes associated with CBNG development in the BiFO would be similar to 

conventional O&G development, having lower volumes and higher salinities. It is probable that 

the produced water would be reinjected into a subsurface aquifer that already has high 

salinities, or would be allowed to evaporate in lined pits. 

The BLM does not anticipate that CBNG drilling and development would result in any 

different environmental impacts than conventional drilling and development. In contrast to the 

Powder River Basin (PRB), coals in the Big Horn and Bull Mountains Basins are at greater 

depths. Operators would drill using conventional drilling rigs and conventional drilling 

techniques, so the area disturbed would be similar to conventional wells. The coal beds 

generally are not sources of fresh water for domestic or agricultural purposes (underground 

sources of drinking water). Produced water would be disposed of in a similar manner as water 

from conventional reservoirs – most likely reinjection into horizons bearing water of similar or 

lower quality. The coals are higher grade and would have greater volumes of adsorbed CBNG 

than PRB coals. Because there aren’t thick, stacked coal beds, there would likely be only one 

well drilled per well pad. For these reasons, the BLM believes it is not necessary to assess 

CBNG drilling separately from other drilling activity. 

3.17.4.5 Well Completion and Stimulation

After the well is drilled, if necessary, testing operations would commence. If testing indicates 

the presence of an economic level of oil and/or gas, the well would be completed for 

production. Typical completion operations would involve setting and cementing the production 

casing to the total depth of the well. There are also instances where casing is set at the top of 

the target zone, and the formation is completed in the open hole. 

After the proper casings are set, wells are often treated to improve the recovery of 

hydrocarbons by increasing the rate and volume of hydrocarbons moving from the natural oil 

and gas reservoir into the wellbore. In many instances, the well(s) would not give up 

commercial volumes of oil or gas unless they were stimulated. These processes are known as 

well-stimulation treatments, and they are designed to create new fluid passageways in the 

producing formation or remove blockages within existing passageways. They include 

fracturing, acidizing, and other mechanical and chemical treatments often used in combination. 

The results from the different treatments are additive and often complement each other, which 

makes it possible to introduce fluids carrying sand, or other small particles of material into the 

newly created crevices to keep the fractures open when the pressure is relieved. This increases 

the flow rate and volume of reservoir fluids that move from the producing formation into the 

wellbore. 

Water produced during drilling, hydraulic fracturing, and completion operations is contained in 

a lined pit or in steel tanks on location. The water can be disposed of by trucking it to an 

authorized disposal pit, allowing the water in the lined pit to evaporate within required 

timeframes, through subsurface injection, or treated and reused to drill or complete another 

well. The disposal of water generated during drilling and completion operations in an injection 

or disposal well requires permit(s) from the primacy state or Environmental Protection Agency 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-189

(EPA). See the Fluid Minerals Operations and Procedures Produced Water section for details 

on primacy. A NEPA analysis is prepared for all requests concerning disposal of water 

generated from federal wells and in accordance to federal and state regulations. 

After completion operations are finished, wellhead equipment consisting of various valves and 

pressure regulators are installed to control the oil or gas flow to the production facilities and 

allow safely shutting in the well under any conditions. 

3.17.4.6 Hydraulic Fracturing

Hydraulic fracturing has been utilized by the oil and gas industry since the late 1940s. Within 

the planning area, hydraulic fracturing, in conjunction with horizontal drilling described above, 

has allowed for development of unconventional zones that were once considered uneconomical, 

like the Bakken and Three Forks Formations in the Williston Basin area. 

Hydraulic fracturing is a technique used to create additional space and connecting existing 

fractures and existing rock pores with newly created fractures that are located in deep 

underground geologic formations. The induced space allows the rock to more readily release 

oil and natural gas so it can flow to the surface via the well bore that would otherwise be 

uneconomical to develop. Wells that undergo hydraulic fracturing may be drilled vertically, 

horizontally, or directionally and the resultant fractures induced by the hydraulic fracturing can 

be vertical, horizontal, or both. The typical steps of hydraulic fracturing can be described as 

follows: 

1. Water, sand and additives are pumped at high pressures down the wellbore. 

2. The liquid goes through perforated sections of the wellbore and into the surrounding 

formation, fracturing the rock and injecting sand or other proppants into the cracks 

to hold them open. 

3. Experts continuously monitor and gauge pressures along with the volume of fluids 

and proppants, while studying how the sand reacts when it hits the bottom of the 

wellbore; slowly increasing the density of sand to water as the frac progresses. 

4. This process may be repeated multiple times, in “stages” to reach maximum areas of 

the wellbore. When this is done, the wellbore is temporarily plugged between each 

stage to maintain the highest water pressure possible and get maximum fracturing 

results in the rock. 

5. Frac plugs are drilled or removed from the wellbore and the well is tested for 

results. 

6. The water pressure is reduced and fluids are returned up the wellbore for disposal or 

treatment and re-use, leaving the sand in place to prop open the cracks and allow the 

oil/gas to flow to the well bore. 

Fracturing fluid is typically more than 98 percent water and sand, with small amounts of readily 

available chemical additives used to carry the proppant and control the chemical and 

mechanical properties of the water and sand mixture. Proppant, consisting of synthetic or 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

3-190 Chapter 3: Affected Environment

natural silica sand, may be used in quantities of few hundred tons for a vertical well to a few 

thousand tons for a horizontal well. The amount of water needed to fracture a well in the 

planning area depends on the geologic basin, the formation, and depth and type of well 

(vertical, horizontal, directional), and the proposed completion process. The amount of water 

used to hydraulic fracture a Bakken or Three Forks well is approximately 2-4 million gallons of 

water per well (EPA, 2012). 

Several sources of water are available for hydraulic fracturing in the planning area. The Fluid 

Minerals Operations and Procedures Appendix contain further details on sources of water that 

could potentially be used for hydraulic fracturing or drilling operations. The use of any specific 

water source on a federally administered well, requires the proposal be reviewed and analyzed 

through the NEPA process for BLM approval during the APD stage to ensure compliance with 

Montana water laws and federal regulations. 

Before hydraulic fracturing takes place, all surface casing and some deeper, intermediate zones 

are required to be cemented from the bottom of the cased hole to the surface in accordance to 

Onshore Oil and Gas Order No.2, MBOGC rules and regulations, and API standards. The 

cemented well is pressure tested to ensure there are no leaks and a cement bond log is run to 

ensure the cement has bonded to the casing and the formation. 

MBOGC regulations also ensure that all resources including groundwater are protected. The 

MBOGC regulations require new and existing wells, which will be stimulated by hydraulic 

fracturing, must demonstrate suitable and safe mechanical configuration for the stimulation 

treatment proposed. If the operator proposes hydraulic fracturing through production casing or 

through intermediate casing, the casing must be tested to the maximum anticipated treating 

pressure. In accordance with MBOGC Rule 36.22.1015 operators are required to disclose and 

report the amount and type of fluids used in well stimulation to the Board or, if approved by the 

Board, to the Interstate Oil and Gas Compact Commission/Groundwater Protection Council 

hydraulic fracturing web site (FracFocus.org). 

3.17.4.7 Locatable Minerals 

Federal minerals in the decision area are available for exploration and development unless 

previously withdrawn. Table 3-55 shows the number of active claims by county in the planning 

area. The surface management program for locatable mineral exploration and development is 

administered under federal regulations (CFR 3809) and an MOU between the Department of 

Natural Resources and Conservation (DNRC) and BLM. Locatable mineral activities in WSAs 

are administered under the 43 CFR 3820 regulations. When a Plan of Operations is submitted, 

it includes a reclamation plan for the project area. 

Mineralization occurrences are often associated with veins and fracture zones located near the 

margins of igneous dikes and intrusions. In the past, the USGS and the former US Bureau of 

Mines have examined various prospects and reported finding deposits that contain values for 

copper, lead, zinc, zeolites, uranium, niobium, zirconium, thorium, titanium, sulfur, tantalum, 

beryllium, lithium, cerium, and vermiculite. These mineral occurrences are considered to be 

uneconomic and marginal in value. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-191

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, 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. 

American Colloid and Wyo-Ben Incorporated (Wyo-Ben) have 151 unpatented placer claims 

encompassing over 3,000 acres. 

American Colloid produced approximately 485,000 tons of bentonite during 2008 with a value 

of around $60.00 per ton. The company has operated under a State of Montana Mining and 

Reclamation Plan since 1972. Under federal surface management regulations (43 CFR 3809), 

this plan was accepted by BLM in 1981. American Colloid has since patented 3,584 acres and 

has an additional 3,739 acres of unpatented federal claims, for a total of 7,323 acres in their 

permit. Wyo-Ben produces bentonite from patented and unpatented claims under their plan 

which was approved in 1999. It currently produces an average of 32,000 tons per year from its 

Montana operations. 

3.17.4.8 Mineral Materials 

There are 15 active sites for mineral materials (sand, gravel, clay, stone, scoria and borrow 

materials) in the planning area. Mineral material permits by county in the planning area are 

shown in Table 3-55. Saleable mineral production in the decision area was 6,500 cubic yards 

for a value of $3,250 from 100 acres of federal land. 

BLM would dispose of salable minerals on unpatented mining claims only for a public purpose 

when no reasonable alternative exists. Salable mineral sites would have an approved mining 

and reclamation plan and an environmental analysis prior to being opened. Mineral material 

would be sold at a fair market value to the public, but would be free to state, county, or other 

local governments when used for public projects. Mineral material sales would be processed on 

a case by case basis. 

Saleable minerals in the decision area consist of sand, gravel, clay, building and decorative 

stone, scoria, and borrow materials which is used for road and other construction activities. 

Common fill that cannot be separated from the soil at the surface may be considered as being a 

right associated with the surface estate. BLM issues permits for the sale of surface materials 

under the Materials Act in the same manner as mineral materials associated with the subsurface 

rights. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

3-192 Chapter 3: Affected Environment

Table 3-55 Claims and Saleable Mineral Permits in the Planning Area 

County Lode Claims Placer Claims Saleable Minerals permits

Big Horn 0 0 2

Carbon 82 151 12

Golden Valley 0 0 0

Musselshell 0 0 0

Stillwater 613 11 1

Sweet Grass 380 2 0

Wheatland 0 0 0

Yellowstone 0 0 0

Total 1,075 164 15

Note: 

Source: 

Most of the sand and gravel mining operations in the planning area are on private lands 

containing alluvial gravel deposits. Some topographically higher terrace gravel deposits exist 

on federal lands, however these are not as easily accessible as the alluvial valley deposits. 

Average annual production of sand and gravel from federal lands in the planning area is on the 

order of 5,000 to 10,000 cubic yards with a current unit royalty value of $0.50 per cubic yard 

(current market value [2008]).

Building and decorative stone is abundant throughout the planning area. Decorative stone is 

primarily a commercial type referred to as “moss rock,” or a lichen covered sandstone. There 

are no active permits for the removal of decorative stone in the planning area; however, an 

average of 100 tons per year could be expected to be produced at scattered locations throughout 

the planning area. The unit royalty value of moss rock is approximately $20 per ton (2008 

current market value). However, this rate can vary. 

Some small amount of building stone and rip rap are produced from a community pit on federal 

land located near Warren, Montana. The stone is normally purchased in small volumes of a ton 

or less with a market value (2008) of $7.50 per ton. There are about 10 small sales annually 

from the site, with each sale averaging one ton. 

3.18 Forestry and Woodland Products 

The demand for wood products in the BIFO decision area is widely variable. Incidental 

amounts of non-forest special products have been sold in the past and have included wildings 

and mushrooms 

3.18.1Forest and Woodland Communities 

Forest and woodland communities in the planning area are discussed in some detail in the 

Vegetative Communities Section.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-193

3.18.2Wood Products 

Most forested lands in the BIFO decision area occur in small isolated parcels with poor access, 

small volume, and limited economic value. Consequently, the sale and harvest of wood 

products has been chiefly through small negotiated sales. Most sales are identified through 

public demand, where access is limited and harvest is occurring on adjacent private lands. 

Volumes sold in the BIFO have averaged less than 50 thousand board feet (MBF) per year over 

the last decade as shown below in Table 3-56. 

Table 3-56 Wood Products Harvested and Sold in the Planning Area (1994-2008) 

Wood Product Volume/15 Years Average/Year Average 

Price/Unit

Monetary

Total

Saw timber: 

Douglas-fir, lodgepole & ponderosa pine 1,261 MBF 84 MBF $ 76/MBF $ 95,380 

Pulp wood 990 MBF 66 MBF $ 1.70/MBF $ 1,683 

Post and pole 3025 ea 202 ea $ .52 ea $ 1,582

Biomass 300 tons 20 tons $ .01/ton $ 3 

Juniper 16,530 lbs 1,102 lbs $ .05/lb $ 100 

Fuel wood 479 cords 32 cords $ 5.00/cord $ 400 

Christmas trees 0 0

Note: 

Averages reflect 15 years 1994-2008. 

Weight factor (computed for burned dry timber) = 12.0lbs/bdft. 

Source: BLM 1984 

Market price dictates the demand for saw timber and wood products. While there are limited 

markets for forest products within the decision area, there are markets in western Montana. 

Current market value for forest products plays a pivotal role in determining when forest 

products can be economically transported to markets outside of the planning area. 

Wildfires are occurring more frequently and with greater intensities, thereby affecting larger 

areas of forested lands. The past two years have seen larger volumes of saw logs, pulp, and 

biomass removal as a result of salvage operations in response to large wildfires. Fuel wood 

sales average approximately 32 cords per year. Historically, few existing markets for pulpwood 

and biomass have existed. Those markets that are available are generally small and unstable, 

with low market prices and high transportation costs. However, during the last two years, 

markets have been available. The type of forest products available in the decision area include, 

but are not limited to: 

 Saw logs 

 Posts and poles 

 Pulp 

 Decorative tree boughs 

 Christmas trees 

 Fuelwood 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

3-194 Chapter 3: Affected Environment

3.19 Realty, Cadastral Survey, and Lands 

Public land policy in the United States fundamentally changed with passage of FLPMA, which 

directed that “public lands be retained in federal ownership, unless as a result of the land use 

planning procedure provided for in this Act, it is determined that disposal of a particular parcel 

will serve the national interest...”. The Realty, Cadastral Survey, and Lands program is a 

support program for all other resources and resource uses in the planning area with a goal to 

manage public lands to support resource program goals and objectives, provide for public land 

uses in accordance with applicable laws and regulations while protecting sensitive resources 

and improving public land management through land tenure adjustments. As such, the program 

responds to requests for ROWs, permits, leases, withdrawals, and land tenure adjustments from 

outside entities. 

The BiFO manages 434,154 acres of surface land and 889,497 acres of split estate land in eight 

counties. Split estate lands are lands where the federal government owns the mineral rights, and 

the surface rights belong to a different owner. Table 3-57 provides a detailed assessment of 

land ownership in the planning area. 

Table 3-57 Land Status by County 

County

Ownership

(in acres)

BLM Public Lands 

(in Planning Area)

BLM Federal Mineral 

Estate 

(in Planning Area)

Other Surface Owners

(private, state, other federal)

Big Horn, MT 7 1.016 2,572,759

*Big Horn, WY 4,298 4,298 0

Carbon 220,556 341,376 1,319,729

Golden Valley 7,943 44,360 755,843

Musselshell 101,247 226,905 1,197,198

Stillwater 5,504 58,348 1,154,905

Sweet Grass 15,893 75,240 1,191,450

Wheatland 1,333 21,437 913,802

Yellowstone 77,373 116,516 1,695,307

TOTAL 434,154 889,497 10,803,310

3.19.1Land Tenure Adjustments and Access 

Land ownership (or land tenure) adjustments are those actions that result in the disposal of 

BLM land and/or the acquisition of non-Federal lands or interest in lands. The FLPMA is the 

primary authority the BLM uses to make land tenure adjustments such as under Section 203 for 

sales, Section 205 for acquisitions, Section 206 for exchanges, and Section 209 for mineral 

conveyances. Other authorities, such as the R&PP Act also provide for disposal. For the 

purpose of addressing the land tenure adjustments in this planning effort, three categories 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-195

related to land tenure adjustments were developed and are described below (note: the 1984 

BiFO RMP Record of Decision only addressed Retention (Category I) and Disposal (Category 

III). 

 Category I: Retention would include all Special Designations (including 

ACECs, WSAs, national historic trails, national monuments, etc.), lands with 

wilderness characteristics, archeological sites and/ or historic districts, and lands 

acquired through LWCF. Lands in 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) lands in Category II would not be available for sale 

under Section 203 of FLPMA. However, lands in 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) 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 in 

Appendix J. 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. 

Table 3-58 shows how lands administered in the BiFO planning area are currently allocated by 

land tenure category. 

Table 3-58 Land Tenure Category Acreage 

Current Land Tenure 

Adjustments Acres Percentage of Planning Area

Retention 27,207 6.3%

Disposal 6,329 1.5%

Note: 

 Source: BLM 1984 ROD 

Table 3-59 Land Exchanges, Acres Disposed/Acquired 

Exchange Serial Number Date Acres Disposed Acres Acquired Geographic 

Name

Bull Mountain MTM-080345 Feb. 1991 3,673.16 (coal) 7,700.26 Grove Creek

Thaut MTM-080893 May 1994 320 639.6 Shepherd Ah-Nei

Altman MTM-084895 Nov. 1997 7,411.80 379.4 Sundance Lodge

Cub Creek MTM-087795 Dec.1998 16,510.92 4,212.33 Cub Creek

Larsen MTM-088157 Feb. 1999 2,155.89 765 Four Dances

Total Acres 30,071.77 13,696.59
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3-196 Chapter 3: Affected Environment

3.19.2Disposals 

Appendix J identifies tracts and legal descriptions from the 1984 RMP (BLM 1984) decision 

for disposal, as well as those lands identified for disposal by alternative. Since the 1984 RMP 

(BLM 1984) decision, 22 of the 36 disposal tracts identified have been patented into private 

ownership. These disposal tracts were conveyed by the above-referenced land exchanges 

(Table 3-59), with the exception of 2 tracts, totaling 50 acres, which were disposed by direct 

sale. The Land Tenure Proposal Summary in Appendix J is adjusted to reflect the current 

management. 

The FLPMA requires that public land be retained in public ownership unless, as a result of land 

use planning, disposals of certain parcels are warranted. Public land must be sold at not less 

than fair market value and must meet specific FLPMA sale criteria, including: 

 Because of its location or other characteristics, it is difficult and uneconomic to 

manage as public land and is not suitable for management by another federal 

department or agency; or 

 It was acquired for a specific purpose, and the tract is no longer required for that 

or any other federal purpose; or 

 Disposal would serve important public objectives, including possible 

community expansion and economic development, which cannot be achieved 

prudently or feasibly on land other than public land and which outweigh other 

public objectives and values such as recreation and scenic values which would 

be served by maintaining such tract in federal ownership. 

All disposal actions must be coordinated with appropriate landowners and authorities, and each 

disposal action requires a site specific environmental analysis under the National 

Environmental Policy Act (NEPA). If a disposal is federally legislated, if is exempt from 

NEPA review. 

3.19.3Exchanges 

Trading lands or interests in lands (or exchanges) are the means by which land acquisitions and 

disposals occur. Exchanges may be made for land or interests in land owned by corporations, 

individuals, or government entities, and they are voluntary and discretionary transactions with 

willing land owners (exceptions are congressionally mandated or judicially required 

exchanges). Land exchanges must be in the best interest of the public and conform to 

applicable BLM land use plans (LUPs). Further, exchanges are done on a value-for-value basis, 

based on the fair market value as determined by the Department of Interior Office of Valuation 

Services. 

3.19.4Acquisitions 

Land acquisitions may be pursued as an important component of the BLM’s land management 

strategy. Lands and interest in lands are acquired to provide the following: 
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 Improve natural resource management through consolidation of federal, state, 

and private lands 

 Secure key property necessary to protect endangered species, promote biological 

diversity, increase recreational opportunities, enhance wildlife habitat, provide 

access to public waters and public land, and preserve archaeological and 

historical resources 

 Implement specific acquisitions authorized or directed by acts of Congress 

Special appropriations approved by Congress, generous donations from concerned citizens, and 

funding through the Land and Water Conservation Fund have all played a critical role in 

shaping the acquisition program, as shown in Table 3-60. 

Table 3-60 Land Acquisitions/Donations 

Name Serial Number, Date Acres Acquired Funding Source

Pompeys Pillar MTM-080383, Nov. 1991 366 Special Appropriation

Weatherman Draw MTM-098616, Dec. 2008 615 Donation

Meeteetse Spires MTM-099053, Jan. 2011 560 LWCF

Total Acres Acquired 1,541 All Sources

3.19.5Rights-of-Way, Leases, and Permits 

There are more than 300 existing ROWs encumbering more than 11,000 acres in the decision 

area, as shown in Table 3-61. These ROWs authorize construction, operation, and maintenance 

of roads, railroads, power lines, renewable energy sites, communication sites, water and 

irrigation facilities, O&G pipelines, and other uses. ROWs have been granted to other federal 

agencies, the state of Montana, numerous counties, corporations, and individuals. Annually, 

over the past 10 years, the BiFO has processed between 8 and 10 new ROW applications or 

amendments to existing ROW grants. 

Table 3-61 Existing ROWs in the Decision Area 

Existing Authorization Number Acres

ROW temporary use permits 6 12.6

ROW Roads (acquired, 44LD513 and re-conveyed) 70 1,110.5

Federal Aid Highway, sections 107 and 307 20 1,146.7

ROW roads RS-2477 1 98.1

ROW railroads 2 96.9

ROW power lines and sites 53 478

ROW power lines for irrigation projects, acquired and reconveyed lands 19 220.8

Renewable energy wind site testing and monitoring 1 6,097
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ROW reclamation project 8 17.9

Communication sites (FLPMA, 1911, Federal and 44LD513) 9 4.7

ROW telephone 42 405.7

ROW water facility and irrigation 22 701.2

ROW oil and gas pipelines/facilities 49 881.1

ROW (other FLPMA, Bundy Fishing Access and DEQ air monitoring site) 2 4.1

ROW roads (other federal – USFS) 21 429.1

TOTAL 325 11,704.4

Note: 

Source: Data based on LR2000 report for authorized ROW, dated December 12, 2008. 

ROW actions are the most common form of authorization to permit public land usage by 

commercial, private, or other governmental entities. A ROW grant is an authorization to use a 

specific piece of public land for specific facilities for a specific period of time. Section 501 of 

FLPMA authorizes the BLM to issue ROWs over, upon, under, or through BLM public lands 

for linear and site facilities necessary for transportation and transmission. ROWs for 

transporting oil and gas products across public lands are authorized under the authority of the 

Mineral Leasing Act of 1920. 

Historically, most ROWs on BLM public lands in the planning area involved roads, O&G 

development, electrical transmission, and communication sites. In recent years however, access 

roads and utilities associated with private land development have become more common. This 

is especially true in the Grove Creek area in Carbon County, where the land ownership pattern 

is scattered with private subdivided lands. 

Wind and solar renewable resource production is permitted by ROWs through the Realty, 

Cadastral Survey, and Lands program and are discussed in the Renewable Energy section of 

this chapter.. 

3.19.6Utility Corridors

Section 368 of the Energy Policy Act of 2005, PL 109-58 (H.R. 6), enacted August 8, 2005, 

directs the Secretaries of Agriculture, Commerce, Defense, Energy, and the Interior to 

designate, under their respective authorities, corridors on federal land in 11 western states for 

oil, gas, and hydrogen pipelines, as well as electricity transmission and distribution facilities. 

The Designation of Energy Corridors on Federal Land in the 11 Western States Programmatic 

Environmental Impact Statement (EIS) ROD was approved on January 14, 2009, and amended 

the 1984 RMP. The BiFO corridor segment is designated as 79-216, a corridor 3,500 feet wide 

and 5.2 miles in length for multimodal uses, meaning overhead electric transmission and/or 

pipelines. The corridor follows the existing Express pipeline located east of Warren, Montana 

and runs from the Wyoming state line in a northwesterly direction into Montana. The 

preliminary EIS amended selected RMPs, including the 1984 RMP. 

Utility corridors are preferred routes for transportation and transmission facilities. Identification 

of corridors does not preclude location of transportation and transmission facilities in other 
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areas if environmental analysis indicates these facilities are compatible with other resource 

values and objectives. Further, identification of corridors does not mandate that transportation 

and transmission facilities will be located there if they are not compatible with other resource 

uses, values, and objectives in and near the corridors or if the corridors are saturated. Each 

ROW application is reviewed and analyzed using the environmental data that exist for the area 

as a basis to evaluate compatibility with existing uses and resource values. 

3.19.7Leases, Permits, and Easements 

The BiFO currently has no leases in effect nor any easements granted. Two different land use 

permits authorizing commercial filming and apiary (beekeeping) on public land are, however, 

in effect. Approximately three short term use permits are issued annually, mostly for PMWHR 

commercial filming projects. 

Leases, permits, and easements provide for use of public lands by the private sector, state, and 

local governments where uses conform to LUPs and cannot be achieved prudently or feasibly 

on land other than public lands. Section 302(b) of FLPMA authorizes BLM to issue leases, 

permits, and easements for the use, occupancy, and development of public lands. Any use not 

specifically authorized under other laws or regulations and not specifically forbidden by law 

may be authorized under this authority. Authorized uses include residential, agricultural, 

industrial, and commercial facilities. 

The BLM has rarely issued easements. An easement is usually issued to restrict land use on a 

parcel of federal land to benefit an adjacent private land area. Such public land restrictions are 

usually undesirable and are rarely sought by private interests. Leases and permits are more 

common. Permits, authorized under 43 CFR 2920, are typically for short-term use not to 

exceed 3 years. Easements, for example a road, are long-term non-possessory and nonexclusive uses. Federal agencies (other than BLM) are specifically excluded from authorization 

of leases, permits, and easements under Section 302 of FLPMA. However, federal agency use 

of public lands can be authorized by ROW, withdrawal, or interagency agreement. 

Under the authority of Section 501 of FLPMA, the BLM issues leases, permits, and ROWs for 

enduring surface disturbing uses of public lands that are not in the scope of the mining laws and 

regulations. 

3.19.8Communication Sites 

Communication sites are land areas where communications equipment and facilities such as 

cellular, television, private mobile radio service, and radio are situated. These sites house 

equipment for multiple users, primarily other government agencies including federal, state, and 

county. The only commercial communications sites are north of Pompeys Pillar, held by the 

Burlington Northern Santa Fe Railway; and Wall Creek located north of Roundup and held by 

Mid-Rivers Telephone Cooperative, Inc. The remaining 3 communications sites are Bridger, 

Tin Can Hill, and Four Dances. These sites provide communications for federal, state, and local 

government only. In the fall of 2008, communication site plans were completed for all 5 of the 

communication sites in the decision area. These sites, however, have not been officially 

designated as communications sites under the existing RMP. 
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The location of communication sites is subject to exclusion and avoidance areas. The purposes 

of the communication site plans include the following: 

 Selected management strategy 

 Location of new facilities and no build zone 

 Access requirement 

 Use of existing facilities, shared building/tower space 

 Multiple use terms and conditions 

 Areas closed or excluded from communication site development 

Designating sites provide direction for the following: 

 Management direction/philosophy and objectives 

 Management constraints (technical limitations, noise floors, compatible uses) 

 Electronic conflicts (frequencies and power) 

 Environmental concerns (soil stability, earthquake and avalanche hazards, T&E 

species, migratory birds, cultural and historical) 

 Site coverage and area served (population zones for rental purposes). 

Several initiatives have been directed to federal agencies regarding telecommunications 

carriers. These initiatives include: 

 President’s Executive Memorandum, dated August 10, 1995, states, “1. (a) 

agencies shall make available Federal government buildings and lands for the 

siting of mobile service antennas in accordance with: Federal, State, and local 

laws and regulations”

 Telecommunications Act of 1996 

 General Service Administration Bulletin 1997 

3.19.9Airport Grants and Leases 

The Airport and Airways Improvement Act of September 3, 1982, provides for the conveyance 

or lease of lands to public agencies for airport and airway purposes. The act requires the lease 

or conveyance of public lands deemed by the Secretary of Transportation to be necessary for 

airport and airway purposes, unless the lease or conveyance would unreasonably interfere with 

the programs of the Secretary of the Interior. There are no airport grants on public lands in the 

planning area. 

3.19.10 Recreation and Public Purpose Leases and Conveyances 

The BiFO administers four patents covering 297 acres and one expired Recreation and Public 

Purpose (R&PP) lease which is currently being reclaimed (Table 3-62). There are no pending 

applications at this time. 
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Table 3-62 Recreation and Public Purpose Leases in the Planning Area 

Current Patents Use Acres

City of Billings Sanitary Landfill 160

Hillcrest Foundation Natural Area Park 119.47

City of Billings Methane Gas Monitoring Site 17.45

Huntley Water and Sewer Water Pump House 0.08

TOTAL 297

Note: 

Source: BLM 1984 

The Recreation and Public Purpose Act authorizes BLM to lease or convey public lands to state 

and local governments and to qualified nonprofit organizations for recreation or public purpose 

uses. Lands are leased or conveyed for less than fair market value or at no cost for qualified 

uses. Examples of typical uses under the act are historic monument sites, campgrounds, 

schools, city and county parks, public works facilities, and hospitals. The land involved must be 

used for an established or definitely proposed project, and the lessee or patentee must commit 

to a plan of physical development, management, and use as well as certain other requirements 

before a lease or patent is issued. Usually, lands are first leased until development is 

substantially completed, at which time a patent may be issued. 

The BLM periodically reviews areas leased or conveyed under the R&PP Act to ensure 

continued compliance with the terms and conditions. A lease may be terminated or title to 

patented land may revert to the United States if the entity involved is not complying with the 

terms. 

3.19.11 Withdrawals 

Withdrawals are formal land designations that set aside, withhold, or reserve federal lands for a 

specific public use. Withdrawals accomplish one or more of the following: 

 Transfer total or partial jurisdiction of federal land between federal agencies 

 Close federal land from operation of all or some of the public land laws and/or 

mineral laws 

 Dedicate federal land to a specific public purpose 

There are three major types of withdrawals: 

1) Administrative withdrawals made by the president, Secretary of the Interior, or 

other authorized officer of the federal government’s executive branch. 

2) Congressional withdrawals legislated by Congress. 

3) Federal Power Act (FPA) or Federal Energy Regulatory Commission (FERC) 

withdrawals: power project withdrawals established under the authority of the 
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FPA of June 10, 1920. Administrative withdrawals are the most common type of 

withdrawal in the BiFO decision area. 

The BLM is responsible for reviewing and making recommendations to designate, revoke, or 

extend withdrawals. Only the Secretary of Interior, however, has the authority to take action. 

Table 3-63 shows the areas and associated acreage currently withdrawn from mineral entry in 

the decision area. 

Table 3-63 Areas Currently Withdrawn from Mineral Entry 

Area Withdrawn Acres

Weatherman Draw

 T. 8 S., R. 24 E., PMM

 sec. 20, S1⁄2SE1⁄4, SE1⁄4SW1⁄4 

 sec. 29, E1⁄2, E1⁄2 W1⁄2.

600

Petroglyph Canyon

 T. 9 S., R. 26 E., PMM

 sec. 35, lots 2, 3, 6, 7, SW1⁄4 NE1⁄4, SE1⁄4NW1⁄4.

240

Britton Springs Cabin and Corral

 T. 58 N., R. 95 W., 6th PM

 sec. 20, N1⁄2SW1⁄4NW1⁄4. 20

Crooked Creek Natural Area

 T. 58 N., R. 95 W., 6th PM

 sec. 28, NW1⁄4.

160

Pompeys Pillar National Monument

 T. 3 N., R. 30 E., PMM

 sec. 21, lots 23-27 inclusive.

51

Four Dances Natural Area ACEC

 T. 1 N., R. 26 E., PMM 

(see case file for legal land description) 

765

Note: 

Source: BLM 

3.19.12 Land Classifications 

Land classification is a process required by law for determining the suitability of public lands 

for certain types of disposal or lease or for retention and multiple use management. 

Some land classifications also close public lands from operation of all or some of the public 

land laws and/or mineral laws. Land classifications are not considered formal withdrawals; 

however, they can amount to de facto withdrawals, especially where segregation is involved. 

Section 7 of the Taylor Grazing Act of 1934 is now the only existing land classification 

authority. Before the passage of FLPMA in 1976, all BLM land disposal or lease actions 

required classification. Since FLPMA, Section 7 classifications are required only for the 

following disposal/lease authorities outside Alaska: 

 Recreation and Public Purpose Act 

 State selections 

 Desert Land Act 
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 Indian Allotment Act 

 Carey Act 

It should be noted that Section 7 classifications, including those made prior to FLPMA, remain 

in full force and effect until modified or terminated. Also, classifications made under now 

repealed authorities such as the Small Tracts Act of 1938 and the Classification and Multiple 

Use Act (C&MU) of 1964 continue in full force and effect until modified or terminated. 

In accordance with a Washington Office directive dated June 18, 1981, the 1984 RMP 

instructed that all C&MU classifications be examined and, if possible, revoked by the end of 

fiscal year (FY) 1983. The C&MU classifications for the BiFO were reviewed and revoked in 

accordance with this directive. 

There are currently no pending applications or requests for R&PP leases or patents in the 

decision area. Since 1984, there has been no activity involving state selections, Desert Land 

Act, Indian Allotment Act, or the Carey Act. 

3.19.13 Trespass 

Trespass actions involve use, occupancy, and development of the public lands without specific 

authorization or which exceed the established thresholds of an authorization or of casual use. 

Casual use is defined by the regulations in 43 CFR 2920.0-5(k) as: 

(k) Casual use means any short term non-commercial activity which does not 

cause appreciable damage or disturbance to the public lands, their resources or 

improvements, and which is not prohibited by closure of the lands to such 

activities. 

Trespass actions can cause unmitigated damage to public lands and natural resources, and it is 

the BLM’s responsibility to protect the public’s best interest in regard to its managed lands. 

Trespass actions also result in a loss of revenue (rental) to the Federal government. Trespass 

has been an ongoing problem in the BiFO, and when trespass actions go undetected or are 

identified and not immediately addressed, there is no incentive to cease trespass activity and no 

deterrent to further trespass action. 

Some known trespass activities include placement of apiaries (beehives); indiscriminate 

dumping of trash, debris, and household wastes; farming/irrigation of public land; road 

construction; and construction of other utility related features. Agriculture trespass and trash 

dumping are the most common type, with numerous small acreages involved. The BiFO prefers 

to resolve and rehabilitate trespassed agricultural lands rather than authorize their use under a 

2920. 

The BiFO typically resolves one to three cases each year, with some situations being resolved 

at the lowest informal level. Other situations may call for more formal resolution including 

action from BLM law enforcement. Trespasses may involve considerable expense for a 

Cadastral Survey land survey to determine property boundaries, rehabilitation of agricultural 

trespass areas, and dump clean ups. In trespass situations that demand legal resolution, the 

BiFO has demonstrated resolve in working with the DOI Field Solicitor and the US Attorney. 
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There are currently no trespass situations identified in the decision area that would require the 

use of a FLPMA section 203 direct sale for resolution. Every effort is made to use good 

judgment and restraint in resolving trespass situations at the lowest level possible with the goal 

of converting the trespasser into a cooperator and respecting the current public land boundaries. 

Trespass resolution involves cessation of the unauthorized use, occupancy, or development and 

may require removal of the unauthorized facilities or appropriate authorization of that use. 

Three considerations are included in trespass abatement. 

 Payment of administrative costs to resolve the trespass. 

 Payment of fair market value for the period of unauthorized use 

 Rehabilitation and restoration of affected public lands 

3.20 Livestock Grazing 

Livestock grazing addresses domestic animal grazing in the decision area and is authorized on 

BLM administered lands by the Taylor Grazing Act of 1934, the Federal Land Policy 

Management Act of 1976 (FLPMA), and the Public Rangelands Improvement Act of 1978. For 

example, the Taylor Grazing Act creates Section 3 lands and Section 15 lands. Section 15 lands 

are disconnected, non-contiguous tracts that are not contained in grazing districts. Section 3 

lands are located in grazing districts and are administered by the Secretary of the Interior 

through a system of preferential grazing permits. 

Approximately 421,627 acres of BLM administered public land in the BiFO planning area are 

in grazing allotment boundaries and are managed in accordance with the 1984 RMP (BLM 

1984) (see Range Allotments - Map 122). There are 5,961 acres that are not allotted, and this 

acreage includes small isolated parcels outside existing allotment boundaries and areas in 

allotment boundaries with no permitted livestock grazing. Livestock that graze on BiFO 

managed lands are primarily cattle with some sheep and domestic horses. Relative numbers of 

these types of livestock have not varied much over the past 10 years. 

There are 382 grazing allotments in the decision area. In addition to BLM public land, these 

allotments may contain other lands (USFS, state, and private). There are 310 grazing 

authorizations for these allotments. Total permitted use is 62,619 animal unit months with 

7,746 animal unit months in suspension. An animal unit month (AUM) is the amount of forage 

needed to feed a cow, one horse or five sheep for one month. Total permitted numbers change 

frequently due to conversions of the class of livestock and changes in allotment or livestock 

management. Three hundred (97 percent) of the authorizations are for cattle grazing. Seven 

authorizations are for horse/burro grazing, and three authorizations are for sheep. 

3.20.1Bureau of Land Management Grazing History 

The Bureau of Land Management (BLM) manages large areas of Public Lands in the western 

United States. The history of the BLM began in 1934. 

The General Land Office (GLO) managed grazing of public lands outside forest perimeters 

prior to 1934. Comprehensive management of these lands was initiated in 1934 when Congress 
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passed the Taylor Grazing Act. The Grazing Service was established with the implementation 

of the Act. Specific tasks within the Act included: establishment of a permit system, 

organization of grazing districts, fee assessment, and consultation with local advisory boards. 

In 1946, the Grazing Service was combined with the General Land Office to create the BLM. 

In the late 1960s and early 1970s, a shift in public attitude regarding the use of public land 

emerged. Congress passed the National Environmental Policy Act (NEPA) in 1969, directing 

land managers to consider the environmental consequences of activities on federal lands. As a 

result of the NEPA and the Natural Resources Defense Council (NRDC) v. BLM decision in 

1973, Environmental Impact Statements (EISs) were prepared for every resource area 

administered by the BLM. One purpose of these EISs was to address the status of grazing and 

to develop an approach to meet long term goals of grazing on public land. 

In 1976, Congress passed the Federal Land Policy Management Act (FLPMA) which requires 

that public domain lands be managed for multiple-use. FLPMA also reaffirmed BLM’s 

authority to reduce livestock numbers if necessary. FLPMA also provided for the preparation of 

Allotment Management Plans (AMPs) in consultation, coordination, and cooperation with 

permittees for each grazing permit. This requirement integrated the development of AMPs into 

the permit process. The Public Rangeland Improvement Act (PRIA), passed by Congress in 

1978, established a grazing fee formula that sets and adjusts annual fees for grazing on public 

domain land. 

In 1986, a management approach was initiated with the goal of monitoring the long term and 

short term effects of grazing. The objective of monitoring was to provide a long term database 

that would allow for the identification of specific problem areas and management actions 

necessary to correct those problems. The method implemented was an “allotment evaluation” 

process with a 3 to 5 year data compilation interval. 

In August of 1995, new regulations were enacted that changed methods and administrative 

procedures used by the BLM in its management of public lands. Commonly referred to as 

Rangeland Reform ’94, these regulations directed the establishment of standards and guidelines 

to “achieve properly functioning ecosystems for both upland and riparian areas.” In addition, 

these regulations changed how the BLM manages and permits grazing allotments. 

Grazing Standards and Guidelines for Montana/ Dakotas were approved by the Secretary of the 

Interior on August 12, 1997. 

Management Eras (Mid-1960s to 1980) 

The “adjudication” of BLM grazing permits occurred over a period of approximately fifteen 

years, from the mid-1950s into the late-1960s. Adjudication consisted of establishing the extent 

of historical grazing on allotments and included a review of the following factors: 

Priority Use - Priority use meant establishing priority grazing use prior to the Taylor Grazing 

Act. All priority period use claims were subject to validation and constituted a primary permit 

preference limitation. 

Base Property Production - All BLM Districts imposed a minimum base property requirement, 

predicated either on land or water. Such assets as privately owned base property, hay fields, hay 
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stacks, pastures, and water rights were inventoried. Privately owned water flows were 

measured, and production was calculated. If the existing grazing allocation exceeded the 

maximum allowable base property production ratio, the grazing permit was subject to 

reduction. 

Public Land Carrying Capacity - During the adjudication period, a one-point-in-time carrying 

capacity survey was conducted of all grazing allotments. After meeting the first two tests, if the 

existing grazing allocations exceeded the surveyed carrying capacity, the grazing permit was 

subject to reduction. If the carrying capacity met the permitted numbers no AUM reductions 

were realized. 

The collective results of applying these three limiting factors determined the amount of 

“adjudicated grazing privileges.” Adjudicated permits were also referred to as “Base Property 

Qualifications” that were subject to change and refinement as further site specific information 

became available. The adjudicated grazing permits also included a number for historical 

suspended AUMs. Suspended AUMs were those AUMs above the number of adjudicated 

AUMs that had historically been grazed on BLM lands. 

After the adjudication process ended, the formal implementation of “grazing management” 

began by the BLM. Grazing management systems were developed and incorporated into 

allotment management plans (AMPs). As AMPs were implemented, a second round of grazing 

permit adjustments generally occurred. This management phase was well underway by the mid1960 and progressed until the mid-1970s when the NRDC lawsuit required a shift in 

management toward the development of environmental impact statements. 

Most AUM reductions during this period were based on results of BLM Soil-Vegetation 

Inventory Method (SVIM) surveys, reported in the earliest grazing EISs. Protests from the 

range livestock industry and professional range management specialists caused the SVIM 

process to be reevaluated and it was demonstrated that one-point-in-time surveys could not be 

used to calculate rangeland carrying capacity in an accurate and consistent manner. The BLM 

issued a decision discontinuing SVIM surveys and began a program based on utilization and 

vegetation trend monitoring. Resultant monitoring data are used to evaluate whether or not 

grazing practices have been successful at meeting objectives established in resource 

management plans, rangeland program summaries, and AMPs. 

(BLM initiated a selective management process to prioritize expenditures of limited range 

management funds. Allotments were grouped into categories according to their resource 

potential, current management status, and complexity of resource issues. Allotments classified 

as “I” were to be managed to Improve current condition; allotments classified as “M” were to 

be managed to Maintain satisfactory conditions; allotments classified as “C” were to be 

managed Custodially while protecting existing resource) 

Management Era (1980 to Present) 

In 1986, the BLM Washington office issued Instruction Memorandum-1986-706). This 

memorandum instructed that monitoring evaluations be conducted of all “I” and “M” 

management category allotments. Each allotment evaluation would result in either grazing 

agreements, issuance of grazing decisions, or documentation to the allotment file concerning 
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grazing management. Allotment evaluations were performed as monitoring results for a fiveyear period became available. These evaluations summarize vegetation condition and trend, 

and provide data so personnel may interpret how the current livestock use, wild horse use, 

precipitation, wildfire, and other factors influence vegetation changes. Each allotment 

evaluation concluded with specific management recommendations. Management changes were 

implemented in the years following evaluation, either through agreement or decision. 

Management actions included reduction in livestock numbers, changes in grazing management 

such as implementation of a grazing system, or a change in season of use. 

In August of 1995, new regulations were enacted. These regulations directed the establishment 

of standards and guidelines to “achieve properly functioning ecosystems for both upland and 

riparian areas.” Although, actions to revise these regulations have been initiated, litigation has 

prevented any significant changes from taking place. 

From 1956 through 1972, the BLM conducted a classification of public lands within the Miles 

City Field Office (Figure 3-28). These are typically referred to as the “Missouri River Basin 

Surveys”. From this effort eight separate reports were generated, which provided the grazing 

use by Animal Unit Months (AUMs) for all BLM lands at the time of survey. 
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Figure 3-28 Grazing Land Classification 

The process to estimate the available forage for livestock grazing was conducted by trained 

individuals and involved intensive vegetation sampling (clipping, weighing, and ocular 

estimation). The BLM, in cooperation with grazing advisory boards, used the information to 

make adjustments so the AUMs allocated to a grazing permit. This cooperative effort resulted 

in decrease, increase, or no change being implemented for every grazing permit in the field 

office. These changes were implemented in a timely manner and completed prior to 1975. 

The BLM organization regarding the Billings Field Office has varied in the past. Prior to 1983, 

the Billings Field Office was part of the Lewistown District. In 1984, the Billings Field Office 
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became part of the Miles City District. The Billings Field Office was part of the Miles City 

District until 1998. In 1999, the Billings Field Office became a stand-alone field office and 

currently remains a stand-alone field office. 

Throughout the multiple organizational changes, the Billings Field Office boundary (Planning 

Area) has remained relatively unchanged. However, small changes have occurred. In the 

1960s, the grazing administration on several grazing allotments near the Montana/Wyoming 

state line was transferred to the BLM Wyoming Cody Field Office. Included in this transfer 

were approximately 29,000 acres of public land and 2,237 AUMs. 

In 1984, while the Billings Field Office was still part of the Miles City District, the current 

Record of Decision (ROD) for the Billings Resource Management Plan was signed. This ROD 

authorized 62,437 AUMs annually. Any reductions in livestock use would be phased in over 

five years, according to the BLM grazing regulations which were substantiated by monitoring 

and consultation. Since this ROD was signed, some reductions were made either by permitting, 

by operator request, or voluntary preference reductions in actual use. The 1992 Range Program 

Summary (RPS) reflects total active preference for the Billings Field Office of 58,324 AUMs 

or approximately 93 percent of the AUMs initially authorized in the 1984 ROD. Additionally 

in 2011, the Billings Field Office billed 49,413 AUMs. This represents 79 percent of the 

AUMs authorized by the 1984 ROD (82 percent if you take the WY CFO off the ROD 

authorization total). 

3.20.2 Grazing Permits and Leases 

Grazing use in a designated allotment is authorized through issuance of grazing permits or 

leases. Permits and leases and attendant activity plans describe livestock class, intensity, 

duration, and timing of grazing as well as fences, water developments, and other range 

improvements to be installed. Permitted use is defined as the total number of AUMs in a 

grazing allotment that BLM has allocated for livestock use. Table 3-64 shows each county’s 

acreage by preference codes. Grazing preference can only be used by qualified operators that 

own or control land suitable as base property. BLM analyzes effects of proposed grazing 

according to the NEPA process and prepares an appropriate environmental document prior to 

permit issuance or renewal. Most permits and leases are valid for a period of 10 years. 

The resource demand by domestic livestock is considered to be the total of current authorized 

(permitted) use (62,619AUMs) and suspended use (7,746 AUMs). Suspended AUMs reflect a 

temporary withholding from active use, through a decision issued by the authorized officer or 

by agreement, of part or all of the permitted use in a grazing permit or lease. 

Table 3-64 Summary AUMs by County and Preference Code in the Planning Area 

(Calendar Year 2008) 

Number of Permitted & Suspended AUMs by County Section 03 Section 15 Total

Big Horn Permitted 39 103 142

Suspended 24 0 24

Carbon Permitted 13,435 279 13,714

Suspended 2,086 0 2,086
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Golden Valley Permitted 100 32 132

Suspended 0 0 0

Musselshell Permitted 24,822 1,143 25,965

Suspended 822 0 822

Stillwater Permitted 0 897 897

Suspended 0 0 0

Sweet Grass Permitted 0 2,485 2,485

Suspended 0 63 63

Wheatland Permitted 6 186 192

Suspended 5 0 5

Yellowstone Permitted 11,028 318 11,346

Suspended 4,695 51 4,746

Total Sum of County Permitted 49,430 5,443 54,873

Total Sum of County Suspended 7,632 114 7,746

Grand Total 57,062 5,557 62,619

Note: 

*Numbers may vary due to fluctuations in permitted AUMS in calendar year and query parameters. 

Source: USDI Bureau of Land Management, Rangeland Administrative System 

Details of management may be incorporated into an Allotment Management Plan that becomes 

part of the lease or permit. These plans include grazing instructions specified to meet resource 

condition, sustained yield, multiple uses, economic, and other objectives. 

The BLM authorizes permittees to use the land for grazing by establishing an allocated amount 

of forage a permittee may graze on an allotment (this is referred to as “active use”). A permittee 

may enter temporary non-use status when operators do not wish to graze for financial, 

operational, or related reasons or where resource conditions do not allow for grazing. 

Alternatively, if excess resource is available as a result of favorable weather and good growth 

conditions, the BLM may temporarily authorize the permittee to graze in excess of the 

established level of use. If the permittee chooses to allow another operator to graze livestock on 

their permitted allotments, livestock control agreements must be filed with and approved by the 

BLM Authorized Officer.

3.20.3Range Health Standard Assessments 

The Montana/Dakota’s Standards for Rangeland Health and Guidelines for Livestock Grazing 

Management (BLM EIS, 1997) addressed resource conditions for soils, riparian systems, 

upland vegetation, wildlife habitat, T&E species, and air and water quality (BLM, 1997). 

Resource conditions on each allotment are evaluated through assessment and monitoring. From 

these assessments, potential impacts of grazing are evaluated in the context of standards for 

rangeland health and guidelines for grazing administration. A BLM interdisciplinary team 

evaluates allotments in accordance with established rangeland health standards and guidelines. 

Standards are descriptions of desired conditions of the biological and physical components and 

characteristics of rangeland. Guidelines are management approaches, methods, and practices 

intended to achieve a standard. Refer to Appendix S for number of allotments and acres under 

each category (i.e. Meeting All Standards, Not Meeting Standards, But Making...etc.) 
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Allotment evaluations include identification of factors influencing resource conditions. Where 

current grazing management practices or levels of grazing on public lands are a significant 

factor in failure to achieve rangeland health standards, BLM has until the next grazing season 

to begin implementing corrective actions. 

Corrective actions may include adjustment to grazing duration, timing, intensity, forage 

utilization, or installation or implementation of range improvement projects. Permittees, 

interested public, and other agencies are consulted and actions are analyzed according to the 

NEPA process prior to implementation of corrective actions. 

3.20.4Guidelines for Grazing Management 

Guidelines for grazing management include methods and practices deemed appropriate to 

ensure standards can be met, or that significant progress can be made, toward meeting 

standards. Guidelines are BMPs, treatments, techniques, and implementation of range 

improvements that help achieve rangeland health standards. Guidelines are flexible and are 

applied in site specific situations. Guidelines may be adapted or changed when monitoring or 

other information indicates the guidelines are not effective or a better means of meeting 

applicable standards exists. 

The grazing regulations under 43 CFR 4180.2(e) requires that minimum state or regional 

guidelines must address the following: 

 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 

 Maintain or promote appropriate kinds and amounts of soil organisms, plants 

and animals 

 Promote the opportunity for seedling establishment 

 Maintain, restore, enhance water quality 

 Restore, maintain or enhance threatened and endangered (T&E) habitat 

 Restore, maintain, enhance T&E candidate and special status species’ habitat 

 Maintain or promote native populations and their communities 

 Emphasize native species in the support of ecological function 

 Only incorporate the use of non-native plant species when native species are not 

available or are incapable of achieving proper functioning condition. 
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3.20.5Range Improvement Projects 

Range improvements are installed and projects are implemented to improve condition or 

facilitate resource management. Most range improvements in the decision area consist of items 

such as fences, wells, and spring developments. Fences are used to keep permittees’ livestock 

separate, control seasonal use, and prevent grazing in selected areas. Water improvements help 

improve livestock distribution and alleviate pressure on natural water sources and provide 

water for some wildlife species. 

Range improvements can be authorized on public land under a Cooperative Range 

Improvement Agreement or Range Improvement Permit. Cooperative Range Improvement 

Agreements are used to authorize permanent structural improvements such as fences, wells and 

reservoirs, and assign maintenance responsibilities to the permittee/lessee. Range Improvement 

Permits only authorize installation of removable improvements such as livestock handling 

facilities. Proposed projects funded by BLM are prioritized based on evaluation of the need and 

costs as they relate to expected benefits. All improvements are constructed according to BLM 

standards and specifications. 

The BLM will apply for new water rights for water sources on BLM land under the same state 

laws and regulations as all other appropriators; except in cases where water use is specifically 

protected by federal law or executive order. Within the decision area, BLM filed 722 water 

right claims. These sources include springs, pothole lakes, reservoirs, and wells. Private parties 

and other government entities filed an additional 45,320 water rights claims within the decision 

area. Most of these claims have been reviewed by the Montana Water Court or published for 

public review to date. For Adjudication Claims, Permits and Total Water Rights by county 

within the decision area, refer to Appendix U.

3.20.6Prohibited Acts 

Permits or leases and preference may be canceled and civil penalties may be applied as a result 

violating grazing rules. The BLM is responsible for monitoring use on the land it administers. 

3.20.7Factors Influencing Grazing 

A variety of environmental, economical, and social factors are considered in planning decisions 

related to livestock grazing. Grazing management is adjusted during permit and lease renewal 

and in response to these factors when appropriate. These factors may influence grazing 

management in the planning area. 

3.21 Recreation and Visitor Services 

Federal lands in the planning area provide a broad spectrum of outdoor opportunities that give 

visitors a range of recreational choices with few regulatory constraints. Recreational 

opportunities are offered to the public on all BLM administered lands in the planning area 

where legal access exists. 

Approximately 300,000 visitors use public lands in the planning area each year. Primary 

recreational activities include big game hunting, trapping, hiking, camping, backpacking, 
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picnicking, wildlife and landscape viewing, OHV riding, horseback riding, mountain biking 

and organized group events. The BLM’s Recreation Management Information System (RMIS) 

report for 2010 listed camping as the most popular outdoor activity in the BiFO; hiking was 

second, and big game hunting was third. Detailed information on recreational activities in the 

planning area is shown in Table 3-65. 

Table 3-65 Planning Area Visits and Visitor Use Days by Primary Recreation Activities 

Recreation Activity Visits Percentage of Total Total Visitor Days

Big Game Hunting 40,777 18.7 60,505

Hiking 40,804 18.7% 60,545

Camping 42,494 19.5% 63,052

Note: 

Source: BLM RMIS, FY 2010 

These diverse recreation uses occur in both dispersed and concentrated recreational settings and 

vary from primitive to developed opportunities. Travel preferences are also variable as 

recreationists seek both non-motorized and motorized opportunities. The RMIS reports indicate 

that most recreation activity in the decision area is associated with dispersed land based use. 

Two areas in the BiFO decision area are managed specifically for all terrain vehicle (ATV) and 

motorcycle use (South Hills and a portion of Shepherd Ah-Nei Areas). Two areas in the BiFO 

decision area are managed specifically for non-motorized day use (Sundance Lodge SRMA and 

Four Dances Natural Area SRMA/ACEC. 

User conflicts have increased with increased recreational use. This is often due to differing 

expectations and incompatible activities. 

BLM Manual 8320 directs the BLM to designate recreational units known as special recreation 

management areas (SRMAs), extensive recreation management areas (ERMAs), and Public 

Lands Not Designated (PLND). All public lands within the Field Office will receive one of 

these classifications in the RMP. 

A Special Recreation Management Area (SRMA) is an area with a commitment to provide 

specific recreational activities and opportunities. These areas usually require a higher level of 

recreation management. Each SRMA has a distinct primary set of objectives, recreation 

opportunities, and character settings, as well as a corresponding and distinguishing 

management strategy. The 1984 RMP (BLM 1984), which designated no SRMAs, was 

amended in 2001 to add two SRMAs to the decision area: Four Dances Natural Area and 

Sundance Lodge Recreation Area. 

Lands not designated as an SRMA but which have non-specialized recreational use are 

managed as extensive recreation management areas (ERMAs). ERMAs are a location where 

recreation is dispersed and does not require intensive management (although such areas may 

contain recreation sites). While recreation is not the primary management objective for 

ERMAs, it is an important consideration. This type of undirected or dispersed recreation 

management affords visitors the opportunity to create their own experience without services or 

developed recreational facilities. These areas are characterized by a natural resource setting and 

a diversity of recreation opportunities. 
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All other lands not designated as a SRMA or an ERMA are lands where recreation is not 

emphasized, however recreation activities may occur in equal emphasis with other resources 

and activities except on those lands closed to public use. The PLND lands are managed to 

allow recreation uses that are not in conflict with the primary uses of these lands and have 

minimal recreation program investment. 

3.21.1Four Dances Natural Area ACEC and SRMA 

Four Dances Natural Area is on a plateau located two miles east of downtown Billings and is 

bordered on the east by Coburn Road and on the west by the Yellowstone River. The plateau is 

edged with cliffs that drop 200 to 500 feet to the Yellowstone River (Map 85). 

The BLM acquired the Four Dances Natural Area in 1999. Through cooperative efforts of the 

landowners, the Yellowstone River Parks Association, and the BLM, 784 acres of undeveloped 

open space in Billings came into public ownership. Approximately 7,000 recreationists visit the 

area annually. Four Dances is designated an SRMA and ACEC. BLM’s objectives for the site 

are the protection of open space and natural and cultural resources while providing dispersed 

and low level facility infrastructure for public recreation in Billings. This area provides a 

unique opportunity for the public to easily access public lands in an urban area. 

Recreation opportunities include wildlife viewing, hiking, nature photography, and 

opportunities for environmental education. This area is for non-motorized day use only. For 

protection of ACEC values and public safety, the area is closed to horseback riding, use of 

fireworks, hang gliding, rock climbing, paint ball activities, the discharge of firearms, and 

exercising pets off leash. Improvements include an interpretive kiosk, vault toilet, host site 

parking pad, some trail-side benches, and a parking lot. Only day use is allowed. 

3.21.2Sundance Lodge Recreation Area SRMA 

Sundance Lodge Recreation Area is located near the confluence of the Clarks Fork of the 

Yellowstone and the Yellowstone rivers. The site includes about 380 acres of river bottom 

intermingled with the irrigated hay lands. Sundance Lodge was a working ranch before the 

BLM acquired it in 1997. The Nature Conservancy, the Yellowstone Chapter of Pheasants 

Forever, and the BLM combined efforts to acquire the land. The area provides dispersed 

recreation experiences near the communities of Laurel and Billings, public access to the Clarks 

Fork of the Yellowstone, and wildlife habitat protection (Map 84). 

An agreement with MTFWP and the Yellowstone Chapter of Pheasants Forever enables them 

to assist BLM with management of the property. 

Recreational opportunities include wildlife viewing, environmental education, photography, 

hiking, biking, and horseback riding on designated roads and trails. Trails in the Sundance 

Lodge Recreation area provide access while protecting fragile riparian resources from overuse. 

Accessibility for all visitors allows for a greater sense of personal freedom through increased 

recreational opportunities. Archery hunting and limited shotgun hunting is available through a 

block management program with MTFWP. Only day use is allowed. Overnight camping is only 

allowed through special use permits for special events approved by the BLM. Motorized 
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vehicle use is not allowed. Improvements to the site include a loop parking and turn around, 

kiosk, and vault toilet. 

3.21.3Other Recreation Management Areas 

The following sites in the decision area were not designated as SRMAs or ERMAs in the 1984 

RMP or subsequent planning efforts; however, the areas provide a variety of recreational 

opportunities and receive slightly heavier visitor use than other BLM-administered lands in the 

planning area. Funding and personnel have been directed to these areas over the years to 

provide visitor services, manage recreation user conflicts, and protect resources for the purpose 

of providing specific “structured” recreation opportunities. Most are essentially being managed 

as ERMAs at this time, while the Shepherd Ah-Nei Recreation Area is being managed at a 

level commensurate with an SRMA. These areas will be addressed in a range of management 

actions to enhance visitor services and protect resources. 

3.21.3.1 Acton Recreation Area 

The Acton Recreation Area is comprised of 3,697 acres and is located approximately 18 miles 

north of Billings, Montana. This public land area is one of the few that is easily accessible to 

recreationists who enjoy non-motorized off road activities such as mountain biking and 

horseback riding. Approximately 7,000 visitors use the area annually. The Acton Recreation 

Area is open to camping, hiking, horseback riding, and mountain biking, and the entire area is 

closed to shooting except during seasons established by MTFWP. Acton provides multiple 

possibilities for year round use. A small kiosk and identification sign are the only 

improvements at the site (Map 86). 

The 1984 RMP identified 133 acres at the Acton Recreation Area that could be developed for 

environmental education opportunities for local schools. However, demand for this type of 

outdoor experience for local schools using specifically designated developed locations, has 

diminished in the past 10 years, and no further development has occurred. 

3.21.3.2 Asparagus Point Area

Asparagus Point is comprised of 158 acres and is located 12 miles east of Roundup, Montana. 

Camping, fishing, and some hunting occurs at the site, however use has not increased 

substantially over the past several years. It is located on the Musselshell River and is the only 

public access point for its entire length in the BiFO. There are limited facilities (an access road, 

directional and site signing, fencing, and a kiosk which were mostly destroyed in the flood of 

2011. At this time no determination has been done on rebuilding the site since engineering and 

financial estimate is required (Map 87). 

3.21.3.3 Pryor Mountains Area 

The Pryor Mountains area is comprised of approximately 81,227 acres and is located 

approximately 60 miles south of Billings and provides a wide variety of recreation 

opportunities. The PMWHR and Pryor Mountain, Burnt Timber Canyon, and Big Horn TackOn Wilderness Study Areas (WSAs), as well as the East Pryor ACEC, the Crooked Creek 
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Natural Area, and the Crooked Creek Natural Area National Natural Landmark are all in the 

Pryor Mountain area. 

More than 100,000 visits to the Pryor Mountains are recorded each year, presumably because 

of their close proximity to urban areas and the range of recreation activities and experiences 

accessible there. Viewing the wild horse herd is one of the Pryor Mountain’s largest draws. 

Visitation to the area is especially heavy during late spring when foals are born and through the 

summer months when horses are in the high open meadows. Other recreation opportunities 

include hiking, backcountry camping, and viewing wildlife. Other seasonal activities include 

upland bird and big game hunting, cross country skiing, and snowmobiling. Motorized use is 

limited to designated roads. A primitive cabin is available for overnight use on a first come, 

first served basis. There are a number of caves which attract recreational users (Map 89). 

3.21.3.4 Shepherd Ah-Nei Recreation Area 

Shepherd Ah-Nei Recreation Area, comprised of 4,680 acres, is located about 30 miles 

northeast of Billings, and is an important outdoor recreation resource in the planning area. The 

entire area is closed to shooting except during hunting seasons established by MTFWP. Visitor 

opportunities include horseback riding, hiking, mountain bike riding, nature study, hunting, and 

OHV riding. 

For management purposes, the recreation area has been separated into three smaller 

management areas. Each area provides unique recreation opportunities (Map 91).

 Area 1 (976 acres) was closed to full sized vehicles in 1985, and current use 

includes ATVs, motorcycles, mountain biking, hunting in season, and hiking. 

An additional 640 acres was acquired in 1994 to expand the area. In 2005, the 

BiFO completed a travel management plan for the area, and 50 miles of trail 

were designated “open.” Improvements include a graveled parking lot, 

handicapped accessible vault toilet, kiosk, fee station, and unloading ramp. 

Motorized users are required to purchase a permit to use the area, and all fee 

receipts are used for site administration and maintenance to enhance visitor 

experience. 

 Area 2 (452 acres) is located across the road (west) from Area 1 and is closed to 

motorized use. The 1984 RMP (BLM 1984) identified 77 acres for 

environmental education opportunities for local schools; however interest in this 

type of outdoor experience has diminished, and nothing further was done. A 

parking lot, rustic picnic tables, cooking grill, and restroom are located in the 

northern portion of Area 2. 

 Area 3 (3,212 acres) is also on the west side of the road and allows motorized 

use by special recreation permit on existing roads. Permits can be purchased 

annually or at the fee station for a single day use. Two walk through gates 

provide access for foot traffic and horseback riders. 
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3.21.3.5 South Hills Area

The South Hills area is comprised of 1,357 acres and is located two miles south of Billings and 

east of Blue Creek Road on the upper level of a large bentonite deposit. Approximately 2,500 

recreationists visit the site annually. South Hills is the only area in the BiFO managed as 

“open,” where motorized cross country travel is allowed. The riding area is open for 

motorcycle use only (Map 93). 

Access to the South Hills riding area is through a small parking area bordered on the west by 

Old Blue Creek Road and on the north by private land. Riverfront Park, an Environmental 

Education Conservatory, and developing residential areas are either adjacent to or one quarter 

mile from the parking lot. A site sign and barrel barriers are the only improvements on site. The 

parking lot and entrance to the riding area is in need of engineering and reconstruction to 

address erosion, user safety, and accessibility. 

Users have established unauthorized/illegal access routes to the riding area. Access is obtained 

by riding up extremely steep terrain to the open riding area above. Legal access routes have 

become rutted and unsafe, and unauthorized access points created by users are dangerous. 

The riding area is adjacent to two large subdivisions. Conflicts between recreationists and 

residents are frequent and result from competing recreational expectations. The 1984 RMP 

(BLM 1984) decision closed a 70 acre portion of the area to provide a noise buffer to the 

adjacent residential area and closed 237 acres to all motorized use. The decision also closed the 

remaining area to all four wheeled vehicles, including ATVs. Currently, unauthorized use is 

occurring in the buffer area resulting in complaints about noise and dust. In one area, property 

damage resulted from a mud flow from the parking lot following a heavy downpour. 

3.21.3.6 17 Mile Area 

The area has good local access with a county maintained road along the southern side of the 

parcel and Montana State Highway 87 along the east side. It is located approximately 17 miles 

north of Billings, the largest community in Montana and is 2,080 acres in size (Map 95). 

The 17 Mile area is a popular and traditional destination for recreational shooting. It has good 

terrain features with shooting distances ranging from approximately 100 yards to over 500 

yards in places, and the backstop is a butte rim with elevations of 50 feet in height. Although 

surrounded by private lands, there are no buildings within 1.25 miles and they are located in the 

opposite direction which shooting is occurring. There are no other recreational uses and the 

area is not grazed commercially. 

Previously, this area was the focus of management issues including unsafe shooting practices, 

littering, and the shooting of animals. BLM management effort to date has included a 

temporary closure, installation of several kiosks for resource and safety information, public 

information and outreach, cleanups, and regular visits by BLM staff. Currently community 

volunteers and users regularly clean the site of shooting debris. 

The BiFO has determined that recreational shooting continues to be popular on public lands, 

and public demand for safe, legal places to shoot remains high. Responding to public requests, 

BLM staff usually direct recreational shooters to the 17 Mile site. 
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3.21.3.7 Horsethief Recreation Area 

The recreational area is located approximately 5 miles west of the community of Roundup, 

Montana. It is approximately 12,261 acres in size. The main activity is dispersed recreation. 

The BiFO has installed two kiosks for public information and access education. The Horsethief 

Recreation Area is open to camping, hiking, horseback riding, mountain biking, and hunting 

(Map 97). 

3.21.3.8 Yellowstone River Corridor 

The Yellowstone River flows northeast through Montana from its source in the southern 

Absaroka range in Wyoming to its junction with the Missouri River in North Dakota. The 

Billings Field Office includes approximately 150 miles of this river between Springdale and 

Custer, Montana. There are numerous small parcels along the banks and 10 islands managed by 

BiFO along its course. Typically the western islands have willow and old growth vegetation 

with an understory of shrubs and grasses. As one progresses eastwards, cottonwoods 

predominate, but willows, thick shrubs, and even open meadows of range grasses are found. 

Invasive species such as Salt Cedar, etc., have established themselves all along the river 

corridors. The small land parcels typically have rolling hills with mixed vegetation and steep 

bluffs along the banks of the river (Map 99). 

Interstate Highway 90 and the mainline of the Northern Pacific Rail Road parallel the 

Yellowstone River for much of the distance, but not always right by the river and there are 

rolling hills and curves in the road and Rail Road courses. The islands do provide outstanding 

opportunities for primitive recreation since access is limited to boat only and the Yellowstone 

River is a popular fishing destination. However, the Yellowstone River is open for motorboat 

use, which is a semi-primitive activity. User numbers are not known. Access from the shore is 

sometimes restricted by private land access issues. The BLM has no developed recreation sites 

or boat launch sites. 

The Yellowstone River varies in width from 74 feet (23 m) to 300 feet (91 m), so fishing is 

normally done by boat. Mainly, anglers seek Burbot, Channel Catfish, Paddlefish, Sauger, 

Smallmouth Bass, and Walleye. 

The area under consideration for potential SRMA designation varies by Alternative. In 

Alternative B it is not considered, except for a small portion known as Bundy Island (98 acres) 

which in Alternative B is considered separately. In Alternative C and Alternative D it is 6,311 

acres. 

3.21.3.9 Bundy Island

Located in T. 3 N., R. 30 E., Sections 19 and 20. There are two separate islands in close 

proximity. They are both known locally as Bundy Island. A portion of the larger island has an 

old and naturally rehabbing agricultural field on it. The approximate total of BLM lands are 80 

acres and 24 acres although it varies with river flow (Map 101). 
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In Alternative B, it is included as a separate SRMA proposal. In Alternative C, Bundy Island is 

included in the proposed Mill Creek/Bundy Island SRMA, while in Alternative D it is included 

in the Yellowstone River SRMA. 

3.21.3.10 Bundy Island/Mill Creek

In Alternative C, this area includes Bundy Island, described, above, and includes a large tract of 

public lands (approximately 34,241 acres) adjacent to it and extending to the north. It is used as 

a dispersed recreational area, popular with hunters and is also a Travel Management Area 

(TMA) (Map 100) 

3.21.3.11 Elk Basin

Elk Basin is located in T.9 S., R. 23 E., approximately 8 miles southeast of the community of 

Belfry, Montana. The general area is broadly defined by Silvertip Road on the west, Long 

Draw road (CW 2066) on the east, and the Montana/Wyoming border on the south. In the RMP 

it is considered to be a component of the Sub-Region III – Silver Tip region of the 

Cottonwood/Weatherman Draw TMA. 

This area provides a challenging single-track trail system for both casual and commercial 

Motorcycle travel. Most of these routes have been user-created. Not all of the motorcycles 

routes have been included in the Cottonwood/Weatherman Draw TMA decision since not all 

single-track routes have been mapped or evaluated. The BLM has a Primitive Staging area with 

minimal facilities on Silver Tip Road and generally directs users to the area, weather conditions 

permitting. 

Although the land use somewhat overlap, OHV use does not generally intrude into the Elk

Basin oil and gas field operations – riders have their own courses north of the main oil and gas 

field area. 

The BLM has not addressed the additional existing single-track routes but will do so as they are 

mapped and evaluated in the follow-on Cottonwood/Weatherman Draw TMA Implementation 

Plan. Currently, the BLM has grouped all single track OHV Trails which have been evaluated 

through inventory and NEPA analysis in this area as routes CW 1EB2084, CW 1EB2085, and 

CW 1EB2086. These routes are shown on the Travel Maps (maps 135, 136, and 137) for the 

Cottonwood/ Weatherman Draw TMA. 

In this area the management objectives are to provide for access and motorized recreational 

opportunities with an emphasis on minimizing impacts to fragile and erosive soils, sage grouse 

and sage grouse habitat, and other resource values. 

3.21.4Special Recreation Permits 

As authorized by 43 CFR 2932, five types of uses exist for which a special recreation permit 

(SRPs) is required: commercial use, competitive events, organized groups, vendor permits, and 

recreation use in special areas. Permits are issued to manage visitor use, protect natural and 
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cultural resources, and provide a mechanism for accommodating commercial recreational uses. 

As noted above, the Shepherd Ah-Nei Recreation Area charges an Individual Recreation Use 

Permit (ISRP), for access to a portion of the unit. 

The BiFO currently administers 16 commercial SRPs, one competitive event permit, and one 

non-competitive organized event. Permitted activities include big game and upland bird 

hunting, horseback riding, guided tours, photography workshops, motocross racing, camping, 

and hobby rocket launching. In addition, several new applications are received annually for 

additional commercial, competitive, or organized group events. All permits are processed on a 

case by case basis with preference given to existing permit holders. Permit lengths depend on 

activities proposed, the area, and the past record of the potential permittee. Permits may be 

issued for periods ranging from one to ten years. 

During the past five years, applications for SRPs have gradually increased 60 percent, with 

requests for guided tour applications increasing substantially. Applications for ranch based 

guided horseback tours and motorized tours for wildlife photography in the Pryor Mountains 

are requested more frequently than other types. Organized groups, primarily scout groups, 

frequently request permits to camp on public lands. These permits are usually for overnight 

campouts for 20 people or less. Fees collected for these special use permits are used to offset 

administrative costs, monitor approved activities, and protect recreation resource values for 

future use. The total amount collected each year varies by actual use. The Shepherd Ah-Nei 

ISRP averages approximately $9,000/year while the other SRPS average approximately 

$2,000.00/year 

3.22Trails and Travel Management 

Travel and transportation are an integral part of almost every activity that occurs on BLM 

public lands. There are numerous routes in the BiFO decision area that connect remote 

locations to roads. These routes are often unpaved and unimproved, typically consisting of 

native material such as dirt, gravel, or sand. Approximately 993 miles of routes/ways in the 

BiFO have been identified. 

Existing roads and trails, some of which are user created, provide access to public recreation 

management areas where most recreation activities take place on public lands in the planning 

area. However, the public land ownership pattern in the BiFO is highly fragmented, resulting in 

access difficulties and potential conflict. Conflicts over access can take place whenever 

ownership is fragmented, along waterways, or where prime resource values occur and 

recreation or other user demands are high. Even where access exists, the lack of boundary 

markers and adequate maps often contribute to confusion about access and can result in 

conflicts among the public, public land administrators, and the owners of associated or 

intermingled private lands. 

Public expectations and demand for motorized and non-motorized recreation has changed 

substantially since completion of the 1984 RMP (BLM 1984) and the Montana, North Dakota 

and portions of South Dakota OHV EIS/ROD (January 2001). Advances in motorized and nonmotorized recreation travel technology and use have increased the public’s ability to traverse 

conditions and terrains not previously envisioned. In addition, OHV use provides access for 

non-motorized recreational purposes, and employees of government agencies, ranchers, timber 
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companies, energy companies, and utility providers use OHVs to access and maintain the 

infrastructure required for the continued operation and maintenance of their facilities. 

Most OHV use in the planning area consists of recreational use of ATVs, motorcycles, and 

other full sized trucks and vehicles. Participation in these recreation activities varies by season, 

topography, vegetative cover, and number of people taking part in the activity. Public lands in 

the planning area provide a wide range of high quality OHV opportunities that vary from 

backcountry to concentrated use areas. In general though, most OHV use occurs on designated 

roads and trails in the decision area (BLM et. al. 2001). 

Motorized OHV use was identified as a planning issue because of concerns related to potential 

resource degradation that may result from high levels of use (BLM et al. 2001). General 

estimates of OHV use in the planning area are shown below in Table 3-66. These estimates 

indicate that the number of trucks used in off highway applications increased 13 percent 

between 1990 and 1998. ATVs and motorcycles were considered a separate group; however 

those numbers increased by 156 percent from 1990 to 1998. 

Table 3-66 Estimated Number of Vehicles Used Off-Highway in Montana (1990-1998) 

Year Trucks ATVs and Motorcycles Total

1990 24,162 7,399 31,561

1991 23,930 8,404 32,334

1992 24,706 10,020 34,726

1993 26,193 11,729 37,922

1994 26,584 13,165 39,749

1995 26,919 14,072 40,991

1996 26,941 15,352 42,293

1997 27,308 16,898 44,206

1998 27,423 18,953 46,376

Note: 

Source: BLM et al. 2001. 

Regional recreational use projections indicate that by 2015 the number of ATVs/motorcycles 

and trucks per year could be 36,249 and 36,797, respectively (BLM et al. 2001). These data 

suggest OHV use is one of the fastest growing activities in Montana. With the registration of 

OHVs increasing annually, OHV use is expected to increase on all Montana public lands, 

including in the planning area. 

The BLM uses three primary designations to manage OHV use on public lands: open, limited, 

and closed. Open designations provide for public driven use and include designated areas and 

trails where OHV use is subject to operating regulations and vehicle standards set in BLM 

Manual 1626. Intensive use areas are generally defined as public lands with no restrictions 

where OHVs are allowed. 

Limited and closed designations help protect natural resources and minimize conflicts among 

various public land users. The limited designation includes areas and trails where OHV use is 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

3-222 Chapter 3: Affected Environment

subject to restrictions, such as limiting the number or types of vehicles allowed, dates, and 

times of use (seasonal restrictions), or limiting use to existing and designated roads and trails. 

The closed designation includes areas and trails where OHV use is permanently or temporarily 

prohibited (BLM et al. 2001). 

The 1984 RMP (BLM 1984) attempted to meet OHV use demand on public land while 

protecting watershed and visual resources and minimizing conflict among OHV users, adjacent 

landowners, and permit holders. In January 1999, the BLM and the USFS prepared the Off 

Highway Vehicle Environmental Impact Statement and Proposed Plan Amendment for 

Montana, North Dakota, and Portions of South Dakota (OHV EIS) (BLM et. al. 2001). The 

OHV EIS considered various ways to minimize the potential for resource damage from cross 

country OHV use. In June 2003, BLM signed the Record of Decision (ROD) for the OHV EIS, 

which amended the 1984 RMP (BLM 1984). This decision limited motorized travel to existing 

roads and trails on BLM managed lands in Montana and the Dakotas and became the current 

standard for establishing management directions related to OHV use on BLM administered 

lands in Montana, North Dakota, and South Dakota. 

The ROD prohibits all wheeled, motorized, cross country travel, including big game retrieval, 

unless otherwise stipulated. In the absence of other travel plan direction, motorized travel is 

restricted to existing established roads and trails. Wheeled motorized cross country travel 

associated with personal use permits is not allowed, unless permitted at the local field office. 

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. Much of the 

motorized wheeled cross country use in the planning area occurs during the fall hunting season 

(BLM et al. 2001). 

Persons with disabilities may be allowed to travel on OHVs in otherwise closed areas on a case 

by case basis. This requires a request to the BiFO to initiate the exception. Motorized wheeled 

cross country travel is allowed for any military, fire, search and rescue, or law enforcement 

emergency. The ROD also directed BLM to identify and complete site specific travel plans to 

designate roads and trails available for motorized use. The ROD includes snowmobile use as a 

component of OHV use. 

The 1984 RMP (BLM 1984), the OHV EIS (BLM et al. 2001) and, for some locations, travel 

management plans completed in April 2007, set forth these objectives to address motorized use 

in the decision area: 

 In a travel management plan completed in April 2007, Acton Recreation Area 

designated 6.5 miles of roads open or limited, and closed areas where 

unauthorized use was occurring. 

 OHV use in Asparagus Point Recreation Area was limited to the main access 

road and parking area (BLM 1984). 

 In a travel management plan completed in May 2005, 640 acres of the Shepherd 

Ah-Nei Recreation Area were designated for authorized use only. Authorized 

use was defined as BLM employees and persons holding a grazing lease. 

Motorized use in the northern part of the recreation area west of CA Road 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-223

(approximately 3,090 acres) was limited to approximately 44 miles of 

designated roads and trails and authorized use. The southern part (approximately 

500 acres) was designated open with the provision that in the event of excessive 

damage, it could be closed to OHV use entirely. Six miles of trails were 

designated closed. 

 A 70-acre area in the South Hills would be permanently closed to all vehicle use 

(to provide a buffer zone), and a 1,200 acre portion of the area would be closed 

to use by four wheeled vehicles (open to motorcycles only). 

 In a travel plan completed in February 2008, approximately 50 miles of roads in 

the Horsethief Area were designated open, and areas where unauthorized use 

was occurring were closed to motorized use. 

 The BLM temporarily restricted motorized vehicle use in the Tin Can Hill parcel 

for resource concerns. 

 A selected number of single-track motorized trails in Elk Basin were designated 

solely for the use by motorcycles and were analyzed through a site-specific 

NEPA process. The remainder of the area and a multitude of single-track 

motorcycle trails are currently under review for Sage Grouse management 

considerations, and the ultimate decision on all of these routes will be set by 

these considerations and addressed through the Cottonwood/Weatherman Draw 

TMA implementation plan. 

A Federal Register Notice published in September 2001 updated and corrected errors in the 

September 25, 1979 and August 4, 1987 road designations based on decisions from the 1984 

RMP (BLM 1984). The following roads in the Pryor Mountains were designated open: 

 Bear Canyon Ridge Road (#1030) 

 Bear Canyon Road (#1014)

 Bent Springs Road (#1039)

 Burnt Timber Ridge Road (#1018)

 Crooked Creek Road (#1017)

 Dandy Mine Road (#1034)

 Demi John Flat Road (#1035)

 East Horsehaven Road (#1030)

 East Petroglyph Canyon Road (#1020)

 Gyp Spring Road (#1015)

 Helt Road (#1016)

 Inferno Canyon Road (#1050)

 Lower timber Ridge Road (#1048)

 Miller Trail Road (#1046)

 Red Pryor Mountain Road (#1022)

 Stockman Trail (#1013)
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Proposed Resource Management Plan and Final Environmental Impact Statement 

3-224 Chapter 3: Affected Environment

 Sykes Road East Loop (#1033)

 Sykes Ridge Road (#1019)

 Sykes Spring road (#1052)

 Timber Canyon Road (#1049)

 Timber Ridge Road (#1047)

 Water Canyon Road (#1051)

 West Horsehaven Road (#1021)

 West Petroglyph Canyon Road (#1036) 

The Nez Perce National Historic Trail auto routes consist of three-season, all weather 

roadways ranging from county-maintained high-standard gravel segments to portions of 

State and Interstate Highways. Nez Perce National Historic Trail signs have been posted 

along the primary auto route and two alternate segments. Auto Tour guides have been 

created for the Nez Perce National Historic Trail (NPNHT) by the USFS, the administering 

agency for the NPNHT. The auto tour guides are available as pamphlets with maps and 

graphics. Designation of these routes as “Auto or Adventure Tour Routes” by the NPNHT 

conveys no new regulation in this RMP. 

3.23 Renewable Energy 

As demand for clean and viable energy to power the nation increases, the occurrence and 

availability of renewable energy sources on public lands is an important consideration in land 

management planning. Solar, wind, biomass, geothermal, and hydroelectric power are 

considered renewable energy resources. It is the BLM’s general policy, consistent with the 

National Energy Policy of 2001, the Energy Policy Act of 2005, the BLM Energy and Mineral 

Policy (August 26, 2008), and the more current Secretarial Order No. 3285 (March 11, 2009), 

to encourage renewable energy development in acceptable areas. 

Market trends and market value determine the pace and magnitude of proposals to develop 

renewable energy. The importance of renewable energy sources in the planning area may 

increase as nonrenewable energy prices increase and as the need for energy grows. Demand for 

renewable energy is illustrated most recently by the increase in project proposals for various 

renewable energy technologies throughout the west on both public and private lands. Some of 

the obstacles to development include a lack of transmission infrastructure for delivery of 

electricity, difficulties in negotiating power purchase agreements, uncertainty in federal and 

state regulatory policy and incentives, and acquisition of financing in a challenging economic 

climate. 

In cooperation with the U.S. Department of Energy’s National Renewable Energy Laboratory 

(NREL), the BLM assessed renewable energy resources on public lands in the western United 

States, including Montana (BLM and DOE 2003). The assessment reviewed the potential for 

concentrated solar power (CSP), photovoltaic (PV), wind, biomass, and geothermal energy on 

BLM, BIA, and Forest Service lands in the west. Hydropower was not addressed in the 

BLM/NREL report. According to the BLM/NREL report, the Billings Planning Unit is rated 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-225

among the top 25 BLM planning units for wind resource potential, with portions of the 

planning area exhibiting Class 5 winds (BLM and DOE 2003). 

The Western Governors’ Association also embarked on a study with the U.S. Department of 

Energy to define Renewable Energy Zones in the Western interconnection. The results of this 

effort are documented in the Western Renewable Energy Zones (WREZ) Phase 1 Report (June 

2009). The report identifies geographic areas labeled Qualified Resource Areas (QRAs) based 

on quantification of energy potential and distance to transmission (Western Governors’ 

Association and DOE, 2009). Based on the QRA information as well as additional 

consideration of sensitive resources and agency protective designations, a map using the 

concept of “hubs” that visually represent areas that may be the most cost-effective for 

development was produced as part of the study. One of the three “hubs” identified in Montana 

in the WREZ Phase 1 Report lies within the boundaries of the BiFO. 

The following discussion outlines the affected environment for all types of renewable energy 

resources in the planning area. However, since wind energy has the greatest potential for 

development in the planning area, it is discussed in more detail than the other renewable 

resources throughout this document.

3.23.1Wind 

The 2003 assessment conducted by BLM in cooperation with the U.S. Department of Energy’s 

National Renewable Energy Laboratory (NREL) rated the Billings Planning Unit among the 

top 25 BLM planning units for wind resource potential, with portions of the planning area 

exhibiting Class 5 winds (BLM and DOE 2003). Subsequently, the Final Programmatic 

Environmental Impact Statement (PEIS) on Wind Energy Development on BLM administered 

lands in the Western United States was released in June 2005 (BLM, 2005) and evaluated the 

potential environmental and socioeconomic impacts associated with wind energy development 

on BLM administered lands in 11 western states over the next 20 years (2005 to 2025). The 

December 2005 Record of Decision (ROD) based on the PEIS analysis amended 52 land use 

plans, including the 1984 Billings RMP, with the establishment of BMPs to be used when 

evaluating and authorizing wind energy applications. The ROD also excluded ROW 

authorizations for wind facilities on BLM-administered lands in Areas of Critical 

Environmental Concern (ACECs) and in areas that are part of the National Landscape 

Conservation System (NLCS), including designated Wilderness, Wilderness Study Areas 

(WSAs), National Monuments, National Conservation Areas (NCAs), Wild and Scenic Rivers, 

and National Historic and Scenic Trails. Subsequently, the policy contained in the 2005 ROD 

on ACECs has been revised to defer to the decisions contained in local land use planning 

documents containing management prescriptions for ACECs. 

As a result of this amendment and current policy, wind energy facilities are currently excluded 

from four WSAs, segments of the Nez Perce and Lewis and Clark National Historic Trails, the 

Pompeys Pillar National Monument, and six of the seven areas currently managed as ACECs in 

the BiFO planning area. 

The potential for utility scale wind energy development in the planning area is based on 

methods used in the Final Programmatic EIS on Wind Energy Development (BLM, 2005). 

Areas are grouped by wind power class derived from 50 meter wind data mapped by the 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

3-226 Chapter 3: Affected Environment

NREL. Wind power classes are divided into seven classes: Poor, Marginal, Fair, Good, 

Excellent, Outstanding, and Superb. For purposes of analysis, the seven wind power classes are 

further grouped into three distinct levels: High, Moderate and Low potential for wind power 

resources (see Maps 151 and 152). 

Table 3-67 outlines the number of acres in the BiFO in Wind Class 1 through 7. Class 1-2 wind 

are considered low, Class 3 winds exhibit moderate potential, and Class 4 through 7 are 

considered high potential areas. Table 2-5 in Chapter 2 identifies the number of acres of high, 

moderate, and low potential excluded from development under current management, as well as 

the other alternatives. 

Table 3-67 Wind Potential in the Billings Field Office in Comparison to All Ownership 

Wind Power Class

&

Resource Potential

Acres

of

BiFO*

Percent 

of BiFO

Acres of

High,

Moderate,

and Low

Percent

of BiFO

Acres in All

Ownerships 

across the 

Planning Area*

Percent 

of

All

Class 1—Poor 56,648 13%

220,242 51%

1,024,065 9%

Class 2—Marginal 163,594 38% 4,076,827 38%

Class 3—Fair 146,057 34% 146,067 34% 3,657,997 34%

Class 4—Good 44,220 10%

63,547 15%

1,191,761 11%

Class 5—Excellent 12,710 3% 401,611 4%

Class 6—Outstanding 4,052 1% 243,258 2%

Class 7—Superb 2,565 <1% 205,316 2%

Note: 

*This does not include 4,298 acres of BLM land in Wyoming administered by BiFO 

In the BiFO, the areas with the greatest wind potential (Class 4 through 7) are located south of 

Bridger, extending to the Wyoming state line, and on scattered parcels in western Stillwater and 

Sweet Grass Counties. 

In addition to wind power classifications, other elements influence the potential for wind 

energy development in the planning area. Proximity to transmission lines as well as available 

capacity on them is a major factor in the siting of wind facilities. Adverse impacts to other 

resources and resource programs can also affect operation and siting. Large wind turbines 

affect the visual landscape and can be considered a visual intrusion. Another key consideration 

is the presence of special status species and potential impacts to both the species and habitat 

from wind development. In the BiFO, concerns with sage grouse, golden eagles and other 

raptors, migratory birds, and bats as well as cultural and paleontological resources pose 

challenges to wind development. 

The BLM currently processes wind energy ROW applications under its Wind Energy 

Development Policy (WO IM 2009-043). On a national basis, BLM continues to develop and 

refine policy and guidance on wind energy planning and development. Only one (1) wind rightof-way grant has been authorized in the BiFO. In 2003, the BiFO approved construction, 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-227

operation, and maintenance of a meteorological tower within a 6,097 project area on BLMadministered land to collect wind data to assess wind resources and development opportunities 

in an area southeast of the town of Bridger. The grant was renewed once, and the “met” towers 

were removed in 2010, with no subsequent development application. Issues with transmission 

and the inability to negotiate lease agreements on private lands appear to present challenges to 

wind development in this area. On a broader scale, indications are that industry may be 

avoiding siting on public land given the potential to encounter resource constraints and 

associated time and resources necessary to address public land issues and processes. 

Wind farms in Montana mainly occupy private lands, though some include State of Montana 

school trust lands. Commercial wind ventures currently generating electricity range from the 

smallest, with 6 turbines producing 9 megawatts at the Horseshoe Bend facility in Cascade 

County, to the largest with 140 turbines producing 210 megawatts at the Glacier I/ II facility 

between Cutbank and Shelby (Montana DEQ, 2011). Closer to the planning area, proposals for 

40 turbines producing 100 megawatts and 44 turbines producing 79 megawatts are under 

consideration in Sweet Grass County. 

Currently, no applications are pending in the BiFO for either wind site testing and monitoring 

(met towers) or development (wind farms). 

3.23.2Solar Resources 

The 2003 assessment conducted by BLM in cooperation with the U.S. Department of Energy’s 

National Renewable Energy Laboratory (NREL) did not rate the BiFO among the top 25 

planning units for solar resource potential, either for concentrated solar power (CSP), or 

photovoltaic (PV) technologies (BLM and DOE 2003). Solar energy on BLM land is currently 

being studied in a six-state area in the Southwest (Arizona, California, Colorado, Nevada, New 

Mexico, and Utah). The BLM and U.S. Department of Energy released a Draft Programmatic 

EIS for the six-state area in December 2010. The study includes BLM lands with solar 

insolation levels greater than 6.5kWh/m2/day and slopes of less than 5%. There are no locations 

in the planning area that receive the solar insolation levels considered necessary for 

development of a viable commercial facility based on current technologies. As a result, the 

potential for development of utility scale solar facilities in the planning area is not likely. To

date, the BiFO has not had any expressions of interest in developing solar resources for 

commercial power production on BLM lands. Due to the unlikelihood of commercial solar 

development in the planning area, allocations and management related to solar development is 

not addressed further in this planning document. 

The BLM currently processes solar energy ROW applications under its Solar Energy 

Development Policy (WO IM 2007-097). In the unlikely event applications for solar energy 

projects are received, the BiFO would apply the policy direction, BMPs, mitigation, and other 

management directives outlined in BLM’s solar program. 

3.23.3Biomass Energy and Resources 

Biomass power is generated from the energy in plants and plant-derived materials, such as food 

crops, grassy and woody plants, residues from agriculture or forestry, and the organic 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

3-228 Chapter 3: Affected Environment

component of municipal and industrial wastes. Biomass can be used for direct heating (e.g., 

burning wood in a fireplace or wood stove) and for generating electricity, or it can be converted 

directly into liquid fuels to meet transportation energy needs. 

The BiFO has not received any applications or authorized any biomass facilities for 

commercial power production. Lack of available transmission, transportation costs to deliver 

feedstock, and high costs per kilowatt for electrical generation all pose challenges for biomass 

energy generation facilities. However, options may exist in the BiFO for biomass utilization. 

Generally, production of biomass resources in the BiFO would result from management of 

forests and woodlands as guided by BLM’s forestry program. Use of small diameter wood 

products or residue is currently encouraged when possible. See the Forest and Wood Products 

section for additional discussion. 

In the event a biomass energy generation facility is proposed on BLM lands, such a proposal 

would be processed under the Realty, Cadastral Survey, and Lands right-of-way regulations.

3.23.4Geothermal 

Geothermal resources are typically underground reservoirs of hot water or steam beneath the 

surface of the earth. Geothermal energy is produced when this steam or heat is used to turn a 

turbine to create electrical energy. Geothermal steam and hot water naturally discharge at the 

earth’s surface in the form of hot springs, geysers, mud posts, or steam vents. Geothermal 

resources also include subsurface areas of hot, dry rock. 

The Final Programmatic EIS for Geothermal Leasing in the Western United States evaluates 

various alternatives for allocating lands as being closed or available for geothermal leasing and 

analyzes stipulations to protect sensitive resources. The ROD for the Geothermal Programmatic 

EIS (BLM and USFS 2008) amended existing plans, including the 1984 Billings RMP, to 

facilitate geothermal leasing on federal mineral estate. In the BiFO, 149,410 acres are open to 

leasing and 6,768 acres are closed. No electrical production via geothermal resources was 

projected from any specific areas in the BiFO. 

Additional information on geothermal resources can be found in the Energy and Minerals, 

section. Any proposals for geothermal development on BLM-administered lands would be 

processed under leasing regulations for geothermal resources, and stipulations, mitigations 

measures, and BMPS outlined in the ROD for the Geothermal Programmatic EIS would be 

applied as appropriate.

3.23.5Hydroelectric 

Hydroelectric power is generated through use of the gravitational force of falling or flowing 

water. There is no specific policy guidance or direction for the development of hydroelectric 

facilities on BLM-administered land as a renewable energy resource. Proposals for 

hydroelectric power development on any federal lands would generally be authorized under 

FERC authority in consultation with BLM on mandatory license provisions for BLMadministered lands, based on provisions of the Federal Power Act, as amended. While the 

potential for construction of major hydroelectric facilities in the BiFO is limited given the lack 

of major flowing water resources under BLM jurisdiction, the potential for smaller hydro-
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-229

pumping projects may exist in certain areas. While interest in these types of projects is 

increasing as an avenue to “firm” electricity generated from wind, the BLM has not received 

applications for any type of hydroelectric power authorizations on BLM-administered land in 

the planning area. 

Specific allocations and management related to new hydroelectric development is not 

addressed further in this planning document. 

3.24Transportation and Facilities 

This section describes transportation facilities and their maintenance as well as other types of 

facilities administered by the BLM. Travel routes/designations are addressed in the Travel 

Management section (Section 3.3.4). The BLM’s transportation system is critical for 

management of its public lands. Transportation facilities and access provide people the 

opportunity to use and travel to and through specific lands in the BiFO planning area, as well as 

provide for BLM-administrative use of BLM public lands and facilities. 

Most of the larger tracts of public lands have legal public access via existing federal, state and 

county roads. Many smaller tracts of public lands do not have legal access. In most cases, such 

parcels do not have resource values/demands that justify the costs for acquiring access to these 

isolated parcels (refer to Appendix J – Land Tenure for information on considering land 

exchanges and/or acquisitions with regard to access). There are some situations where road 

segments to and within these parcels are important for a given resource use or to provide 

through access to other lands and are therefore included in the transportation plan. 

3.24.1Federal Roads, Airports, and Railways 

A network of federal, state, and county roads provides access throughout the planning area. 

Traffic volumes on the network are highly variable with the highest volumes found on major 

roadways in or near the larger communities. Primary federal roads in the planning area include 

Interstate 90, which bisects the planning area and runs between Hardin and Big Timber, and 

Interstate 94, which runs between Billings and the area east of Pompeys Pillar NM. These 

interstate highways carry traffic throughout the region and from surrounding states. 

Rail travel through the planning area began with the construction of the Northern Pacific 

Railway in the early 1880s. The federal government subsidized developing rail lines with 

substantial land grants that were, in turn, developed for mineral, agricultural, and tourist 

potential. Currently, passenger service is not available in planning area. The nearest passenger 

service is an Amtrak stop in Malta, 212 miles north of Billings. Freight service is provided on 

several main track lines by the BNSF Railway Company. 

Billings Logan International Airport is situated just north of Billings. The airport was 

constructed in 1928, and passenger service began in 1933. The airport services eight airlines 

flying to multiple destinations, including Canada. Regular commercial air service is not 

available in any other town in the BiFO planning area. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

3-230 Chapter 3: Affected Environment

3.24.2State and County Roads 

There are six state highways located in the planning area. Over the past decade the Montana 

Department of Transportation has upgraded several of these highways, as shown in Table 3-68. 

Table 3-68 State Highway Conditions in the Planning Area 

Highway Upgraded

Highway 87 from Billings to Roundup Yes

Highway 310 to Bridger and Warren Yes, to the Wyoming state line

Highway 78 to Absarokee Yes

Highway 212 No

Highway 12 from Melstone to Harlowton No

Highway 72 Belfry South Yes

Highway 72 Belfry North Pending 2010 contract letting

Highway 310 from Bridger to the Wyoming State Line In progress

Note: 

Source: BLM 1984 

The planning area is connected by a network of county roads. County roads vary from a 30 foot 

graveled running surface with regular maintenance to native surface roads with a 10 foot 

running surface and minimal maintenance. State and county system roads (depending on road 

class) are usually constructed and maintained to higher standards than BLM roads and provide 

the primary arterial collector road systems for access to and through BLM lands. These state 

and county system roads are not maintained by the BLM. 

3.24.3BLM Roads 

There are 216 miles of BLM roads exist in the BiFO decision area, as shown in Table 3-69. 

BLM roads provide public, agency, and permittee access to and through public lands. 

Reasonable administrative access is made available to persons engaged in valid uses such as 

mining claims, mineral leases, livestock grazing, and recreation. Most BLM road usage is 

defined as casual. 

BLM conducts trails and travel management planning to identify areas where foot, mechanized, 

and motorized vehicle travel is appropriate, restricted, or not allowed. For comprehensive travel 

management information, refer to Section 3.21.

FAMS now shows: 

 Roads – 201 miles 

 Primitive roads – 14 miles

 Administrative sites – 8 

 Recreation sites – 10

 Bridges – 2 

 Dams – 5
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-231

Table 3-69 Roads in the Decision Area 

Segment Name Segment

Length (Miles)

Primitive Road

(Yes/No)

00301 – Acton Road 3.6 N

00301 – Acton Road 3.8 Y

00302 – Shepherd Road 0.2 N

01001 – Cottonwood Road 20.4 N

01002 – Hatcher Pass 2.5 N

01003 – Bobcat Pass 4.6 N

01004 – Hunt Creek Road 4.2 Y

01005 – Cub Creek Road 9.88 N

01006 – Long Draw Road 7.25 Y

01008 – East Basin Road 5.85 Y

01009 – Goblers Knob Road 3.85 Y

01010 – Williams Draw Road 6.05 Y

01010 – Williams Draw Spur Road 2.15 Y

01011 – Hollenbeck Draw Road 7.4 N

01013 – Stockman Trail Road 2.05 Y

01014 – Bear Canyon Road 8.2 N

01015 – Gyp Springs Road 7.6 N

01016 – Helt Road 13.55 N

01017 – Crooked Creek Road 6.6 N

01018 – Burnt Timber Ridge Road 1.2 N

01018 – Burnt Timber Ridge Road 6.9 N

01019 – Sykes Ridge Road 17.25 N

01021 – Horse Haven Road 6.5 Y

01022 – Red Pryor Road 3.0 N

02301 – Asparagus Point Road 0.5 N

1043 – Sand Springs Road 2.0 Y

1044 – Williams Draw Spur Road 1.5 Y

1038 – Cub Creek/Long Draw Ridge Road 4 Y

1037 – Cub Creek Loop Road 2.5 Y

1042 – Jones Reservoir Road 0.75 Y

1041 – Bear Canyon Spur Road 0.5 Y

1031 – Bear Canyon Ridge Road 1.0 Y
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

3-232 Chapter 3: Affected Environment

Segment Name Segment

Length (Miles)

Primitive Road

(Yes/No)

1032 – Bear Canyon Ridge Spur Road 0.75 Y

1030 – East Horse Haven Road 1.25 Y

1034 – Dandy Mine Road 2 Y

1035 – Demijohn Flat Road 2.75 Y

1036 – West Petroglyph Canyon Road 1.5 Y

1040 – East Petroglyph Canyon Road 1.0 Y

1033 – Sykes Ridge Loop East Road 2.0 Y

2301 – Asparagus Point 0.5 Y

2302 – Steamboat Butte Road 2.5 Y

0304 – Shepard Road Spur 0.09 Y

0305 – Four Dances Road 0.1 Y

0306 – South Hills Parking Area Road 0.01 Y

0307 – Sundance Lodge Road 0.05 Y

1045 – Robertson Draw Road 8.0 Y

1039 – Bent Springs Road 2.5 Y

1046 – Miller Trail Road 3.0 Y

1047 – Timber Ridge Road 2.0 Y

1048 – Lower Timber Ridge Road 0.75 Y

1049 – Timber Canyon Road 1.5 Y

1050 – Inferno Canyon Road 1.5 Y

 – Water Canyon Road 1.0 Y

2305 – North Willow Creek Road 9.5 Y

0310 – Acton Spur, W Road 2.0 N

0311 – Acton Spur, NE Road 0.75 N

0312 – Acton Spur, SE Road 1.75 N

TOTAL 216.08

Note:

Source = AMS 

3.24.4Road System Maintenance 

BLM maintains its roads under standards set forth in BLM 9100 Manual to protect resources, 

accommodate users, and maintain its investment. Road system maintenance has focused on 

maintaining major recreational access roads, which generally receive most of the traffic 

volume. The BiFO maintains on an average about 118 miles of roads and 98 miles of primitive 

roads in the decision area, depending on road conditions and funding availability. Road 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-233

maintenance generally consists of blading or grading and is usually performed in the summer or 

fall. Additional corrective maintenance or water drainage work (installation of culverts, drains, 

or other water management devices) is performed as needed, such as after periods of heavy 

rainfall. There is no snow removal on BLM roads. Gates and cattle guards on the road system 

are constructed and maintained using available funds from multiple programs. 

3.24.5Facilities 

Facilities for administrative purposes facilitate land management responsibilities at several 

locations within the decision area. All facilities/sites are maintained and upgraded as needed to 

achieve management objectives for safety, resource protection, and quality recreational 

experiences. Facilities found to not meet agency needs or which are contributing to resource 

impacts, are considered for redesign, relocation, closure, or decommission to minimize adverse 

impacts or conserve funding. Existing facilities are inspected on an established schedule in 

accordance with the Bureau’s Condition Assessment guidance. 

The BLM BiFO currently has five developed administrative sites for BiFO staff to store 

equipment, supplies, and to prepare to work on field oriented tasks. These administrative sites 

include: 

 The Billings Fire Dispatch Center (located at the Billings Airport). This site 

includes a complex of full service buildings housing year round and seasonal 

field office fire program staff; dispatch center with technical communications 

equipment; fire fighting vehicles, warehouses, and equipment. The site also 

serves as a regional service, operations, training, and support center for 

interagency operations. The BLM leases the land at this site. 

 The Pompeys Pillar Administrative Site. This site is located at the Pompeys 

Pillar National Monument (the administrative site excludes the Pompeys Pillar 

Interpretive Center and the associated recreational facilities (e.g., trails, parking 

lots, etc.). The site provides support for Pompeys Pillar National Monument 

operation and for some of the nearby public lands outside of the Monument. 

There are several buildings which include a warehouse, pump house, and a 

water treatment system. The BiFO staff uses the buildings for storage, operation, 

and repair of equipment, construction tasks, and maintenance of the recreation 

facilities. 

 The Britton Springs Administrative Site. This site is located on public lands 

at the south end of the Pryor Mountains and is adjacent to the Pryor Mountain 

WSA and Pryor Mountain Wild Horse Range. The site consists of corrals, a 

building for temporary quarters, several outbuildings for storage of feed and 

supplies. It is mostly used only as a base for temporary operations associated 

with the local area, which is both remote and at the far end of the field office. 

 The Four Dances Natural Area ACEC Administrative Site. This site is 

located on public lands at the Four Dances Natural Area in Billings, and 

includes a small parking pad with overhead pavilion and includes culinary water 

and septic. It is used seasonally and provides housing and a contact station for a 
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small staff for local recreational operations. It is a cooperative management site 

with a non-federal agency partner. 

 The Sundance Lodge Administration Site. This site is located on public lands 

in the community of Laurel and is adjacent to the BiFO Sundance Lodge 

Recreation Area. The site consists of a storage yard for large supplies and 

equipment, a warehouse and work shop. It is used as the principle work and 

storage site for the BiFO staff for non-fire purposes and has year-round access. 

In the future, new facilities determined to be necessary for permanent, short- or long-term use 

as part of the Agency mission would be constructed subject to NEPA and approved engineering 

standards. Consideration would be given to use demands, location, safety, funding, and 

resource constraints when determining the type of facility necessary. 

3.25 Special Designations 

This section provides information on the current condition of special designations that could be 

affected by the revised RMP alternatives described in Chapter 2. Special designations discussed 

in this RMP include: 

 Pompeys Pillar 

► National Monument 

► National Historic Landmark 

► Area of Critical Environmental Concern 

 Areas of Critical Environmental Concern (ACECs) 

► Bridger Fossil Area ACEC 

► Castle Butte ACEC 

► East Pryor ACEC 

► Four Dances Natural Area ACEC 

► Meeteetse Spires ACEC 

► Petroglyph Canyon ACEC 

► Stark Site ACEC 

► Weatherman Draw ACEC 

 Wilderness Study Areas 

 Wild and Scenic Rivers 

 Pryor Mountain Wild Horse Range 

 National Historic Trails 

3.26 Pompeys Pillar 

Pompeys Pillar is an area of critical environmental concern (ACEC), a National Monument 

(NM), as well as a National Historic Landmark (NHL), and is an identified Lewis and Clark 

National Historic Trail high potential historic site and a high potential route segment. The 
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exceptional qualities Pompeys Pillar possesses and an explanation of management processes is 

described below. The L&CNHT section adjacent to Pompeys Pillar NM is addressed in more 

detail in Section 3.31 – National Historic Trails of this document. 

3.26.1General Overview 

Pompeys Pillar is a massive sandstone outcrop that rises approximately 127 feet on the banks 

of the Yellowstone River, approximately 30 miles east of Billings. The monument’s premier 

location at a natural ford in the Yellowstone River, and its geologic distinction as the only 

major sandstone formation in the area, have made Pompeys Pillar a celebrated landmark and 

outstanding observation point for more than 11,000 years of human occupation. Hundreds of 

markings, petroglyphs, and inscriptions left by visitors have transformed this geologic 

phenomenon-into a living journal of the American West. 

On January 17, 2001, Pompeys Pillar was designated a national monument under the authority 

of Section 2 of the Antiquities Act. Fifty-one acres of federally owned land were set apart and 

reserved as Pompeys Pillar National Monument for the purpose of protecting the ethnographic, 

historic, and archaeological values associated with the massive sandstone outcrop known as 

Pompeys Pillar. 

Prior to being designated a National Monument, Pompeys Pillar was officially designated a 

National Historic Landmark (NHL) in 1965. In 1991, the BLM acquired the NHL and adjacent 

land, totaling 366 acres. The total area currently being managed as Pompeys Pillar is 474 

acres; the additional 107 acres being an adjacent island in the Yellowstone River that is also 

under BLM administration. 

Ownership of the mineral estate has not been established due to the complexities arising from 

the multiple ownerships previous to BLM acquisition. To the extent that the federal 

government owns the minerals at Pompeys Pillar National Monument, they are withdrawn 

through the Presidential Proclamation signed January 17, 2001. 

3.26.2National Monument 

Approximately 51 acres at Pompeys Pillar was designated a National Monument (NM) by 

executive proclamation of the President (Appendix W) in January 2001 for the purpose of 

protecting the historic and cultural objects described below. This was accomplished through 

Section 2 of the Antiquities Act of June 8, 1906 (34 Stat. 225, 16 U.S.C. 431). Section 2 states, 

“The President of the United States is authorized, in his discretion, to declare by 

public proclamation historic landmarks, historic and prehistoric structures, and 

other objects of historic or scientific interest that are situated upon the lands 

owned or controlled by the Government of the United States to be national 

monuments, and may reserve as a part thereof parcels of land, the limits of which 

in all cases shall be confined to the smallest area compatible with proper care 

and management of the objects to be protected. When such objects are situated 

upon a tract covered by a bona fide unperfected claim or held in private 

ownership, the tract, or so much thereof as may be necessary for the proper care 

and management of the object, may be relinquished to the Government, and the 
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Secretary of the Interior is hereby authorized to accept the relinquishment of such 

tracts in [sic] behalf of the Government of the United States.”

Ethnographic and archaeological evidence indicates that Pompeys Pillar was a place of ritual 

and religious activity. Hundreds of petroglyphs on the face of the rock, noted by Clark in his 

journal, reflect the importance of the site to early peoples. The Crow people, dominant 

residents of the region when Clark passed through, refer to Pompeys Pillar in their language as 

the “Mountain Lions Lodge,” and it figures prominently in Crow oral history. Pompeys Pillar 

also includes the markings and signature of a host of characters from the pioneer past, including 

fur trappers, Yellowstone River steamboat men, frontier army troops, railroad workers, 

missionaries, and early settlers. In 1873, Lieutenant Colonel George Armstrong Custer and his 

men camped at its base, where they came under attack by Sioux warriors. 

3.26.3National Historic Landmark 

National Historic Landmarks (NHL) are nationally significant historic places designated by the 

Secretary of the Interior because they possess exceptional value or quality in illustrating or 

interpreting the heritage of the United States. In 1965, Pompeys Pillar was officially designated 

a NHL primarily because of the significance of William Clark’s signature panel. The boundary 

includes approximately 6 acres above the 2,890 foot contour level. In 1983, the same site was 

listed on the National Register of Historic Places (NRHP) as a significant cultural property 

(Appendix W). A significant cultural property is a property or a place that is eligible for 

inclusion on the NRHP because of its association with cultural practices and beliefs that are 

rooted in the history of a community and are important to maintaining the continuity of that 

community’s traditional beliefs and practices. Pompeys Pillar fulfills both of these descriptions 

for multiple Native American populations. The Pompeys Pillar NHL is located entirely within 

the Pompeys Pillar NM boundary. 

3.26.4Area of Critical Environmental Concern 

The BLM designated Pompeys Pillar an ACEC in 1996 to protect its cultural and historic 

resource values. Pompeys Pillar served as an important landmark and traveler register during 

the exploration and fur trade period and is an important physical reminder of the nineteenth 

century’s westward movement of Euro-American culture. 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. Pompeys Pillar ACEC (432 acres) includes Pompeys Pillar NM 

(51 acres), designated in 2001, and Pompeys Pillar NHL (six acres) designated in 1965. Table 

3-70 provides a summary of special designations at Pompeys Pillar. 
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Chapter 3: Affected Environment 3-237

Table 3-70 Pompeys Pillar Designations and Rationales 

Designation Acreage Rationale for Designation

National Monument (NM) 51 Cultural and historic values

National Historic Landmark (NHL) 6 +/- Cultural and historic values

Area of Critical Environmental Concern (ACEC) 432 Cultural and historic values

Three management zones were delineated as part of the Pompeys Pillar ACEC designation to 

achieve various management objectives, based on ensuring the historic setting and enhancing 

the visitors’ experience: the Historic Zone (90 acres), Historic Zone – Developed (110 acres), 

and General Management Zone (270 acres). 

The RMP planning area for Pompeys Pillar encompasses about 432 acres. Map 170 – Pompeys 

Pillar Management Zones identifies the various designations and management zones at 

Pompeys Pillar. Based on public involvement and the environmental setting, Pompeys Pillar 

was divided into three distinct separate management zones. A brief description of the 

management zones, character/setting of each zone, and the types of infrastructure currently 

available and/or allowed in each zone is below. 

3.26.4.1 Historic Zone 

Management objectives of this 29-acre zone are to provide visitor access to Clark’s signature 

and other historic inscriptions and rock art and enhance the visitors’ experience through 

providing landscapes that appear similar to the natural setting Clark viewed in 1806. Landscape 

modifications would be the minimum necessary for visitor safety and protection of the 

signature and other rock art. Current facilities in the Historic Zone include a picnic area, 

sidewalks, contact station, boardwalk to Clark’s signature and to the top of the pillar, concrete 

trail with interpretive signage, gravel entrance road and parking area, electronic surveillance 

equipment, and vault toilets. 

3.26.4.2 Historic Zone - Developed 

Management objectives of this 54 acre zone are to provide an area where most facilities would 

be placed. Facilities in this zone are designed to enhance visitor experiences through 

interpretation and visitor services. Current facilities include an interpretive center; outdoor 

amphitheater; paved parking, entrance road and drop off loop; picnic area; and interpretive 

displays. 

3.26.4.3 General Management Zone

Management objectives of this 349 acre zone are to improve and/or maintain wildlife habitat 

condition, enhance dispersed recreation opportunities, and utilize agriculture to further general 

management. These include weed control, soil stabilization, and provision of a food source for 

wildlife. A Cooperative Habitat Agreement between Montana Fish, Wildlife, and Parks, 

Pheasants Forever, and the BLM Billings Field Office exists in the General Management Zone 

with the objective of improving habitat for introduced species such as ring-necked pheasants, 

Merriam’s turkey, and other wildlife. 
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3.26.5Current Land Usage at Pompeys Pillar National Historic 

Landmark and National Monument 

Current uses at Pompeys Pillar mainly focus on the historic/cultural recreational experiences 

for visitors. Pompeys Pillar is used extensively for education by regional schools. Pompeys 

Pillar is located adjacent to an interstate highway and, as a result, continued and possibly 

increased use by motorists traveling through the region may occur. The interpretive trail 

system, outdoor amphitheater, and scenic views offer outstanding opportunities for both local 

and non-resident visitors. 

Pompeys Pillar ACEC also offers exceptional recreational activities, including hunting, in the 

general management zone. Wildlife viewing, photography, and dispersed recreational 

opportunities (i.e. hunting) are among the most frequently-used visitor uses. There are few 

public land opportunities along the Yellowstone River with good physical and legal access. The 

recent acquisition of the Yellowstone Wildlife Management Area and Yellowstone River State 

Park by MTFWP, across the river, also provides outstanding recreational opportunities. It is 

likely that the recreational use at Pompeys Pillar ACEC will increase. Access for motorized and 

non-motorized boating opportunities will likely be a publicly-driven demand as river use 

increases. Lands surrounding and/or adjacent to the Pompeys Pillar planning area are 

important to preserving the historic and cultural viewshed.

3.27 Areas of Critical Environmental Concern 

The ACEC designation is an administrative designation used by the BLM that is accomplished 

through the land use planning process. It is unique to the BLM in that no other agency uses this 

form of designation. The Federal Land Policy and Management Act states that the BLM will

give priority to the designation and protection of ACECs during the development and revision 

of land use plans. 

BLM regulations (Title 43 Code of Federal Regulations Subpart 1610) define an ACEC as an 

area “within the public lands where special management attention is required (when such areas 

are developed or used or where no development is required) to protect and prevent irreparable 

damage to important historic, cultural, or scenic values, fish and wildlife resources, or other 

natural systems or processes, or to protect life and safety from natural hazards.” Private lands 

and lands administered by other agencies are not included in the boundaries of ACECs. ACECs 

differ from other special management designations (e.g., wilderness study areas) in that 

designation by itself does not automatically prohibit or restrict other uses. In order to be 

designated, special management beyond standard provisions established by the plan must be 

required to protect the relevant and important values. Further information about these criteria is 

presented in Appendix E. 

3.27.1National Natural Landmark 

A National Natural Landmark (NNL) is a nationally significant natural area designated by the 

Secretary of the Interior. To be nationally significant, a site must be one of the best examples of 

a biotic community or geologic feature in its natural region. Examples of this natural diversity 
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include terrestrial and aquatic ecosystems, features, exposures, and landforms that record active 

geologic processes as well as fossil evidence of biological evolution. 

There are two National Natural Landmarks on BLM managed public land within the BiFO 

decision area, Bridger Fossil Area NNL and Crooked Creek NNL (located in Wyoming). 

3.27.2Laws, Regulations and Policies 

Section 202(c)(3) of the FLPMA mandates the BLM give priority to the designation and 

protection of ACECs in the development and revision of land use plans. BLM Manual 1613 

describes the process to nominate ACECs and screen areas for their suitability or ACEC 

designation. The BLM’s planning regulations (43 CFR 1610.7-2) establish the process and 

procedural requirements for designating ACECs in RMPs and RMP amendments. 

3.27.3Existing ACECs 

Currently nine ACECs exist in the planning area, including Pompeys Pillar (Section 3.4.2 –

Pompeys Pillar) for a total of 37,896 acres. A summary of all the ACECs and the values they 

protect is in Table 3-71, and more detailed information for each ACEC is provided below. The 

values for which these ACECs were designated are still present and require continued 

management attention (Map 159). 

Table 3-71 ACECs in the Planning Area 

ACEC Year Designated BLM Public Land 

(in acres) Values

Bridger Fossil Area 1999 577 Paleontology

Castle Butte 1999 184 Cultural resources

East Pryor Mountains 1999 29,550 Scenic, geologic, Wild horses, wildlife habitat, 

cultural, paleontological, vegetation

Four Dances Natural 

Area 2002 784 Cultural and historic resources, scenery, natural hazards 

Meeteetse Spires 1999 965 Vegetation, scenery

Petroglyph Canyon 1999 240 Cultural resources

Pompeys Pillar* 1996 432 Cultural and historic resources (1, 2, and 3)

Stark Site 1999 799 Cultural resources

Weatherman Draw 1999 4,365 Cultural resources

Total 9 ACECs 37,896

Note: 

*Addressed in Special Designations Section 

Source: BLM ACEC amendment 1999 

http://www.blm.gov/style/medialib/blm/mt/blm_programs/planning/billings_rmp/amendments.Par.94086.File.dat/acecEA.pdf 
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3.27.3.1 Bridger Fossil Area ACEC 

Bridger Fossil Area was designated in 1999 primarily to protect the paleontological values of 

the area. The area consists of three separate tracts, one with public access. The Bridger Fossil 

National Natural Landmark (161 acres), designated in 1973, is located entirely within the 

Bridger Fossil Area ACEC. The entire NNL (161 acres) has been withdrawn from mineral 

entry. Located in Carbon County, Montana, the area includes the fossil remains of 

Deinonychus antirrhopus, a highly predaceous carnivorous dinosaur from the Cretaceous 

Cloverly Formation. Interpretation of the anatomy and habits of this creature led to ideas about 

the warm-bloodedness of dinosaurs, and possible close relationship to modern birds. A bone 

bed in the Jurassic Morrison Formation contains the remains of numerous juvenile and subadult 

sauropods. The Museum of the Rockeis, Montana State University and the Cincinnati Museum 

Center - Geier Collections and Research Center (Vertebrate Paleontology) have both conducted 

long term studies at this site. The area is also used extensively for the collection of invertebrate 

fossils and as an outdoor classroom. 

Exposures of the Late Jurassic Morrison and Early Cretaceous Cloverly Formations in this area 

have yielded fossils of rare dinosaur taxa. While fossil localities dating to this time period exist 

elsewhere, the quality, concentration, and kinds of fossils present on public lands in the Bridger 

Fossil Area can provide an outstanding record of the environment and a glimpse of terrestrial 

life during those periods. 

In addition, the area includes the most fossiliferous exposures of the Cloverly Formation in 

northern Wyoming and southern Montana. Deinonychus and Tenontosaurus, rare dinosaur 

species have been documented here, as well as an extremely rare concentration of dinosaur egg 

and embryonic remains. These specimens may hold the answer to central questions in dinosaur 

research, regarding dinosaur physiology and behavior. 

To conserve the Bridger Fossil Area ACEC for future scientific study, the area is managed 

according to the following management prescriptions (1999). Livestock grazing is allowed, 

while ROWs, mineral material sales and permits, and O&G leasing are not allowed. 

Underground explosives for geophysical exploration for O&G are not allowed. Other 

geophysical exploration methods for O&G are allowed if the method does not damage the 

paleontology resource. If monitoring indicates fossil damage as a result of a geophysical 

activity, it will no longer be allowed. Off-road vehicle use is limited to designated roads and 

trails. Noncommercial collection of common invertebrate and plant fossils is allowed. The area 

is managed per VRM Class IV objectives. 

3.27.3.2 Castle Butte ACEC

Castle Butte in Yellowstone County is a remarkable topographic feature. The butte is composed 

of relatively soft, friable, bedded sandstones of the upper Cretaceous Hell Creek Formation. 

Paleontological resources, including paleobotanical fossils, are found in the area as well. 

Castle Butte is a remarkable topographic feature with access from an adjacent county road and 

is locally well known. It has been known to Euro-Americans since the late 19th Century. Site 

24YL0418 at Castle Butte is eligible for the National Register of Historic Places. 
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The BLM acquired the 105 acres containing Castle Butte in 1974 as part of a land exchange. 

However, in this exchange, the BLM only acquired the surface state, the mineral estate remains 

private. 

Castle Butte was designated as an ACEC in 1999 due to its cultural values, such as rock art. 

The ACEC consists of three sites: 24YL0418: 160 rock art panels (77 prehistoric and 83 

historic graffiti); 24YL0759: a bison kill processing area and occupation site; and 24YL0760: 

a multi-component open occupation site. All of the rock art panels are actively weathering to 

some degree, and in several instances, elements in the panels can no longer be seen. Some 

panels are threatened by large blocks that periodically drop from the face of the cliffs as erosion 

of the butte progresses, the most recent occurring in 2012. Blocks of the sandstone butte 

located on the north side of Castle Butte dropped during spring 2012. These blocks contained 

both pictographs and petroglyphs (panels 92, 93, 94, 95, and 96). 

With the aim of documenting the rock art, the University of North Dakota and Minot State 

University conducted an intensive inventory of the rock art panels in 1991 (site 24YL0418). 

The University of Washington excavated portions of site 24YL0759 in 1989 and 1990. 

Association of rock art motifs on the butte with specific ethnic groups still present in the 

northern plains suggests it may be considered a significant site to contemporary Native 

Americans in addition to its research value. Because of their excellent preservation and well as 

the large numbers of individual rock art panels, Castle Butte will continue to be important in 

investigations into the ethnohistory of the Northern Plains. 

Castle Butte is one of the premier rock art sites of the Northwestern Plains. Information from 

the site has been used by a number of prominent rock art investigators in constructing and 

debating an understanding of the sequence of regional rock art styles in use on the 

Northwestern Plains and elsewhere in the High Plains from Alberta to Texas, particularly for 

the early historic period. The quality, quantity, and concentration of rock art, as well as the 

potential for relative and absolute dating, make this site more than locally significant. 

Information on this site has been widely published in professional journals and monographs. 

To conserve the exceptional rock art for future generations to study and enjoy, the area is 

managed according to the following management prescriptions (1999). Livestock grazing and 

range improvements are allowed. Fire is managed with conditional fire suppression. Wood 

product sales are not allowed. Geophysical exploration for O&G is not allowed on the 

significant cultural resource sites. Geophysical exploration is allowed (surface methods and 

vibroseis) in the remainder of the area. The mineral estate at Castle Butte ACEC is privately 

owned. Additionally, ROWs are allowed when they avoid the significant cultural resource 

sites. Off-road vehicle use is limited to designated roads and trails. The area is managed per 

VRM Class III objectives. 

3.27.3.3 East Pryor Mountain ACEC

This area, located in Carbon County, Montana and Big Horn County, Wyoming, contains 

several important areas/designations within and overlapping the ACEC boundary: the Pryor 

Mountain Wild Horse Range; the Burnt Timber Canyon, Pryor Mountain, and Big Horn TackOn WSAs; the Crooked Creek Natural Area (2,101 acres); and the Crooked Creek Natural Area 
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National Natural Landmark (300 acres), designated in 1966. The Crooked Creek Natural Area 

and the Crooked Creek NNL are located entirely within the East Pryor ACEC. The ACEC, 

designated in 1999, has many diverse habitat types and associated wildlife species. The area is 

rich with paleontological and cultural resources, including early Cretaceous land vertebrates 

(one of only two localities in North America) in the lower elevations of the ACEC and Native 

American vision quest sites in the higher elevations of the ACEC. Although vegetation was not 

one of the characteristics for which the East Pryor Mountain ACEC was designated, sites of 

several BLM sensitive plants occur in the ACEC. 

In 1966, when the Crooked Creek NNL was designated, the area was known as one of only two 

localities in North America which had produced early Cretaceous land vertebrates. Important 

primary finds of early Cretaceous dinosaur specimens were made here by paleontologists from 

Princeton University in the late 1940s and by workers from Yale University in the 1960s. 

Fauna first identified at the Crooked Creek NNL include a primitive hadrosaur, a small and 

large carnivorous dinosaur, a sauropod, an ankylosaur, and an ornithopod dinosaur. The 

primitive hadrosaur and the small of the two carnivores were recovered as essentially complete 

skeletons. These fossil bearing Cretaceous deposits are the type-site for eight species and ghree 

genera of early Cretaceous dinosaurs. 

The Burnt Timber Canyon, Pryor Mountain, and Big Horn Tack-On Wilderness Study Areas 

(WSAs) were recommended for wilderness designation in the Montana Statewide Wilderness 

Study Report, Volume II (BLM, 1991). 

The Pryor Mountain Wild Horse Range (PMWHR) encompasses the majority of the three 

WSAs. The wild horse range is located in the southeastern portion of Carbon County, Montana 

and extents into the northern portion of Big Horn County, Wyoming. The range is bordered on 

the north and west by the Custer National Forest, on the south by private lands, and on the east 

by Big Horn Canyon National Recreation Area. The PMWHR was created by order of the 

Secretary of the Interior on September 9, 1968. 

The area has many diverse habitat types and associated species of wildlife coexisting with a 

herd of wild horses. The primary big game species are mule deer, Rocky Mountain bighorn 

sheep, and black bear. Upland game birds include blue grouse and pheasant. Three species of 

bats occur within the East Pryor ACEC: Townsends’ Big-Eared Bat, Pallid Bat, and Spotted 

Bat. The area contains caves that provide summer and winder habitat for bats 

Crooked Creek is the only active fishery in the area supporting species of brook, rainbow, and 

cutthroat trout. Yellowstone Cutthroat trout may be isolated in the upper portions, representing 

a pure genetic strain with high intrinsic value. 

To conserve the area for wild horse and paleontological values, provide recreational use and 

enhance fish and wildlife habitat, the East Pryor ACEC is managed according to the following 

management prescriptions (1999). Fire is managed with conditional fire suppression. Wood 

product sales, ROWs, livestock grazing and geophysical exploration for O&G are not allowed. 

Off-road vehicle use is limited to the designated vehicle ways. Locatable minerals are 

withdrawn from entry. Mineral material sales and permits, and O&G leasing are not allowed. 

Noncommercial collection of common invertebrate and plant fossils are allowed. The area is 

managed per VRM Class II objectives. 
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3.27.3.4 Four Dances Natural Area ACEC 

Four Dances Natural Area ACEC, designated in 2002, is located two miles east of downtown 

Billings and is bordered on the east by Coburn Road and on the west by the Yellowstone River. 

The BLM acquired this property in 1999. When the BLM acquired this property, the 

Yellowstone River Parks Association nominated the area as an ACEC. 

The location of Four Dances Natural Area ACEC marks the downstream end of the Coulson 

Bottom plain. The high sheer sandstone cliffs that form the western edges of Four Dances 

Natural Area ACEC are also a notable landmark in the Yellowstone Valley. Numerous 

references to the area exist in both Crow and Hidatsa oral literature. 

The aboriginal Crow name for the cliffs is “Annishshisoopash”, translated as “Place of Four 

Dances”. The cliff is traditionally recognized as a fasting site used by Four Dances, a 

prominent Crow warrior in the 1830s, during the heyday of the Rocky Mountain fur trade and 

the intertribal Plains wars. Four Dances took his name from the vision he received while 

fasting at this place. Four Dances’ name refers to the dancers who appeared to him in four 

different places during his vision. Four Dances went from his fasting place to achieve a great 

Crow victory over the Lakota. Crows visited Four Dances’ fasting place until about the turn of 

the century. 

The majority of the property is a plateau 200-500 feet above the Yellowstone River, which 

command views of many important traditional Crow sites and offers great potential for 

interpretation of many historical and aboriginal sites. The lower end of Coulson Bottoms was 

favored for Crow camps in the eighteenth and nineteenth centuries. Major fords crossing the 

Yellowstone and an important pass to the uplands north of the valley were both located here. 

The pass to the north was documented by Lieutenant James Bradley in 1876, when he passed 

through with Crow scouts on the way to discover the defeated Custer troops at Little Bighorn. 

In the twentieth century, internationally known cowboy artist and author, Will James 

periodically worked on the Snook Ranch which included the Four Dances property. Will James 

used a small cabin overlooking the Yellowstone Valley as a retreat. This cabin remains intact 

on the Four Dances Natural Area ACEC and appears much as it did in James’ time. James was 

instrumental in perpetuating the myth of the American West and the image of the cowboy as 

the quintessential American character. The best known of James’ works includes Smoky the 

Cowhorse (1926). Smoky the Cowhorse won the Newbery Medal for children’s literature in 

1927 and the Lewis Carroll Shelf Award in 1965. 

The Four Dances Natural Area ACEC is directly across the river from Coulson City, a late 

nineteenth century steamboat landing and the precursor to Billings. Coulson City was built just 

across the river from what was then the Crow Reservation (the reservation boundary was 

adjusted to the east in 1891). A segment of the historic Meeteetse to Billings stage and freight 

road also appears to have crossed the northeast corner of the Four Dances Natural Area ACEC. 

The cliffs on the Four Dances site were also noted by William Clark when he floated past in 

1806. His manuscript maps refer to them as “Yellow Cliffs”. A few days later Sergeant Pryor 

and his party crossed the Yellowstone with the expedition’s horse herd just below the cliffs. 
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To the extent that the BLM owns the mineral estate at Four Dances Natural Area ACEC a 

regulatory withdrawal on the mineral estate is in place on the 784 acres. The current 

management of Four Dances Natural Area ACEC consists of the following (2002). It is an 

avoidance area for land use authorizations (ROWs). Uses and practices would be consistent 

with the Deed of Conservation Easement. A restricted quantity of ROWs, temporary use 

permits and land use authorizations are available if the actions are consistent with the ACEC 

objectives. Land Tenure: No land sales, R&PPs, conveyances or long term leases for 

habitation or industrial use. Off-Highway vehicle use: OHV use (including bicycles) limited 

to administrative or authorized use only. No snowmobiles and no off-road vehicle use. Visual 

Resource Management: Class III. It is closed to oil and gas leasing, exploration, and 

development, withdrawn from locatable mineral and solid leasable mineral development, and 

mineral material sales are not allowed. Fire Suppression: Appropriate management response 

to wildfire would be aggressive fire suppression; including use of natural barriers and hand 

constructed fire lines; use of bulldozers and retardant avoided unless approved by authorized 

officer. Fuels Management: Prescribed fire would be used to reduce hazardous fuels and meet 

other resource objectives. Allowed only during favorable smoke dispersal conditions with 

stable atmospheric conditions. Fuel wood cutting/wood product sales: wood product sales 

permits would not be issued. Commercial timber harvest not allowed. Timber management for 

the safety and enhancement of other values would be practiced in the woody draws, on the 

islands, and along the Yellowstone River bottom. Livestock Grazing: Only authorized to meet 

other resource objectives consistent with ACEC designation. Grazing must meet Standards and 

Guidelines. Buffalo grazing is not permitted. Noxious/Invasive weed treatments: Treatments 

may include any combination of herbicide application, burning, grazing and the use of insects 

or pathogens. The use of chemicals would be minimized. Hunting/target shooting: No 

discharging of firearms. Archery hunting may be allowed if deemed necessary by MTFWP 

(authorization from BLM required). Special Recreation Permits: Authorizations would be 

required or timing and locations would be specified for events such as cross country races. 

Some limitations on use by the general public may be required to facilitate Native American 

religious activities. These would be limited to specific time periods and specific portions of the 

property. Recreation: Day use area only. Closed to horseback riding, use of fireworks, hang 

gliding, rock climbing, paint ball, discharging of firearms, and exercising pets off leash. 

Wildlife: Special management and priority would be given to protecting falcon eyries by 

restricting human activity along the rims that might adversely affect the nesting birds. NonACEC values may be adjusted as necessary. (Map 85 – Four Dances Natural Area 

ACEC/SRMA) 

3.27.3.5 Meeteetse Spires ACEC 

Meeteetse Spires ACEC, designated in 1999, is located in Carbon County, Montana, at the base 

of the eastern slopes of the Beartooth Mountains. The Meeteetse Spires are in the rain-shadow 

of the Beartooth Mountains and exhibit an extremely abrupt change in annual precipitation 

from nearly 26 inches on the western boundary to six inches in the east (Lesica, 1998). The 

terrain slopes steeply, dropping from 7,200 feet to5,600 feet. The spires are formed by a tilted 

layer of sedimentary rocks at the edge of the Beartooth Uplift and are remnants of upturned 

Madison limestone. 
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Meetseetse Spires ACEC is in the vicinity of recreation areas near Red Lodge. Hikers, 

climbers, and sightseers use the area during the spring and summer. In the fall, hunters use the 

Meeteetse Spires ACEC intensively. 

Meeteetse Spires was dedicated as a Centennial Preserve on October 7, 1989, through the 

efforts of The Nature Conservancy and the BLM. The Preserve was created to protect the 

spectacular scenery and natural beauty of the Spires and the ecological habitat for two rare 

plant species. The area is drained by nearly a dozen perennial and intermittent streams which 

flow eastward from the mountain front to form the Grove Creek and Wolf Creek drainages. 

Variations in moisture have affected soil development which determines the plant communities 

in the area. Shoshonea pulvinata and Townsendia spathulata, occur at higher eleveations. A 

rare plant species, Shoshonea pulvinata is known in only three location in Montana and fewer 

than 12 locations globally (Lesica, 1998). It is a candidate for listing as a federal endangered 

species. Townsendia was considered rare in Montana, but in the 1993 Pryors Botanical Study 

conducted by the Montana Natural Heritage Program indicated that Townsendia was widely 

distributed throughout the Pryor Mountains and did not warrant sensitive listing. It is also 

found in two western Montana counties (Beaverhead and Broadwater) and in Wyoming. (Map 

171 -- Meeteetse Spires ACEC). 

To protect and enhance the rare plant Shoshonea pulvinata and conserve this scenic area for 

recreational use, the area is managed according to the following management prescriptions 

(1999). An easement across state land (T. 8 S., R. 20 E., Section 36) has been obtained. Fire is 

managed with conditional fire suppression. Selected timber harvests may be periodically 

necessary to protect the area’s overall resource value. Livestock grazing, except for sheep, is 

allowed. Wood product sales, ROWS, O&G leasing, and mineral material sales and permits are 

not allowed. Locatable minerals will be withdrawn from entry. In the sensitive plant area, 

geophysical exploration for O&G is not allowed by any method. On the remaining area, 

geophysical exploration is accessed by air only. Exploration is shot holes and above-ground 

shots. Vibroseis is allowed. Off-road vehicle use is limited to designated roads and trails, 

yearlong, in the entire area. The area is managed per VRM Class II objectives. 

3.27.3.6 Petroglyph Canyon ACEC

Petroglyph Canyon ACEC is in southern Carbon County, Montana, along the 

Montana/Wyoming stateline. It is a late prehistoric rock site (24CB0601) listed on the 

National Register of Historic Places on November 20, 1975. The site consists of 38 panels of 

petroglyphs and represents the northernmost extension of an art style not commonly found in 

Montana. Human figures dominate the artwork. Materials recovered in excavations at the base 

of the panels include chipped stone tools, flaking debris, and charcoal. Radiocarbon dating of 

the charcoal resulted in the dates 850 +/- 50 BP and 1270 +/- 125 BP. Although there is no 

absolute association between these dated cultural levels and the petroglyphs, the ages have been 

tentatively used to establish the relative age of the en toto pecked style. Based on the proximity 

of the cultural debris to the rock art, tentative ages of 1,200 to 850 years were suggested for the 

en toto pecked style. 

The majority of the petroglyphs were made by pecking through the dark rock varnish to expose 

the lighter colored interior stone. The practice of removing all the interior of each petroglyph, 
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as opposed to simply pecking away an outline of each figure, is used as one of the criteria in 

establishing a type of petroglyph known as the en toto pecked style. Petroglyphs in this style 

were through to be part of a continuous tradition that lasted through at least four centuries. 

In 1983 the each panel (1-38) at Petroglyph Canyon was photographed using a series of 

filters/lenses then using a low level aerial photograph, every boulder or rock face containing 

rock art was identified with a corresponding panel number. 

Petroglyph Canyon ACEC is segregated from appropriation under the agricultural land laws, 

from sales under Section 2455 of the revised statutes, and from operation of the mining laws. It 

was withdrawn from mineral entry, but not from mineral leasing March 7, 1988. 

To conserve this area for future generations to study and enjoy, the area is managed according 

to the following management prescriptions (1999). Wood product sales, ROWs, O&G leasing 

and geophysical exploration for O&G are not allowed. Livestock grazing and range 

improvement are allowed. Locatable minerals are withdrawn from entry through a regulatory 

withdrawal on the entire 240 acres. It is closed to off-road vehicle use.. The area is managed 

per VRM Class IV objectives. 

3.27.3.7 Pompeys Pillar ACEC 

Pompeys Pillar ACEC is discussed in Section 3.4.2 – Pompeys Pillar. 

3.27.3.8 Stark Site ACEC

The Stark Site ACEC is located in western Musselshell County, Montana. The area is a 

complex of sites used for bison impoundment and processing, occupations, burials, a rock 

shelter, rock art, and historic remains. Of the 26 sites recorded, 21 are considered eligible for 

nomination to the National Register of Historic Places (Map 171). 

The Stark Site Complex has the potential to yield significant information on Native American 

societies of the Northwestern plains from the Plains Archaic period to the early Historic period. 

The complex of sites in the area includes evidence for the repeated impoundment, slaughter, 

and processing of bison over a long period of time. Included are seven separate bison bone bed 

deposits, each representing a kill and processing episode; a number of open occupation sites 

with artifacts, hearth features, and buried deposits; and a small rock shelter with rock art and 

with the potential for buried occupation deposits. At least two human burials have been 

removed from the area. 

When originally recorded in 1972, one of the bison kill and processing sites yielded ceramic 

sherds similar to types found in late prehistoric contexts on the Missouri River in North Dakota. 

Limited excavation was subsequently conducted by Montana State University. Material culture 

remains from the Stark Site include flaked stone tools, groundstone, bone and shell artifacts, 

and pot sherds. The presence of this rare (for central Montana) and exotic artifact type (pot 

sherds), suggests that these people may have been among the earliest Crow to move into the 

area after splitting off from North Dakota agricultural groups. The opportunity to investigate 

the activities of late prehistoric Plains nomad societies at a time when they were initially 
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entering the area is unusual and may be quite significant, not only for an understanding of 

Crow and Hidatsa ethnohistory, but for understanding the ethnohistory of numerous other 

groups who entered the North American Plains in late prehistoric and historic time. 

Although bison kill and butchering sites on the Northwestern Plains are not uncommon, the 

Stark Site complex represents the greatest density of such sites known on public lands in 

southcentral Montana. The presence of both kill and processing sites dating over a 

considerable span of time provides the opportunity to compare hunting and related strategies by 

various groups using the site over differing time periods. 

To conserve this area for future generations to study and enjoy, the area is managed according 

to the following three management prescriptions (1999). Livestock grazing and range 

improvements are allowed. Fire is managed with conditional fire suppression. Wood product 

sales, ROWs, and mineral material sales and permits are not allowed. O&G leasing is allowed 

with a No Surface Occupancy stipulation. Geophysical exploration for O&G is not allowed on 

the significant cultural resource sites and is allowed (surface methods and vibroseis) in the 

remainder of the ACEC. Off-road vehicle use is limited to designated roads and trails. The area 

is managed per VRM Class III objectives. 

3.27.3.9 Weatherman Draw ACEC 

Weatherman Draw ACEC in Carbon County, Montana, contains rare archaeological resources. 

Weatherman Draw contains the largest collection of polychromatic pictographs known in the 

Northern Plains. Petroglyphs are also found in the ACEC. The area has implications for the 

understanding of prehistoric rock art throughout the North American Great Plains and Rocky 

Mountain region. 

Weatherman Draw is also an area of high religious importance for many Native Americans. 

The Blackfeet, Comanche, Crow, Eastern Shoshone, Kiowa, Northern Arapaho, Northern 

Cheyenne, Standing Rock Sioux, Spirit Lake Sioux, Yankton Sioux, Nez Perce, Leech Lake 

Ojibwe, and the Fort Peck Assiniboine and Sioux are just some of the Native American 

communities who place high religious significance on this area. The Weatherman Draw area is 

still being used for religious purposes by many tribes. 

There has been almost 80 years of work in the Weatherman Draw area. The intriguing thing 

about this is that the initial work was driven towards finding and recording rock art. In that 

period most of the large panels were recorded and Loendorf focused his famous studies on the 

Valley of the Shields. This seminal work triggered emphasis on the rock art in the area by 

other archaeologists. The focus on rock art tended to skew the data set towards one aspect of 

the prehistoric use of the area. 

By 2001, over 85 sites had been recorded within the ACEC boundaries, including 39 rock art 

sites, 29 prehistoric occupation sites, 14 historic rock inscriptions, and 4 historic 

camps/mines/homesteads. 

Beginning in 2004, the BLM Billings Field Office entered into a ten year agreement with 

Western Wyoming Community College to undertake a Class III cultural resource inventory of 

the Weatherman Draw ACEC plus an additional 8,000 acres of BLM managed public lands 
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surrounding the ACEC (expanded ACEC area). This research has focused on determining the 

nature of the cultural landscape. More to the point, it has focused on the settlement and spatial 

patterns of the area, studying all the sites in conjunction with the ecozones in which they are 

located to get a better understanding of the cultural landscape. All portions of the cultural 

landscape are being studied; from the aboriginal rock art, vision quest sites, and occupation 

sites to the historic homesteads and opportunistic coal mines. 

There was a great deal of controversy over the 1985 and 1987 oil and gas lease sales in which 

two leases were purchased for the Weatherman Draw area by Blackford Energy. Neither of 

these leases included stipulations that restricted surface occupancy. In 1993, BLM received an 

Application for Permit to Drill (APD) for four wells within the Weatherman Draw area. By 

law, BLM can deny the APD only if it violates the lease stipulations or applicable laws. The 

BLM initiated an environmental assessment which revealed significant cultural properties 

within the proposed drilling area. The BLM determined that tribal consultation was required 

under provisions of Section 106 of the National Historic Preservation Act. 

As part of the tribal consultation (1994), the BLM consulted with tribes in Montana and 

Wyoming. Four tribes identified the area as having significant traditional religious values and 

ongoing religious use. Blackford Energy applied for a suspension, which the BLM granted. 

In 1995, the BLM proposed to designate the Weatherman Draw area as an ACEC. Blackford 

Energy issued a position that the proposed designation in no way affected their rights to drill 

since their leases predated the designation. BLM agreed, but postponed a decision on the 

APDs pending review and public comment. 

In 1996, Blackford Energy transferred its leases to Anschutz Exploration. Anschutz submitted

an APD on two Blackford locations and indicated that a second APD could be filed, depending 

on test results of the first well. A second APD is filed. The BLM conducted an analysis to 

review the two well proposals and potential production of each well. 

In 1997, BLM received official consultation from the seven tribes of the Medicine Wheel 

Coalition, requesting no permits to drill be issued in Weatherman Draw due to the sacred nature 

of the locality. BLM determined that drilling must be allowed under the conditions of the 

original lease (valid existing rights), however still delayed issuance of the permit pending 

resolution of the Sacred Site conflict. 

In 1998, Anschutz threatened a lawsuit if BLM did not issue a permit. 

In 1999, Weatherman Draw ACEC is designated (4,268 acres) with specific management 

prescriptions to protect the ACEC values. However the 1985 and 1987 oil and gas leases in 

Weatherman Draw are valid and existing rights. BLM concluded an EIS would be needed to 

study impacts related to production. Anschutz withdrew its original proposal and submitted 

another APD for a single exploratory well. BLM decided that the area known as Cottonwood 

Creek, which includes many Historic Properties, should receive a sample cultural resource 

inventory prior to the issuance of any new lease in the vicinity. Three new proposed oil and 

gas leases were deferred pending completion of this inventory and subsequent 

recommendations. The selected acreage included both public lands and split estate lands 

(private surface and federal mineral estate) located outside the ACEC boundary. The BLM’s 
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objective was to locate the tracts containing high cultural resource values which would aid in 

the formulation of protective stipulations to be applied to the deferred leases. 

In 2000, a letter writing campaign by the Sierra Club promoted much public involvement. 

Public comment reached its peak and Senator Conrad Burns (R-MT) gets involved. Anschutz 

modified its original APD to a single exploratory well. BLM and Anschutz agreed that if the 

well is a producer, no further permits will be issued. Anschutz Energy is issued a permit to 

drill a single exploratory well in Weatherman Draw under stringent restrictions and a one 

million dollar mitigation bond. 

In 2001, BLM’s decision is appealed to the IBLA (Interior Board of Land Appeals) by a 

coalition consisting of the National Trust for Historic Preservation (NTHP), Sierra Club, and 10 

Native American tribes. The coalition appears before congress and Representative Nick Rahall 

(D-WV) introduces the “Valley of the Chief’s Native American Sacred Site Protection Act of 

2001” (HR2085). The bill failed in committee. The coalition entered into negotiations with 

Anschutz and offered alternative drilling locations in tribal lands. Anschutz agreed to delay 

drilling pending agreement. 

In 2002, Anschutz agreed to donate its leases to the NTHP. The NTHP agreed to drop its court 

challenge. 

In 2003, the first lease expired. The final report detailing the results of the Cottonwood Creek 

cultural inventory was received by the BLM in January 2003. Based on the data derived from 

the report, the BLM recommended the area immediately surrounding Weatherman Draw be 

withdrawn from mineral leasing and be included in an expanded Weatherman Draw ACEC. 

In 2004, funding was received to begin the cultural inventory of Weatherman Draw ACEC and 

the surrounding area (identified as the proposed expanded ACEC). In 2005, the last existing 

lease in Weatherman Draw expired. 

In 2008, 615 acres of private land, which included the parking area at the west entrance of 

Weatherman Draw, was offered for sale. The 615 acres of land was purchased by a Billings 

resident who then donated it to the BLM in order to keep the public access open to the 

Weatherman Draw ACEC. The sale and transfer of the land to the BLM became final in 

December 2008. 

To conserve this area for future generations to study and enjoy, the area is managed according 

to the following management prescriptions (1999). Livestock grazing is allowed. Fire is 

managed with conditional fire suppression. ROWs associated with valid existing O&G lease 

rights are allowed with restrictions. Other ROWs are not allowed. Range improvements are 

allowed when they do not conflict with the ACEC values. Locatable minerals are withdrawn 

from mineral entry on 600 acres through a regulatory withdrawal. Wood product sales and 

mineral material sales and permits are not allowed. O&G leasing are allowed with a No Surface 

Occupancy stipulation with no waiver, exception, or modification provisions. The area is 

closed to geophysical exploration for O&G. Motorized vehicle use is limited to authorized use 

only. The area is managed per VRM Class II objectives. 
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3.28 Wilderness Study Areas 

There are four Wilderness Study Areas (WSAs) in the Planning Area, as set forth in Table 

3-72. These areas are Big Horn Tack-On, Burnt Timber Canyon, Pryor Mountain, and Twin 

Coulee. 

Table 3-72 WSAs in the Planning Area 

WSA Name WSA Number Total 

Acreage

Acres Recommended 

for Wilderness

Acres Recommended for 

Non-Wilderness

Big Horn Tack-On MT-067-207 2,689 2,470

Burnt Timber Canyon MT-067-205 3,516 3,430

Pryor Mountain MT-067-206 15,590 12,575

Twin Coulee MT-067-212 6,836 0 6836

Note: 

Source: BLM 1984 

BLM Manual 6330 (Management of BLM Wilderness Study Areas) states:

“...Wilderness preservation is part of the BLM's multiple-use mandate, and the 

wilderness resource is recognized as one of the array of resource values considered in 

the land-use planning process.”

The original wilderness review process outlined under Section 603 of FLPMA had three 

phases: inventory, study, and reporting to Congress. Public involvement was encouraged in all 

phases of the process, with opportunity provided for comment, participation, and review. The 

wilderness inventory was conducted from 1978 to 1980, and excluded Alaska and Oregon and 

California Grant Lands Act of 1937 (O&C Act) lands managed primarily for timber production. 

The original inventory focused on roadless areas of public lands of 5,000 acres or more and on 

roadless islands, but also included areas of less than 5,000 acres that had wilderness 

characteristics in association with contiguous roadless lands managed by another agency, and 

areas of less than 5,000 acres that had wilderness characteristics and could practicably be 

managed to keep those characteristics in an unimpaired condition. Additional WSAs were 

designated through the BLM land use planning process under the authority of Sections 

201,202, and 302 of FLPMA after the reports to Congress were completed in 1993.

Pursuant to the Wilderness Act of 1964, Section 2(c), “wilderness” is defined as 

“. . . an area where the earth and its community of life are untrammeled by man, 

where man himself is a visitor who does not remain . . . an area of undeveloped 

federal land retaining its primeval character and influence, without permanent 

improvements or human habitation, which is protected and managed so as to 

preserve its natural conditions and which (1) generally appears to have been 

affected primarily by the forces of nature, with the imprint of man’s work 

substantially unnoticeable; (2) has outstanding opportunities for solitude or a 

primitive and unconfined type of recreation; (3) has at least five thousand acres 

of land or is of sufficient size as to make practicable its preservation and use in an 
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Chapter 3: Affected Environment 3-251

unimpaired condition; and (4) may also contain ecological, geological, or other 

features of scientific, educational, scenic, or historical value.”

The FLPMA of 1976 directs the BLM to inventory and study its roadless areas for wilderness 

characteristics. An area must have the following characteristics to be designated a WSA: 

 Size – Public lands that are roadless and of at least 5,000 acres in area or of a 

manageable size 

 Naturalness – Generally appears to have been impacted primarily by the forces 

of nature 

 Opportunities – Provides outstanding opportunities for solitude or primitive 

and unconfined types of recreation 

WSAs also often have special qualities, such as ecological, geological, educational, historical, 

scientific, and scenic values. 

FLPMA mandated that the BLM would inventory and study its lands for their wilderness 

suitability within 15 years and, based on that review the Secretary of the Interior would forward 

his/her wilderness recommendations to the President. Recommendations for the BiFO planning 

area were included in the Montana Statewide Wilderness Study Report released in September 

1991 (USDI-BLM 1991b). The Secretary of the Interior and President signed recommendations 

and forwarded them to Congress before the end of that year. As a result of the inventory and 

study the four existing WSAs were recommended in the 1984 RMP (BLM 1984). 

Only Congress can designate the WSAs established under Section 603 of FLPMA as 

wilderness or release them for other uses. Therefore, the status of existing WSAs will not 

change as a result of the BiFO planning process and RMP revision. WSAs will be reevaluated 

to ensure current management and uses are compatible with the intent of their designation. The 

BLM’s management policy is to continue resource uses on lands under wilderness review in a 

manner that maintains suitability for preservation as wilderness. 

BLM Manual 6330 (Management of BLM Wilderness Study Areas), directs Agency 

management of WSAs until Congress acts on designation. If Congress designates the areas as 

wilderness, they would be managed according to the Wilderness Act of 1964, as amended, 

Public Law 88-577 (16USC 1131-1136). If Congress releases them from wilderness 

consideration, the areas would be managed as prescribed under the existing RMP management 

direction.

3.28.1WSAs in the Planning Area 

3.28.1.1 Big Horn Tack-On WSA 

Big Horn Tack-On is a narrow strip of land about nine miles long and less than one-half mile 

wide with 2,470 acres in Montana and 80 acres in Wyoming. The WSA is located between 

Sykes Ridge Road on the west and the BCNRA to the east. 
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3-252 Chapter 3: Affected Environment

This WSA is primarily in a natural state with a few dispersed, but fairly well screened, human 

intrusions. These consist of uranium exploration pits; a wild horse trap in the north along the 

west boundary road; vehicle ways, one in the north and one in the south; and the power line on 

the southeast (Map 161 - Burnt Timber WSA, Big Horn Tack-On WSA and Pryor Mountain 

WSA). 

3.28.1.2 Burnt Timber Canyon WSA

The area encompasses an extremely rugged and isolated portion of Crooked Creek Canyon, 

which has remained relatively free of modern human influences. The WSA is predominantly 

natural and offers outstanding opportunities for solitude and primitive recreation. 

The major drainage, Crooked Creek, supports a genetically pure strain of native cutthroat trout. 

The creek is not considered an outstanding fishery because the trout are small, and dense brush 

restricts ready stream access. However, native trout species here have a high intrinsic value 

and, in 2007, the BLM installed a fish barrier in the upper reaches of Crooked Creek to protect 

this species (Map 161 - Burnt Timber WSA, Big Horn Tack-On WSA, and Pryor Mountain 

WSA). 

3.28.1.3 Pryor Mountain WSA 

The Pryor Mountain WSA is 12,575 acres and contains some of the most rugged, isolated 

portions of the Pryor Mountains. The wide expanses and topographic screening in this area 

offer outstanding wilderness values. This unit is in the heart of the PMWHR and the free 

roaming wild horse herd enhances the wilderness characteristics of the area. Human activity is 

well distributed throughout the WSA. Vegetation and topographic screening significantly limit 

any detraction from the WSA’s extensive natural setting. There are 4,352 acres of the Pryor 

Mountain WSA which are located in Big Horn County, Wyoming (Map 161 - Burnt Timber 

WSA, Big Horn Tack-On WSA and Pryor Mountain WSA). 

3.28.1.4 Twin Coulee WSA 

The Twin Coulee WSA is 6,870 acres located on the southeast flank of the Big Snowy 

Mountains in Golden Valley County, Montana. It consists of steep mountainous topography 

with several deeply incised drainages. Most of the WSA is made up of a mixed coniferous 

forest with bunch grasses for an understory. Elevations range from 5,500 to 7,600 feet. (Map 

160 – Twin Coulee Wilderness Study Area). 

3.29 Wild and Scenic Rivers 

Congress enacted the Wild and Scenic River Act (WSR Act) on October 2, 1968 to provide a 

national policy for preserving and protecting selected rivers and river segments in their freeflowing condition for the benefit of present and future generations. Section 5(d)(1) of the WSR 

Act) (Public Law 90-542; 16 US Code 12711287) directs federal agencies to consider potential 

wild and scenic rivers in their planning processes. To fulfill this requirement, the BLM 

inventories and evaluates rivers when it develops or revises an RMP for public lands in a 

specified area. 
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A Wild and Scenic River (WSR) study process has two main components: the eligibility phase 

and the suitability phase. The eligibility phase is conducted during the RMP data gathering 

stage, and the suitability phase is done during formulation of the draft and proposed RMP.

As part of its RMP process, the BiFO conducted the initial inventory and study processes 

provided for under the Act. The Final Wild and Scenic River Eligibility Report describes the 

methodology and process used to identify river segments, assess their eligibility, and for 

eligible segments, assign a preliminary classification (Ecosystem Management Inc. 2009). The 

study was completed in April 2009 and is included in Appendix R – Final Wild and Scenic 

River Eligibility Report. The Eligible Wild and Scenic River Segments map shows eligible 

river segments in the decision area. 

This study considered only BLM administered lands along streams and rivers. Private, state, 

and other federally administered lands were not part of the study. Currently, no rivers or river 

segments in the decision area are managed under the Act. 

3.29.1Eligibility Phase 

Currently, only the eligibility phase of the WSR process is complete. The eligibility phase is 

undertaken to identify eligible river and stream segments and assign tentative classifications to 

each. A wide variety of internal and external sources are considered when identifying 

potentially eligible rivers. The BLM applies standard criteria to identified segments to 

determine eligibility. A river segment must be free flowing and possess at least one river 

related value considered outstandingly remarkable to be eligible. 

As part of the land use planning process for the RMP, the BiFO interdisciplinary team analyzed 

all river and stream segments that may be eligible for inclusion in the National Wild and Scenic 

River System (NWSRS). This included screening rivers to identify those with BLM surface 

ownership. In addition, BLM coordinated with other federal and state river administering 

agencies and consulted applicable source listings such as the NPS Nationwide Rivers Inventory 

and the American Rivers Outstanding Rivers List. These initial screening and identification 

efforts resulted in a list of 78 rivers or river segments in the decision area that required further 

consideration in the inventory process. Fourteen of the 78 were identified for further study. 

Additional reviews focused on whether these segments met the free-flowing criteria and 

contained any outstandingly remarkable values, as defined in the WSR Act. 

Of the 14 segments, seven were determined eligible because they contained one or more 

outstanding or remarkable criteria, as defined by BLM Manual 8351. The seven segments that 

met the eligibility criteria and corresponding resource values are shown in Table 3-73 (Map 

162).
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Table 3-73 Wild and Scenic Rivers and River Segments Eligibility 

River or Creek Name

Total Segment 

Length Including 

Non-BLM Lands 

(miles)

Portion of 

Segment 

Occurring 

on BLM 

Lands 

(miles)

Free Flowing DeterminationScenicRecreationGeologicalFishWildlifeHistoricCulturalOther

Bad Canyon 5 4.5 Y X

Bear Canyon 1.6 1.6 Y X X X

Crooked Creek

(above fish barrier)

1.59 1.59 Y X X X X

Crooked Creek 

(below fish barrier) 1.56 1.56 Y X X X

Gyp Springs .46 .46 Y X X

Piney Creek .16 .16 Y X

Yellowstone RiverPompeys Pillar 4.46 4.19 Y X X X X

Note: 

Source: Data extracted from Ecosystem Eligibility Report, 2009, Appendix R. 

The seven waterway segments in the decision area that were identified as meeting the eligibility 

criteria are tentatively classified as wild, scenic, or recreational. 

3.29.2Suitability Phase 

The purpose of the suitability phase is to determine whether eligible river segments are suitable 

for inclusion in the NWSRS per the WSR Act criteria. The suitability evaluation does not result 

in official designation; it is only a suitability determination for designation. The BLM cannot 

administratively designate a stream into the NWSRS through a planning or other agency 

decision. Only Congress or, in some instances, the Secretary of the Interior may designate a 

wild or scenic river segment. Water protection strategies and measures to meet the purposes of 

the WSR Act will be the responsibility of Congress in any legislation proposed. Rivers that do 

not meet suitability would be dropped from further consideration and managed according to the 

objectives outlined in this RMP. 

The suitability phase is conducted as part of the RMP revision process and addressed in a range 

of alternatives. 

3.30 Pryor Mountain Wild Horse Range (PMWHR) 

See Wild Horses Section 3.9 for PMWHR information. 

3.31 National Historic Trails 

National Historic Trails are a congressionally designated trail that is an extended, long-distance 

trail, not necessarily managed as continuous, that follows as closely as possible and practicable 
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the original trails or routes of travel of national historic significance. The purpose of a National 

Historic Trial is the identification and protection of the historic route and the historic remnants 

and artifacts for public use and enjoyment. A National Historic Trail is managed in a manner 

to protect the nationally significant resources, qualities, values, and associated settings of the 

areas through which such trails my pass, including the primary use or uses of the trail. 

National Historic Trails, especially high potential sites and segments, are managed and 

protected in accordance with the National Trails System act, Section 106 of the National 

Historic Preservation Act, the National Landscape Conservation System Act, Executive Order 

13195, and BLM IM-2009-215. 

To qualify for designation as a national historic trail, a trail must meet the following criteria: 

 Have been established by a historic use and have historical significance as a 

result of that use 

 Have historic use of the trail that has had a far and reaching effect on broad 

patterns of American culture 

 Has significant potential for public recreational or historical interest. 

National Historic Trails are managed in accordance with the National Trails System Act of 

1968, as amended (16 USC 1241-1251) to recognize the nationally significant resources, 

qualities, values, and associated settings of the areas through which such trails may pass, 

including the primary use or uses of the trail and according to their respective comprehensive 

management plans. The Nez Perce NHT Comprehensive Management Plan was completed in 

1990 and is currently under plan revision at this time (2014). The Lewis and Clark NHT 

Comprehensive Management Plan was completed in 1982. In 2012, the Lewis and Clark NHT 

completed a Foundation Document, which is a formal statement of the Trail's core mission that 

provides basic guidance for all planning and management decisions 

The Bureau of Land Management guidance further provides that National Historic Trails 

(NHT) should be managed to promote preservation, public access, travel opportunities, 

enjoyment, and appreciation of National Trails for present and future generations as a 

component of the National Landscape Conservation System or the National Trails System. 

The BiFO manages several segments of two National Historic Trails. These include segments 

along the Lewis and Clark National Historic Trail (L&CNHT) and the Nez Perce National 

Historic Trail (NPNHT) (Map 166 – National Historic Trails). 

The BiFO manages approximately 12 miles of the Nez Perce (Nimíipuu or Nee-Me-Poo) 

National Historic Trail. The BiFO also manages the portion of trail on public land along the 

Clarks Fork of the Yellowstone River and north toward the Bear’s Paw Mountains. The trail 

stretches from Wallowa Lake, Oregon, to the Bear’s Paw Battlefield near Chinook, Montana. It 

was designated as a National Historic Trail in 1986. This route was used in its entirety only 

once; however, components of the route were used for generations prior to and after the 1877 

flight of the Nez Perce. 
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The BiFO manages approximately seven miles of the L&CNHT that primarily follows the 

Yellowstone River through the planning area. Most public lands along the river trail are 

inaccessible except for 2.2 miles near Pompeys Pillar National Monument. The L&CNHT 

section adjacent to Pompeys Pillar NM is addressed in more detail in Section 3.4.2 - Pompeys 

Pillar of this document.
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3.32 Social and Economic Conditions 

3.32.1Social Conditions 

3.32.1.1 Attitudes and Social Trends

This section focuses on the attitudes and social trends that affect BLM land management. This 

information is important to land management decision makers because the trends and attitudes 

can affect relationships between the agency and its constituents, the ability to successfully 

implement plans, and the potential impacts to individuals and communities (both in the 

geographical sense and communities of interest.) 

Changes in the management of BLM-administered lands are just one aspect of a broader debate 

in environmental and resource management occurring locally, nationally, and globally. 

Commodity, amenity, environmental quality, ecological, recreation, and spiritual are all social 

land and natural resource values. While the emphasis on the commodity value of public lands 

has been prevalent in the past, a recent study examining public attitudes toward ecosystem 

management in the United States found “generally favorable attitudes toward ecosystem 

management (defined as maintaining and ensuring sustainability) among the general public.” 

(Bengston, Xu, and Fan 2001) 

In the rural West, in places where land use has been relatively unrestricted, some individuals 

and groups have expressed concern regarding the control and management of BLMadministered lands. People with these concerns feel that government officials and 

environmental advocacy groups that do not have a true understanding of the lands or local 

residents who depend upon these lands for income and recreation drive changes in BLM land 

management. Of particular concern is the loss of current land uses such as livestock grazing 

and OHV use. People with these concerns seek to balance what they consider environmental 

extremism with economic and human concerns, and they may feel that local elected officials, 

with whom they are more closely in touch on a daily basis, are better equipped to make 

decisions about BLM-administered lands. 

The Billing Field Office is located in an area where there is a significant amount of federal land 

ownership. In addition to BLM administered lands, the planning area counties include parts of 

several National Forests, the Bighorn Canyon National Recreation Area, the Little Bighorn 

National Monument, several small National Wildlife Refuges and Yellowstone National Park. 

Some members of the public do not readily differentiate between the various federal land 

management agencies so that activities by other federal agencies may affect the public’s views 

of the BLM. General attitudes toward the federal government, in some cases unrelated to 

specific BLM activities, may also influence attitudes toward the BLM. 

Some of the major trends affecting BLM’s land management of the Billings Field Office area 

are: 

1) The increasing popularity of BLM land for recreation. A comprehensive report on 

recreation by Cordell et al. (1999) indicates that demand in the Rocky Mountain West for 
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recreation activities will increase substantially by the year 2020, with non-consumptive wildlife 

activities, sightseeing, and visiting historic places increasing the most. 

2) Concern regarding access to BLM-administered land and the loss of public access to 

some private land is adding pressure on BLM-administered lands. These changes, linked to the 

pursuit of a quality recreation experience, occur for a variety of reasons, which include the 

purchase of lands for private use, leases to outfitters for exclusive use, and closure of private 

land and roads to avoid problems of safety, fire, fences, weed, litter, and open gates. 

3) An aging population is another trend occurring in the nation and Montana; in 2009, 14.6 

percent of the population in the planning area was 65 or older, compared to a nationwide figure 

of 13.0 percent. For the state as a whole, the percentage of population 65 or older is expected to 

increase to about 25 percent by 2025. The percentage of people 65 or older is actually 

increasing more rapidly in states like Montana because young people are more likely to leave 

for advanced education, military service, and employment opportunities not available locally. 

4) An increase in year round and vacation homes in the wildland urban interface (WUI) 

which has led to an increase in human caused ignitions and greater demands for resources 

necessary to suppress fire.

3.32.1.2 Population

3.32.1.2.1 Montana, Wyoming, and the Planning Area 

The planning area includes eight counties in south central Montana and two counties 

contiguous to the Montana counties in north central Wyoming. The Montana Counties are Big 

Horn, Carbon, Golden Valley, Musselshell, Stillwater, Sweet Grass, Wheatland and 

Yellowstone, and the Wyoming Counties are Big Horn and Park. The Wyoming Counties are 

included because the Billings Field Office administers over 4,000 acres in Big Horn County, 

Wyoming as part of the Pryor Mountain Wild Horse Range, and some economic activity 

related to Carbon County mineral development occurs in Park County, Wyoming (Table 3-74). 

In 2010, the Montana state population was 989,415 persons across a 145,552 square mile land 

area. This represented a 9.7 percent increase from 2000. Population density was an average of 

6.8 persons per square mile, compared to a national figure of 87.3. In 2009, 14.6 percent of all 

Montana residents were 65 years and older compared to a national figure of 13.0 percent. 

Based on 2005-2009 data, 90 percent of persons over 25 in Montana were high school 

graduates compared to 85 percent for the country as a whole. In 2009, 15.0 percent of the state 

population had incomes below the poverty level compared to a figure of 13.8 percent 

nationwide. 

The Montana portion of the planning area had a population of 191,118 in 2010, which was 

about 19 percent of the total population of the state. This figure represented an 11.6 percent 

increase from 2000 which was slightly higher growth than for the state as a whole. Population 

density was an average of 9.4 persons per square mile which was higher than for the state as a 

whole. The influence of Yellowstone County, home to Billings which is the largest city in 

Montana, is obvious in these figures. Nearly 77 percent of the planning area population was 
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located in Yellowstone County, population density in Yellowstone County was 56.2 compared 

to 0.8 to 4.9 in the other counties, and the growth rate for Yellowstone County was higher than 

for all the other Montana planning area counties. 

 

In 2009, 16.3 percent of the Montana planning area population was 65 years or older compared 

to a Montana figure of 14.6 with the oldest populations being in the more rural counties. Based 

on 2005 to 2009 data, an average of 89.9 percent of persons over 25 in the planning area were 

high school graduates with the highest figure being in Yellowstone County. In 2009, 16.3 

percent of the planning area counties had incomes below the poverty level with the level being 

highest in Big Horn County. The percent American Indian in 2010 was 9.0 percent with the 

figure being highest in Big Horn County where the Crow Reservation is located. 

As mentioned previously, the largest community in the Montana part of the planning area is 

Billings in Yellowstone County, with a 2010 population of 104,170. There are nine other 

incorporated areas in the planning area with 2010 populations greater than 1,000: Lockwood 

6,797 (Yellowstone County), Laurel 6,718 (Yellowstone County), Hardin 3,505 (Big Horn 

County), Red Lodge 2,125 (Carbon County), Columbus 1,893 (Stillwater County), Roundup 

1,788 (Musselshell County), Big Timber 1,641 (Sweet Grass County), Crow Agency 1,616 

(Big Horn County) and Absarokee 1150 (Stillwater County). In addition, there are numerous 

other incorporated and unincorporated communities in the planning area that function with 

independent and/or shared services including water districts, sewer districts, and school 

districts. 

In 2010, the Wyoming state population was 563,626 persons across a 97,100 square mile land 

area. This represented a 14.1 percent increase from 2000. Population density was 5.8 persons 

per square mile, compared to a national figure of 87.3. In 2009, 12.3 percent of all Wyoming 

residents were 65 years and older compared to a national figure of 12.9 percent. Based on 

2005-2009 data, 91.1 percent of persons over 25 in Wyoming were high school graduates 

compared to 84.6 percent for the country as a whole. In 2009, 10.2 percent of the state 

population had incomes below the poverty level compared to a figure of 14.3 percent 

nationwide. 

The Wyoming portion of the planning area had a population of 39,971 in 2010, which was 

about 7 percent of the total population of the state. This figure represented a 6.8 percent 

decrease from 2000 which was about half the growth rate for Wyoming as a whole. In 2009, 

17.2 percent of the Wyoming planning area population was 65 years or over compared to a 

Wyoming figure of 12.3. Based on 2005 to 2009 data, an average of 90.0 percent of persons 

over 25 in the planning area were high school graduates with the higher figure being in Park 

County. In 2009, 10.5 percent of the planning area counties had incomes below the poverty 

level which was slightly higher than the state figure. The percent American Indian in 2010 was 

0.8 percent which was lower than the state figure of 2.4 percent. 

There are five incorporated communities with a population greater than 1,000 in the Wyoming 

portion of the planning area. These include: Cody 9,520 (Park County), Powell 5,373 (Park 

County), Lovell 4,604 (Big Horn County), Greybull 1,879 (Big Horn County) and Basin 1,269 

(Big Horn County). In addition there are numerous other incorporated and unincorporated 
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communities that function with independent and/or shared services including water districts, 

sewer districts, and school districts. Some of the communities in both Big Horn and Park 

Counties are affected by mineral development occurring in the Montana Counties. 

 
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Table 3-74 Demographic and Social Information for the Montana and Wyoming Planning Area Counties

Demographic and Social Information for the Montana and Wyoming Planning Area Counties

Big Horn 

(MT)

Carbon

(MT)

Golden 

Valley

(MT)

Musselshell

(MT)

Stillwater

(MT)

Sweet Grass

(MT)

Wheatland

(MT)

Yellowstone

(MT)

Big Horn

(WY)

Park

(WY)

Planning Area

MT/

WY

State of 

MT

State of WY

2010 Population 12,865 10,078 884 4,538 9,117 3,561 2,168 147,972 11,668 28,205 191,183/

39,971 989,415 563,626

% Change 2000-2010 1.5 5.5 -15.2 0.9 11.3 1.2 -4.0 14.4 1.8 9.4 11.6/

6.8 9.7 14.1

Persons Per Sq. Mi.

(2010) 2.6 4.9 0.8 2.4 5.1 2.0 1.5 56.2 3.7 4.1 9.4/3.9 6.8 5.8

Net Migration

(2000-2009) -1,077 347 2 219 405 39 -175 10,026 NA NA 978** 42,980 NA

% Age 65 & Over 

(2009) 9.7 17.4 15.8 18.7 16.4 18.5 20.5 14.0 17.2 17.2 16.3/17.2 14.6 12.3

% White

(2010) 31.4 97.2 94.0 96.1 96.8 96.6 95.8 90.7 94.4 95.6 87.3/95.0 89.4 90.7

% American

Indian (2010) 64.3 0.8 1.0 1.3 0.8 0.4 0.5 4.0 0.9 0.6 9.0/0.8 6.3 2.4

% HS Grad

Persons 25 & Over

(2005-2009)

82.4 91.1 89.2 83.9 91.4 86.3 87.6 91.0 88.3 92.1 89.9/

90.0 90.4 91.1

Median Household

Income (2009) $32,223 $41,952 $30,424 $33,382 $53,637 $41,993 $28,730 $47,139 $22,675 $47,264

$38,685/

$34,969 $42,222 $54,400

% Persons Below the 

Poverty Level (2009) 24.0 12.1 21.7 20.5 9.3 11.5 19.5 11.7 10.6 10.4 16.3/10.5 15.0 10.2

NA indicates information not available 

*Montana Planning area includes the 6 Montana Counties; Wyoming Planning area includes the 2 Wyoming Counties 

**Includes only the Montana Counties 

Source: 2010 Quickfacts, Bureau of the Census 
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3.32.1.2.2 Montana County Information 

Big Horn County, Montana 

Big Horn County, located in the southern part of the planning area, is the home of the Crow 

Indian Reservation (covering 64 percent of the county). The tribal headquarters are located in 

the county at Crow Agency. The county also contains a small part of the Northern Cheyenne 

Indian Reservation, part of the Bighorn Canyon National Recreation Area, and the Little 

Bighorn Battlefield National Monument. The U.S. Bureau of Reclamation operates a major 

water project, Yellowtail Dam, in the county. The county population was 12,865 in 2010, an 

increase of 1.5 percent since 2000. Hardin, the county seat, had a 2010 population of 3,505. 

Other smaller communities include Crow Agency, Lodge Grass, Busby and Fort Smith. In 

2007, Big Horn County had 695 farms and ranches with 369 (53%) of the principal operators 

identifying farming and ranching as their primary occupation. The number of farms and 

ranches increased 19 percent between 2002 and 2007 while the amount of land in farms 

increased by 3 percent and the average size of the farm declined by 13 percent to 4,172 acres. 

There are 7 acres of BLM administered surface land and 1.016 acres of BLM administered 

mineral estate in Big Horn County. 

Carbon County, Montana 

Carbon County, located in the southwestern part of the planning area, has more BLM 

administered surface acreage and mineral estate than any other planning area county. Located 

at the base of the Beartooth Mountains, it has become a tourist destination and is home to the 

beginning of the Beartooth All-American Road and Scenic Highway, Red Lodge ski resort, 

most of the Bighorn Canyon National Recreation Area and part of the Pryor Mountain Wild 

Horse Range. The county population was 10,078 in 2010, an increase of 5.5 percent since 

2000. Red Lodge, the county seat, had a population of 2,125 in 2010. Other smaller 

communities include Belfry, Bridger, Fromberg and Joliet. In 2007, Carbon County had 715 

farms and ranches with 335 (47%) of the principal operators identifying farming and ranching 

as their primary occupation. The number of farms and ranches increased 2 percent between 

2002 and 2007 while the amount of land in farms increased by 5 percent and the average size of 

the farm increased by 4 percent to 1,110 acres. There are 220,556 acres of BLM administered 

surface land and 341,376 acres of BLM administered mineral estate in Carbon County. 

Activities on BLM administered lands include oil & gas leasing and production, bentonite 

production, recreation use, livestock grazing and rights-of-way. 

Golden Valley County, Montana 

Golden Valley is located in the north central part of the planning area. It is bordered by the Big 

Snowy Mountains to the north, and the Musselshell River runs through the center of the county. 

Golden Valley County is the least densely settled county in the planning area and lost the most 

population (proportionately) in the prior decade. The county population was 884 in 2010, a 

decrease of 15 percent since 2000. Ryegate, the county seat, had a population of 214 in 2010. 

In 2007, Golden Valley County had 153 farms and ranches with 96 (63%) of the principal 

operators identifying farming and ranching as their primary occupation. The number of farms 

and ranches increased 9 percent between 2002 and 2007 while the amount of land in farms 

increased by 2 percent and the average size of the farm declined by 7 percent to 4,391 acres. 
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There are 7,943 acres of BLM administered surface land and 44,360 acres of BLM 

administered mineral estate in Golden Valley County. Activities on BLM administered lands 

include oil & gas leasing and production, recreation use, and livestock grazing. 

Musselshell County, Montana 

Musselshell County, which has an active underground coal mine in the Bull Mountains, is 

located in the northeastern part of the planning area. It has the second most BLM administered 

surface acreage and mineral estate of any county in the planning area. The county population 

was 4,538 in 2010, an increase of 1 percent since 2000. Roundup, the county seat, had a 

population of 1,788 in 2010. In 2007, Musselshell County had 373 farms and ranches with 190 

(51%) of the principal operators identifying farming and ranching as their primary occupation. 

The number of farms and ranches increased 10 percent between 2002 and 2007 while the 

amount of land in farms increased by 17 percent and the average size of the farm declined by 6 

percent to 3,038 acres. There are 101,247 acres of BLM administered surface land and 226,905

acres of BLM administered mineral estate in Musselshell County. Activities on BLM 

administered lands include oil & gas leasing and production, recreation use, coal mining, 

timber production and livestock grazing. 

Stillwater County, Montana 

Stillwater County is located in the southwestern part of the planning area and is home to the 

Stillwater Mine, currently the only operating platinum/ palladium mine in the United States. 

The county population was 9,117 in 2010, an increase of 11.3 percent since 2000. Columbus, 

the county seat, had a population of 1,893 in 2010. Other smaller communities include 

Absarokee, Park City, Reed Point and Rapelje. In 2007, Stillwater County had 635 farms and 

ranches with 290 (46%) of the principal operators identifying farming and ranching as their 

primary occupation. The number of farms and ranches increased 15 percent between 2002 and 

2007 while the amount of land in farms decreased by 4 percent and the average size of the 

farm decreased by 16 percent to 1,350 acres. There are 5,504 acres of BLM administered 

surface land and 58,348 acres of BLM administered mineral estate in Stillwater County. 

Activities on BLM administered lands include oil & gas leasing and production, timber 

production, recreation use, livestock grazing and rights-of-way. 

Sweet Grass County, Montana 

Sweet Grass County is located in the western part of the planning area and is surrounded by the 

Absaroka, Beartooth, and Crazy mountains. The county population was 3,561 in 2010, an 

increase of 1.2 percent since 2000. Big Timber, the county seat, had a population of 1,641 in 

2010. In 2007, Sweet Grass County had 355 farms and ranches with 177 (50%) of the principal 

operators identifying farming and ranching as their primary occupation. The number of farms 

and ranches decreased 1 percent between 2002 and 2007 while the amount of land in farms 

decreased by 6 percent and the average size of the farm decreased by 6 percent to 2,289 acres. 

There are 15,893 acres of BLM administered surface land and 75,240 acres of BLM 

administered mineral estate in Sweet Grass County. Activities on BLM administered lands 

include oil & gas leasing and production, timber production, recreation use, livestock grazing 

and rights-of-way. 
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Wheatland County, Montana 

Wheatland County is located in the northwest part of the planning area and is home to new 

wind farm development. Wheatland County is the second least densely settled county in the 

planning area and lost the second most population (proportionately) in the prior decade. The 

county population was 2,168 in 2010, a decrease of 4 percent since 2000. Harlowton, the 

county seat, had a population of 997 in 2010. In 2007, Wheatland County had 137 farms and 

ranches with 75 (55%) of the principal operators identifying farming and ranching as their 

primary occupation. The number of farms and ranches declined 16percent between 2002 and 

2007 while the amount of land in farms declined by 2 percent and the average size of the farm 

increased by 16 percent to 6,002 acres. There are 1,333 acres of BLM administered surface 

land and 21,437 acres of BLM administered mineral estate in Wheatland County. Activities on 

BLM administered lands include livestock grazing. 

Yellowstone County, Montana 

Yellowstone County is located in the central part of the planning area and is the major trade 

and service center for south central Montana and north central Wyoming. It is by far the most 

densely settled county in the planning area. The county population was 147,972 in 2010, an 

increase of 14.4 percent since 2000. Billings, the county seat, had a population of 104,170 in 

2010. In 2007, Yellowstone County had 1,407 farms and ranches with 538 (38%) of the 

principal operators identifying farming and ranching as their primary occupation. The number 

of farms and ranches increased 10 percent between 2002 and 2007 while the amount of land in 

farms increased by 3 percent and the average size of the farm declined by 6 percent to 1,148 

acres. There are 77,373 acres of BLM administered surface land and 116,516 acres of BLM 

administered mineral estate in Yellowstone County. Activities on BLM administered lands 

include oil & gas leasing and production, recreation use, livestock grazing and rights-of-way. 

3.32.1.2.3 Wyoming County Information 

Big Horn County, Wyoming 

Big Horn County, Wyoming, is located along the Montana-Wyoming border directly south of 

Carbon and Big Horn Counties, Montana. It is home to part of the Pryor Mountain Wild Horse 

Range (PMWHR), the Pryor Mountain Wild Mustang Center (PMWMC) and part of the 

Bighorn Canyon National Recreation Area. The county population was 11,668 in 2010, an 

increase of 1.8 since 2000. Basin, the county seat, had a population of 1,269 in 2010. Lovell, 

with a 2010 population of 4,604, is the largest community in Big Horn County and the location 

of the PMWMC. There are 4,303 acres of BLM administered surface land and mineral estate 

in Big Horn County. Activities on BLM administered lands include livestock grazing and 

recreation on the PMWHR. In addition, some communities in this county are affected by 

mineral development on BLM administered land in the adjacent Montana counties. 

Park County, Wyoming 

Park County, Wyoming, is located directly south of Carbon County, Montana. 

The county population was 28,205 in 2010, an increase of 9.4 percent since 2000. Cody, the 

county seat with a 2010 population of 9,520, is a gateway community to Yellowstone Park 

which comprises a large part of the county. There are no acres of Billings RMP administered 

surface or subsurface land in this county. However, some communities are affected by mineral 

development on BLM administered land in the adjacent Montana counties. 
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3.32.1.3 Potentially Affected Groups and Individuals

Discussions of potentially affected groups and individuals in the BiFO planning area are 

included to facilitate an assessment of social effects that may occur. The groups listed below 

are residents, recreationists, or others who have direct relationships to management of BLM 

lands: 

 Ranchers/ livestock permittees 

 Recreationists (participants in motorized and-motorized activities) 

 Groups and individuals who prioritize resource protection 

 Groups and individuals who prioritize resource use 

 Wild horse advocates 

 American Indian tribes 

These groups are not mutually exclusive, and examples of households that fit into more than 

one category are likely. 

In many cases, social effects are described in terms of quality of life, which could include the 

quantity and quality of available resources (recreation opportunities) and resolution of 

problems related to resource activities. Other less tangible beliefs that may affect quality of life 

include: individuals having a sense of control over the decisions that affect their future and 

individuals feeling that the government strives to act in ways that consider all stakeholders’ 

needs. 

3.32.1.3.1 Ranchers/Livestock Grazing Permittees 

Ranching is an important part of the history, culture, and economy of the study area. In 2007, 

there were almost 4,500 farms and ranches in the Montana part of the planning area. Many 

livestock operators in the planning area graze livestock on public lands (both BLM and 

National Forest lands). Ranchers face many challenges today that include changes in federal 

regulations, economic issues, aging ranching populations and changing land use. Ranchers and 

grazing permittees may face increasingly stressful social situations as they try to balance their 

traditional lifestyles with demands from government agencies and other public land users such 

as recreationists. In addition, the absentee ownership of base property associated with the 

allotments has increased, as has the number of permittees that do not rely on livestock grazing 

for their primary source of income. Some permittees have shifted the focus of their 

management to wildlife habitat improvement and recreation. Others have diversified their 

income by seeking supplemental work off the ranch, providing outfitting and guest ranch 

services, and/or diversifying their output. These changes in the types of permittees that run 

livestock have resulted in the diversification of perspectives among the permittees. 

Ranchers and livestock grazing permittees in the planning area offered the following 

comments/concerns during scoping: maintain motorized access to administer allotments, 

maintain availability of forage and AUMs, range condition, a desire to purchase BLM 

inholdings within ranches, concern with public use of leased areas, and trespass across private 

ground to access public lands. 

 
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3.32.1.3.2 Recreationists 

Outdoor recreation is a component of most lifestyles in the planning area. According to 

University of Montana research, Montanans take more leisure trips than the United States 

average (MFWP 2008). The substantial recreational opportunities for fishing, hunting, hiking, 

horseback riding, OHV use, and sightseeing are important elements of the overall quality of life 

for planning area residents. Recreationists represent very diverse groups of people, and changes 

in recreation management can affect people who engage in the various activities differently 

based on need and preference. Due to the diversity of recreation activities, recreationists tend to 

organize into interest groups. Examples of these would be hunters, OHV users, horse riders, 

etc. Most recreational activities have at least one organization that advocates for their 

particular activity. The Montana Statewide Comprehensive Outdoor Recreation Plan outlined 

key issues based on statewide surveys and other research (MFWP 2008). The following are 

some of the key issues relevant to BLM-administered lands in the planning area: 

 a need for continued access to, and maintenance of, rural and backcountry trails and use 

areas for hiking, biking, skiing, equine and motorized (OHV, snowmobile) recreation; 

 a need for increased miles and maintenance of urban and rural trails and access for waterbased recreation.; and 

 insufficient quality and quantity of recreation facilities for youth. 

Outfitters and guides use recreational opportunities in the planning area for economic gain. 

Some outfitters and guides are ranchers or farmers who use recreation as a means to achieve 

economic diversification. Others operate full-time or seasonal outfitter businesses and employ 

some local residents as guides, while still others are permanent full-time guides who have their 

own local and non-local clients. 

Comments from recreationists during scoping included: more access for preferred activities 

including horseback riding, mountain biking, and winter activities, increased hunting 

opportunities, signing to identify public lands, education of users, adequate law enforcement, 

address user conflicts, and place high value on open places and scenery. Motorized 

recreationists wanted motorized opportunities to be maintained, improved trails, loop trails, and 

volunteer opportunities. Non-motorized recreationists wanted solitude and tranquility and were 

concerned about illegally created roads and resource damage from motorized use. 

3.32.1.3.3 Groups and Individuals Who Give a High Priority to Resource Protection 

Various individuals and groups at the local, regional, and national levels are interested in the 

ways BLM manages public lands. Many of these concerns regard wildlife and wildlife habitat, 

special status plant species and habitat, water quality, and visual quality. They value BLMadministered land for wildlife, recreation, education, scenic qualities, wilderness, and open 

space, among other reasons. Their concerns include preserving healthy ecosystem and plant 

communities, protection of rare plant species, need for designating more ACECs, and the 

effects of oil and gas development, wind energy, residential development on adjacent lands and 

motorized access. 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-267

3.32.1.3.4 Groups and Individuals Who Give a High Priority to Resource Use 

Many individuals and groups are concerned about limitations on the availability of public lands 

for commercial uses, such as livestock grazing and mineral or energy development. They 

indicate that the public lands have to be managed to be as productive as possible and the 

survival of local economies and local communities depend upon these industries. Some of the 

comments received during scoping indicated concerns about stipulations, restriction and delays 

on oil and gas development, support for wind energy development and timber harvest, and a 

desire for reasonable access. 

3.32.1.3.5 Small Communities 

Small communities can be tied to BLM and public lands in a variety of ways. Local businesses 

and governments depend upon BLM employees to support businesses and public services, 

while use of public lands for recreation activities, livestock grazing, minerals or energy 

development, and other activities can provide economic and leisure-time opportunities. Area 

residents are concerned about young people and families leaving the area to seek employment 

elsewhere, declining farm populations, local business closings, and lack of funds for public 

services resulting from the declining tax base. 

Comments received during scoping include: want to see new economic opportunities for jobs, 

tax revenue for schools, services and infrastructure, concern about increasing residential 

development, concerns with non-locals overriding local interests, and private property rights on 

lands adjacent to public lands.

3.32.1.3.6 Wild Horse Advocates 

Various individuals and groups at the local, regional and national level are very interested in 

the welfare of the wild horses on the Pryor Mountain Wild Horse Range. A visitor center, the 

Pryor Mountain Wild Mustang Center is located in Lovell, Wyoming, and the herd and range 

are an important part of that community’s identity. Comments received during scoping 

included: want to see the wild horses and their areas left alone, people from all over the world 

and all walks of live come to see the horses---and spend their money, promote the use of land 

so the herd can sustain larger numbers, end roundups, work with NPS and USFS to expand the 

range, and provide responsible viewing opportunities for the public. 

3.32.1.3.7 American Indian Tribes 

Two Reservations are located in the vicinity of the Billings RMP planning area: the Crow 

Reservation in Big Horn County, Montana, and the Northern Cheyenne Reservation that is 

located directly to the east of the Crow Reservation in Rosebud County, Montana. Other 

federally recognized tribes in and adjacent to Montana with an affinity to the planning area 

include: 

 Fort Peck Indian Reservation, Montana (Assiniboine and Sioux Tribes) 

 Blackfeet Indian Reservation, Montana (Blackfeet Tribe) 

 Rocky Boy’s Indian Reservation, Montana, (Chippewa-Cree Tribe) 

 Fort Belknap Reservation, Montana (Fort Belknap Indian Community) 
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3-268 Chapter 3: Affected Environment

 Wind River Reservation, Wyoming (Eastern Shoshone and Northern Arapaho 

Tribes) 

 Cheyenne River Indian Reservation, South Dakota (Cheyenne River Sioux Tribe) 

 Rosebud Indian Reservation, South Dakota (Rosebud Sioux Tribe) 

 Pine Ridge Indian Reservation, South Dakota (Ogalala Sioux Tribe) 

 Fort Berthold Indian Reservation, North Dakota (Three Affiliated Tribes) 

 Turtle Mountain Indian Reservation, North Dakota (Turtle Mountain Band of 

Chippewa) 

 Spirit Lake Indian Reservation, North Dakota (Spirit Lake Sioux Tribe) 

 Standing Rock Indian Reservation, North Dakota & South Dakota (Standing Rock 

Sioux Tribe) 

 Fort Hall Indian Reservation, Idaho (Shoshone-Bannock Tribes) 

 Nez Perce Tribe 

 Confederated Tribes of the Umatilla Reservation 

 Confederated Tribes of the Colville Indian Reservation 

 Kiowa Tribe 

American Indian traditionalists have maintained connections to places containing edible and 

medicinal plants, rock art, grave sites, and places used for tree platform “burials,” mineral and 

plant products used in rituals or for paints, and vision quest stations. They are also interested in 

visiting the sites of battles, old trading posts, and ghost towns to learn more about these aspects 

of their history. Currently, through a project led by Big Horn Canyon National Recreation 

Area in cooperation with the Northern Cheyenne and Crow tribal colleges, young American 

Indians are participating in archeological excavation as a means of maintaining connections to 

their tribal history and acquiring marketable skills. 

Concerns received during scoping included protection for: edible and medicinal plants, rock art 

sites, grave sites, mineral and plant products used in rituals or for paints, and vision quest sites. 

3.32.1.3.8 Indian Trust Resources 

Indian Trust Resources are legal interests in assets held in trust by the federal government for 

federally recognized Indian tribes or nations or for individual Indians. These assets may be real 

property, physical assets, or intangible property rights. Examples include land, minerals, water 

rights, hunting and fishing rights, other natural resources, money, or claims. Federal laws and 

guidance that may apply to Indian Trust Resources in the conditions of the RMP include, but 

are not limited to, the American Indian Religious Freedom Act, Native American Graves 

Protection and Repatriation Act, Indian Sacred Sites, and Secretarial Order 3206. Indian Trust 

Resources located on the Crow and Northern Cheyenne Indian Reservations are managed and 

protected by the tribes. Indian Trust Resources located on lands administered by the BLM are 

managed and protected by the BLM; however, no Indian Trust Resources have been identified 

on BLM administered lands in the planning area. However, the Montana/Dakotas BLM 

currently holds ownership of a number of water rights held in trust for the Crow Tribe. The 

BLM acquired these trust resources as a result of land exchanges that occurred under the Crow 
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Chapter 3: Affected Environment 3-269

Boundary Settlement Act. The water rights are currently located on lands owned by the Crow 

Tribe. 

3.32.1.3.9 Tribal Treaty Rights 

Laws, Regulations, and Policies

BLM coordination or consultation with Native Americans, as it pertains to treaty rights and 

trust responsibility, is conducted in accordance with the following direction: 

 Bureau Handbook H-8120-1 – General Procedural Guidance for Native American 

Consultation (December 3, 2004). Executive Order No. 13084 – Consultation and 

Coordination with Indian Tribal Governments, May 14, 1998. 

 Government-to-Government Relations with Native American Tribal Governments 

(Memorandum signed by President Clinton; April 29, 1994). 

 Order No. 3175 – Departmental Responsibilities for Indian Trust Resources (Section 2 of 

Reorganization Plan No. 3 of 1950 – 64 Stat. 1262; November 8, 1993). 

Treaties are negotiated contracts made pursuant to the Constitution of the United States and are 

considered the “supreme law of the land.” They take precedence over any conflicting state 

laws because of the supremacy clause of the Constitution (Article 6, Clause 2). Treaty rights 

are not gifts or grants from the United States, but are bargained-for concessions. These rights 

are grants-of-rights from the tribes, rather than to the tribes. The reciprocal obligations 

assumed by the Federal government and Indian tribes constitute the chief source of present-day 

Federal Indian law. 

The federal government has a unique and distinctive political relationship with federally 

recognized Indian tribes. It is defined by treaties, statutes, executive orders, judicial decisions 

and agreements and differs from relationships with state and local governments or other 

entities. It has given rise to a special federal trust responsibility, involving the legal 

responsibilities and obligations of the United States toward Indian tribes and the application of 

fiduciary standards of due care with respect to Indian lands, tribal trust resources and the 

exercise of tribal rights. 

The United States and represented agencies, including the BLM, have a special trust 

relationship with Indian tribes because of these treaties. As a Federal land managing agency, 

the BLM has the responsibility to identify and consider potential impacts of BLM plans, 

projects, programs, or activities on Indian trust resources (e.g., fish, game, and plant resources–

see Glossary). When planning any proposed project or action, the BLM must ensure that all 

anticipated effects on Indian trust resources are addressed in the planning, decision, and 

operational documents prepared for each project. The BLM also has the responsibility to 

ensure that meaningful consultation and coordination concerning tribal treaty rights and trust 

resources are conducted on a government-to-government basis with federally recognized tribes. 

Native American Indians inhabited north-central Montana, including the lands now managed 

by the Billings Field Office, for thousands of years prior to European contact. They hunted, 

fished, gathered plant foods, buried their dead, and conducted religious ceremonies on lands 
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3-270 Chapter 3: Affected Environment

within the planning area since time immemorial. The lands managed by the Billings Field 

Office are within the historical use area/aboriginal territories of the Crow Tribe of the Crow 

Reservation, the Northern Cheyenne Tribe of the Northern Cheyenne Reservation, the Eastern 

Shoshone of the Wind River Reservation in Wyoming, and the Shoshone-Bannock of the Ft. 

Hall Reservation in Idaho. All tribes continue to express interest in and concern over, public 

lands and cultural/natural resources within the planning area. 

During the 1850s and 1860s, treaties were negotiated with the tribes in the northwestern 

United States in order to acquire Indian lands for homesteading. The settlement of the 

northwestern United States by non-Indians led to the collapse of the Tribal Nations as 

they were previously known, including their economic, social, cultural, religious, and 

governmental systems. 

 

Examples of these treaties include the Treaty of Ft. Laramie with Sioux, etc., 1851. On 

September 17, 1851 a treaty was signed at Ft. Laramie, Indian Territory, between the United 

States and many of the Plains Indian Tribes including the Sioux, Cheyenne, Arapaho, Crow, 

Assiniboine, Gros Ventre, Mandan, and Arikara. Article 2 of the treaty states, “The aforesaid 

nations do hereby recognize the right of the United States Government to establish roads, 

military and other posts, within their respective territories”. Article 5 of the treaty delineated 

the boundaries of established “territories” for each of the tribes, and further stated, “It is, 

however, understood that, in making this recognition and acknowledgement, the aforesaid 

Indian nations do not hereby abandon or prejudice any rights or claims they may have to other 

lands; and further, that they do not surrender the privilege of hunting, fishing, or passing over 

any of the tracts of country heretofore described.” 

Subsequent treaties established formal reservations. On May 7, 1868, at Ft. Laramie, 

Dakota Territory, the Crow Tribe and the United States signed the Treaty with the Crows, 

1868. In accordance with the treaty, the tribe relinquished ownership to millions of acres 

of land in Montana and Wyoming territories to the United States, and was guaranteed a 

permanent homeland which has become known as the Crow Reservation in south central 

Montana. Article 4 of the treaty also states, “The Indians herein named agree, when the 

agency-house and other buildings shall be constructed on the reservation named, they 

will make said reservation their permanent home, and they will make no permanent 

settlement elsewhere, but they shall have the right to hunt on the unoccupied lands of the 

United States so long as game may be found thereon, and as long as peace subsists 

among the whites and Indians on the borders of the hunting districts." 

On May 10, 1868, at Ft. Laramie, Dakota Territory, the Northern Cheyenne and Northern 

Arapaho tribes and the United States signed the Treaty with the Northern Cheyenne and 

Northern Arapaho, 1868. In accordance with the treaty the tribes relinquished ownership to 

millions of acres of land, and was guaranteed a permanent homeland, “And they do solemnly 

agree that they will not build any permanent homes outside of said reservations, and that within 

one year from this date they will attach themselves permanently either to the agency provided 

for near the mouth of Medicine Lodge Creek, or to the agency about to be established on the 

Missouri River, near Fort Randall, or to the Crow agency near Otter Creek, on the Yellowstone 

River, . . . . . . and it is hereby expressly understood that one portion of said Indians may attach 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-271

themselves to one of the afore-mentioned reservations, and another portion to another of said 

reservations, as each part or portion of said Indians may elect.” Article 2 of the treaty also 

states, “And the Northern Cheyenne and Arapaho Indians do hereby relinquish, release, and 

surrender to the United States, all right, claim, and interest in and to all territory outside the two 

reservations above mentioned, except the right to roam and hunt while game shall be found in 

sufficient quantities to justify the chase.”

On July 3, 1868, the Eastern Band Shoshone and Bannock Tribes and the United States signed 

the Treaty with the Eastern Band Shoshoni and Bannock, 1868, commonly known as the Fort 

Bridger Treaty (15 Stat. 673). In the Fort Bridger Treaty, the Tribes relinquished ownership of 

approximately 20 million acres to the United States, and were guaranteed a permanent 

homeland, which has become known as the Fort Hall Indian Reservation in southeastern Idaho. 

Article 4 of the treaty also retains the Tribes’ rights to hunt, fish, and gather natural resources, 

and provides other associative rights necessary to effectuate these rights on the unoccupied 

lands of the United States. 

Since the BLM manages portions of the “unoccupied lands” that are within the traditional use 

areas of these tribes, the BLM has a trust responsibility to provide the conditions necessary for 

Indian tribal members to exercise their treaty rights. Treaty rights in the planning area are 

extended not only to the tribes within and adjacent to the planning area, but also to other 

federally recognized tribes, which may have treaty language that extends their rights to lands in 

this area. 

Currently, no Native American tribes are dependent on commodity resources from lands 

managed by the Billings Field Office for their economic livelihood. Tribal treaty rights 

pursued on public lands within the Billings Field Office may include gathering various natural 

resources for both cultural/religious and medicinal purposes. Currently, there is little specific 

information available on the exact species sought or locations used by Native Americans 

exercising their treaty rights within the boundaries of the planning area. Areas and natural 

features within the planning area may also be used for ceremonial/religious purposes in 

accordance with the American Indian Religious Freedom Act. However to date, there have 

been no areas or resources formally identified as Traditional Cultural Properties (TCPs). 

3.32.1.3.10 Environmental Justice 

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations, states “each Federal agency shall make achieving 

environmental justice part of its mission by identifying and addressing, as appropriate, 

disproportionately high and adverse human health or environmental effects of its programs, 

policies, and activities on minority populations and low-income populations...” (Executive 

Order 12989) (Table 3-75).

Minority populations as defined by Council on Environmental Quality (CEQ) guidance under 

the National Environmental Policy Act (CEQ 1997) include individuals in the following 

population groups: American Indian or Alaskan Native; Asian or Pacific Islander; Black, not of 

Hispanic origin; or Hispanic. A minority population is identified where “(a) the minority 

population of the affected area exceeds 50 percent or (b) the minority population percentage of 
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Proposed Resource Management Plan and Final Environmental Impact Statement 

3-272 Chapter 3: Affected Environment

the affected area is meaningfully greater...” (CEQ 1997). Additionally, “[a] minority 

population also exists if there is more than one minority group present and the minority 

percentage, as calculated by aggregating all minority persons, meets one of the above-stated 

thresholds” (CEQ 1997). Low-income populations are determined by the U.S. Census Bureau 

based upon poverty thresholds developed every year. 

U.S. Census data is used to determine whether the populations residing in the study area 

constitute an “environmental justice population” through meeting either of the following

criteria: 

 At least one-half of the population is of minority or low-income status; or 

 The percentage of population that is of minority or low-income status is at least 10 

percentage points higher than for the entire State of Montana (for the counties in 

Montana) or the entire State of Wyoming (for counties in Wyoming). 

Data for the identification of low-income is from the U.S. Census Bureau, Small Area Income 

and Poverty Estimates (SAIPE). The SAIPE program produces yearly single year poverty 

estimates for states, counties, and school districts and is considered the most accurate for these 

geographic scales, especially for areas with populations of 65,000 or less (U.S. Census 2014). 

Minority populations are identified using the U.S. Census Population Estimates program which 

provides estimates for the resident population by age, sex, race, and Hispanic origin at the 

national, state and county scales. Total minority population refers to that part of the total 

population which is not classified as Non-Hispanic White Only by the U.S. Census Bureau. By 

using this definition of minority population, the percentage is inclusive of Hispanics and 

multiple race categories and any other minority single race categories. This definition is most 

inclusive of populations that may be considered as a minority population under EO 12898. 

Estimates from SAIPE and the Population Estimates program are used in federal funding 

allocations. 

For this planning effort the identification of environmental justice populations is conducted at 

the county level due to the large geographic area. The 2013 data provided in Table 3-75

indicates that there are both minority and poverty populations in Big Horn County, Montana 

that meet the criteria to be identified as environmental justice populations. American Indians 

make up a majority of the population in Big Horn County, Montana, in part due to the Crow 

Reservation being located there. Overall, the planning area does have at least one county that 

meets the criteria for environmental justice populations and therefore outreach and 

collaborative efforts with these environmental justice populations should be conducted. 

Table 3-75 Environmental Justice Information for the Planning Area by County, 2013 

Race Alone1

Geography

% 

White

% Black 

or 

African 

American

% American 

Indian and 

Alaska 

Native

% 

Asian

% Native 

Hawaiian 

and Other 

Pacific 

Islander

% Two 

or More 

Races1

% 

Hispanic 

or 

Latino1

% Total 

Minority2

% 

Poverty, 

All 

Ages3

Montana 89.5% 0.6% 6.5% 0.8% 0.1% 2.5% 3.3% 13.0% 16.1%

Big Horn 

County, MT 31.6% 0.4% 64.8% 0.5% 0.0% 2.7% 5.0% 70.3% 27.6%
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Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-273

Carbon 

County, MT 96.9% 0.4% 1.1% 0.4% 0.0% 1.2% 2.3% 5.1% 12.6%

Golden 

Valley 

County, MT 95.1% 0.3% 1.0% 0.7% 0.0% 2.8% 4.0% 8.1% 19.6%

Musselshell 

County, MT 95.7% 0.5% 1.5% 0.3% 0.0% 1.9% 3.2% 6.9% 17.0%

Stillwater 

County, MT 96.4% 0.3% 1.0% 0.4% 0.0% 1.9% 3.2% 6.3% 9.5%

Sweet Grass 

County, MT 96.8% 0.2% 0.6% 0.6% 0.0% 1.8% 1.7% 4.7% 12.2%

Wheatland 

County, MT 95.5% 0.4% 0.8% 0.5% 0.0% 2.8% 1.7% 6.0% 19.7%

Yellowstone 

County, MT 91.5% 0.8% 4.3% 0.7% 0.1% 2.7% 5.1% 12.6% 12.9%

Wyoming 92.7% 1.7% 2.6% 0.9% 0.1% 1.9% 9.7% 15.9% 10.9%

Big Horn 

County, WY 95.4% 1.5% 1.3% 0.5% 0.0% 1.3% 8.8% 12.5% 11.2%

Park County, 

WY 95.4% 1.5% 0.8% 0.8% 0.1% 1.5% 5.8% 9.9% 10.0%

Note:

Sources: 1 U.S. Census Bureau, Population Division, 2014

 

2Total minority is calculated from the above data source using the formula: (total population minus non-Hispanic White only population) divided by total 

population.

 

3U.S. Census Bureau, Small Area Income and Poverty Estimates (SAIPE) Program, 2014.

3.32.2Economic Conditions 

The area of local economic influence consists of eight counties in south central Montana (Big 

Horn, Carbon, Golden Valley, Musselshell, Stillwater, Sweet Grass, Wheatland, and 

Yellowstone) and two counties (Big Horn and Park) in north central Wyoming. The ten-county 

area of economic influence in Montana is referred to as the “local economy.”

BLM-administered lands consist of approximately 434,154 surface and 889,479 subsurface 

acres for which the BLM makes land use decisions covered by this RMP. A majority of the 

BLM-administered surface lands and minerals, as well as related land uses, are located in 

Carbon and Musselshell Counties. BLM administered lands within the Planning Area accounts 

for approximately four percent of the total land area, and BLM-managed mineral estate 

accounts for about eight percent of the mineral estate within the planning area boundaries. 

Table 3-76 and the Land and Realty section of this chapter provide a detailed assessment of 

land and mineral ownership in the planning area by county. 

During the last century, ranching, farming, mining, oil and gas development, transportation, 

and the emergence of Billings as a regional trade and service centers have all been important 

factors in the local social and economic history of the area. Billings, near the center of the 

Planning Area is the largest population, business, and service center in the planning area and 

the state. Two major travel corridors, I-90 and I-94, converge in Billings, which also has the 

largest airport, medical center, business, and shopping hub in the state and region. 
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3-274 Chapter 3: Affected Environment

3.32.2.1 Demographic and Economic Characteristics and Trends 

The following section provides a summary of economic indicators that could be affected by 

BLM management actions. Potential economic effects associated with the proposed RMP 

revision include anticipated changes in employment, income, public revenues, economic 

dependency, and economic stability. The information in this section is presented to help clarify 

economic issues, describe relevant economic trends, and to provide context for potential 

economic impacts. 

The Planning Area covers about 12 percent of Montana’s land area; contains 19 percent of the 

state’s population, 20 percent of the state’s employment, and 21 percent of the state’s personal 

income. About 70 percent of the state’s industries are in the planning area’s economy. Golden 

Valley County has the fewest industries and is the least diverse, while Yellowstone County has 

the most industries and is the most diverse (Table 3-77). 
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Chapter 3: Affected Environment 3-275

Table 3-76 BLM Surface and Mineral Estate and Major BLM Land/Mineral Uses within the Billings RMP Planning Area (in 

acres) 

County

BLM Public 

Lands 

(surface)

BLM Percent 

of Total 

Surface

BLM- Federal 

Mineral Estate

BLM Percent of 

Total Mineral 

Estate Major Population Center(s) and BLM Land/Mineral Uses

Big Horn, MT 7 0% 1.015 0% Hardin

Big Horn, WY 4,298 NA 4,298 NA Recreation, livestock grazing

Carbon Co. 220,556 13% 341,380 38%

Red Lodge, oil/gas leasing and production, bentonite production, recreation use, 

livestock grazing, rights-of-way, chemical limestone production

Golden Valley 7,943 1% 44,360 5% Livestock grazing, oil/gas leasing and production, recreation

Musselshell 101,247 7% 226,885 26%

Roundup, recreation use, coal mining, oil/gas leasing and production, livestock 

grazing, timber

Stillwater 5,504 0% 58,359 7%

Columbus, recreation, oil and gas leasing and production, timber, rights-of-way, 

livestock grazing

Sweet Grass 15,893 1% 75,229 8%

Big Timber, , recreation, oil and gas leasing and production, timber, rights-of-way, 

livestock grazing

Wheatland 1,333 0% 21,433 2% Harlowton

Yellowstone 77,373 4% 116,517 13% Billings, Laurel, recreation use, livestock grazing, rights-of-way, oil and gas leasing

Park, WY NA NA NA NA Cody, Powell

Planning Area 434,154 4% 889,479 8%

Billings, Laurel, Cody, Powell, Red Lodge, Columbus, Hardin, and Round Up, oil/gas 

leasing and production, bentonite production, recreation use, livestock grazing, 

rights-of-way

Note: 

Source: BLM Annual Report (2008) 
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Table 3-77 Selected Economic Statistics, 2012 

County

Area

(Sq. Miles) Employment

Number of 

Industries/ 

Sectors

Average 

Household 

Income

Total Personal

Income

(millions)

Montana 145,556 634,895 344 $84,562 $37,562

10-County Area 27,904 155,363 252 $92,563 $9,457

Big Horn, MT 5,003 6,486 111 $84,725 $361

Carbon 2,052 5,250 134 $76,540 $367

Golden Valley 1,177 640 47 $88,781 $35

Musselshell 1,870 2,540 100 $65,787 $145

Stillwater 1,798 5,412 122 $84,977 $342

Sweet Grass 1,858 2,672 107 $68,087 $112

Wheatland 1,426 1,286 75 $69,765 $67

Yellowstone 2,640 103,727 225 $94,977 $6,281

Big Horn, WY 3,137 7,042 123 $82,283 $397

Park, WY 6,943 20,307 161 $104,407 $1,350

Note: 

Source: IMPLAN (2012) 
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Chapter 3: Affected Environment 3-277

3.32.2.2 BLM Land and Mineral Uses that Affect the Local Economy 

Local economic activity and desired economic conditions are influenced by BLM land use 

decisions and associated land uses. Surface and mineral estate and major BLM land/mineral 

uses by county are displayed in Table 3-76. The following narrative description summarizes 

major BLM land and mineral uses within the planning area.

3.32.2.2.1 Livestock Grazing and Production 

Ranching is an important part of the history, culture, and economy of the Planning Area. 

Grazing is allowed on BLM lands for the purpose of fostering economic development for 

private ranchers and ranching communities by providing ranchers access to additional forage 

(GAO, Sept. 2005). Livestock grazing on BLM lands is authorized on an annual basis. 

Authorized (actual) use of AUMs varies from year to year due to factors such as drought, 

wildfire, financial limitations on operators, grazing transfers, and implementation of grazing 

management to improve range conditions. 

Between 1999 and 2009, billed grazing use averaged 42,931 Animal Unit Months (AUMs) per 

year. BLM issues grazing permits and leases to about 310 livestock operators in the planning 

area. Livestock grazing on BLM lands involves livestock operators who have Section 3 grazing 

permits (i.e., grazing on public lands within grazing districts, BLM Manual 1373.12) and 

Section 15 grazing leases (grazing on public lands outside the original grazing district 

boundaries). On public domain lands, 50 percent of revenues from Section 15 grazing fees on 

public domain lands are distributed to the state/counties; 12.5 percent of grazing fees from 

Section 3 permits are distributed to the state/counties. On lands acquired under the Bankhead 

Jones Land Utilization Act (LU lands), 25 percent of grazing revenues are distributed to the 

counties. Approximately 74 percent of the public lands administered by the BLM are public 

domain lands; 24 percent are acquired lands administered under the Bankhead Jones Land 

Utilization Act. Annual revenues to the federal government average about $62,000 given a 

2013 BLM grazing fee of $1.35 per AUM plus 6.5 percent for late fees, surcharge, transfer fees 

etc.; annual payments to the counties would average about $10,000. Average annual billed 

livestock grazing between 1999 and 2009 is shown in Table 3-78. 

Table 3-78 Average Annual Authorized Livestock Grazing Use (AUMs), Billing Years 

1999-2009 

Section 3* Section 15** Total Cattle/Horses Sheep/Goats

11-Year Average 38,334 4,597 42,931 42,771 160

Note: 

Source: Range Administration System, 2010 

* Section 3 of the Taylor Grazing Act concerns grazing permits issued on public lands within the grazing districts established 

under the Act. 

** Section 15 of the Taylor Grazing Act concerns issuing grazing leases on public lands outside the original grazing district 

boundaries. 

BLM contributes about one percent of the total livestock forage needs in the planning area. 

BLM’s forage contribution is greatest in Musselshell, Carbon, and Yellowstone counties; 

however, in none of these counties does the BLM contribution exceed five percent of total 

forage needs. 
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Cattle are the most prevalent class of livestock that graze on BLM land, although sheep, horses, 

and burros are authorized to graze in 10 allotments. Livestock operations are primarily cow/calf 

operations. Most calves are born in late winter through spring on private lands. Cattle are 

turned out to graze as cow/calf pairs. Calves have historically been weaned in the fall or early 

winter and most leave the region to be grown out and/or fed in other parts of the US. At 

weaning, most cows have been taken to winter pasture where they remain until they calve the 

following year. An estimated 83 percent of total cattle and calves inventory within the planning 

area are marketed each year (2007 Census of Agriculture). 

Roughly 70 percent of all agricultural products marketed are livestock related and the BLM 

provides less than one percent of the total forage requirements for the livestock inventory 

within the planning area. By assuming a direct relationship between the percent of agricultural 

products that are livestock-related and the percent of agricultural related employment that is 

associated with livestock production, it is estimated that BLM livestock grazing contributes 

about 71 total jobs to the local economy. It is estimated that about $974,000 in total wage and 

proprietor’s income is related to BLM livestock grazing within the planning area (IMPLAN 

2012). 

BLM’s grazing fee is established by formula and is generally lower than fees charged by the 

other agencies or private ranchers who set fees to obtain the market value of forage. 

Livestock operations in the planning area often involve large tracts of land and ranchers depend 

on a mix of private and federal lands to graze cattle seasonally. None are wholly dependent on 

forage coming from public lands. 

To qualify for a BLM grazing permit/lease, an operator must be able to accommodate his/her 

livestock for a specified period of time on private land owned or controlled (base property) 

apart from the public land (43 CFR 4110). It is rare for dependence on public land forage to 

exceed 50 percent, and many operators depend on public lands for less than 20 percent of their 

total forage needs. However, operations may depend heavily on forage from public lands 

during a specific season (operators graze public land in the spring through fall for five to seven 

months and winter their livestock on base property).

BLM grazing permits are valuable to livestock producers because the grazing fees are very 

favorable, and land is often available when private hay meadows is being grown to provide 

forage for the winter. The 2013 BLM grazing fee of $1.35 is considerably lower than the 2013 

private statewide average of $21.00 per AUM (USDA, National Agricultural Statistics Service, 

2014). 

Access to BLM grazing may be important to area livestock producers even though additional 

management costs are usually incurred to use these lands. According to a 2005 Government 

Accounting Office (GAO) report on livestock grazing, “Fees charged by private ranchers and 

state land agencies are higher than the BLM and Forest Service fees because, generally, 

ranchers and state agencies seek to generate grazing revenues by charging a price that 

represents market value for that land and/or the services provided.” 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-279

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. Mining of private 

minerals include these same minerals as well as coal, sand and gravel, and platinum group 

minerals. Aggregated mining sectors (industry sectors 20-30) support approximately 6,060 total 

jobs and $498.0 million in labor income within the planning area (IMPLAN 2012). About 47 

percent of the jobs and labor income in the mining sectors are associated with oil and gas 

related activities and 53 percent of the employment and income is associated with the other 

mining sectors (IMPLAN, 2012). The Stillwater mine (platinum and palladium) and Bull 

Mountains Mine No.1 (coal) are the largest mines in the planning area. The amounts of federal 

minerals and the dependency of local economies on BLM-managed federal mineral production 

vary among the counties. 

3.32.2.2.3 Oil and Gas 

In March 2011, BLM had leases in effect covering 149,829 acres within the Billings Field 

Office boundaries. Annual lease rent is paid on 133,885 acres that are not held by production 

on leases with oil/gas being produced from one or more wells. Lease rent was not paid on 

15,955 acres that were held by production. Instead, royalties are paid on oil and gas production 

from these leases. Leasing has been deferred on additional acres pending completion of the 

RMP and site specific environmental review. More Federal leases and more acres were leased 

in Carbon County than any other county in the Planning Area. 

In 2011, leasing and production of federal minerals occurred in every county within the 

planning area except Big Horn and Wheatland (USDI, ONRR, 2011). Most Federal oil 

production occurs in Carbon County; with much smaller amounts in Musselshell, Stillwater, 

and Yellowstone Counties. The only reported natural gas production from Federal minerals 

within the Planning Area also occurs in Carbon County. While some gas production from 

Federal minerals does occur in Big Horn County, Montana, this comes from the mineral estate 

managed by the Miles City BLM office that is not part of this RMP. 

Local oil and gas exploration, development, and production as well as gas pipeline transmission 

industry all support jobs and income in the local economy. Local contractors, as well as 

regional firms from Miles City and Park County, Wyoming, provide most of the contract 

services to local oil and gas fields. Between 1990 and 2008, there has been an average of one 

producing well and one dry hole drilled annually on federal minerals within the Planning Area. 

Currently there are 9 producing gas wells and 60 producing oil wells.

A portion of the revenues collected by the federal government is distributed to the state and 

counties. The amount that is distributed is determined by the federal authority under which the 

federal minerals are being managed. The leased acres changes daily as leases expire and other 

parcels are leased. Generally, within the planning area, public domain federal minerals account 

for about 58 percent of the acres leased; Bankhead-Jones lands account for about 41 percent of 

acres leased; and the other authorities for acquired minerals account for less than 1% of federal 

leased acres (BLM, LR 2000). 

Forty-nine percent of these federal leasing revenues from public domain minerals are 

distributed to the state and the state distributes 25% back to the counties (Title 17-3-240, 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

3-280 Chapter 3: Affected Environment

Montana Code Annotated). Twenty-five percent of the federal leasing revenues are distributed 

to the counties on federal minerals administered under the Bankhead-Jones Act.

3.32.2.2.4 Coal 

Currently there are no mines producing coal from federal minerals. However, Signal Peak 

Energy applied in 2008 to lease approximately 61 million tons of federal coal beneath 2,680 

acres about 10 miles southeast of Roundup straddling Musselshell and Yellowstone counties. 

The federal coal in question is within the company’s existing mine plan and would be mined 

along with adjacent, nonfederal coal. Signal Peak is operating an underground mine that is 

expected to produce an annual average of 11.910 MM tons per year and has an expected life of 

16 years. There is an estimated 37 million tons of recoverable federal coal. 

Revenues associated with federal coal production would include coal lease bonus bids, annual 

rent, Abandoned Mine Reclamation Tax, Black Lung Disease Tax, production royalties, 

Montana Coal Severance Tax, Montana Resource Indemnity Trust Tax, and the Local Gross 

Proceeds Tax.

3.32.2.2.5 Other Minerals 

Other federal minerals produced include sand and gravel (average 6,500 cu. yd/year @ 

$0.75/yd3); building stone (average 10 tons/yr. @ $7.50/ton); and bentonite (average 517,000 

tons/year @ $60/ton). No revenues in the form of leases, rents, or federal or state royalties are 

collected on the production of these minerals. However, Montana has a Montana Bentonite 

Production Tax that is equal to $1.50 per ton of bentonite produced. Production of federal 

bentonite generates an estimated $396,000 for this tax annually. After 2014, 77.95 percent of 

this tax revenue will be disbursed to the counties of production (Title 15-39-101 MCA). 

Currently, an estimated $309,000 of this is disbursed to Carbon County per year. Mining 

platinum-group metals at the Stillwater mine involves private minerals and is not related to 

BLM mineral management. 

3.32.2.3 Economic Contributions

Total employment and labor income related to BLM managed minerals averages about 193 

jobs and almost $9.3 million per year in labor income. Aggregated mining sectors (industry 

sectors 20-30) support approximately 6,060 total jobs and $498 million in labor and proprietor 

income within the 10-county local economy (IMPLAN 2012). About half of the jobs and 

income are associated with oil and gas exploration, development, and production (IMPLAN 

2012). The amounts of federal minerals and the dependency of local economies on that 

production vary among the counties. Carbon County has the only federal natural gas production 

and the largest amount of federal oil production.

Mineral and energy development is closely linked to fiscal conditions of local governments and 

school districts through contributions to local property-tax base, oil/gas production taxes, and 

federal mineral royalty payments on production from public mineral estate. Federal oil and gas 

leases generate a one-time lease bid as well as an annual rental. The bonus bid averaged $12.54 

per acre (2005-2010); lease rental is $1.50 per acre per year for the first five years and $2.00 

per acre per year thereafter. Annual lease rentals continue until one or more wells are drilled 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-281

that result in production and associated royalties. Half of these federal leasing revenues are 

distributed to the state and the state distributes a portion back to the counties. 

Oil and gas production in Montana is not subject to ad valorem, or property taxes; rather it is 

subject to production taxes. Federal oil and gas royalties generally equal 12.5 percent of the 

value of production. With production from public domain minerals, half of these royalties are 

distributed to the state, of which 25 percent is distributed back to the county of production 

(Title 17-3-240, MCA). Twenty-five percent of the royalties are distributed to the counties on 

federal minerals administered under the Bankhead-Jones Act. The annual average revenue from 

oil, gas, and bentonite production disbursed to the counties is about $890,000. 

3.32.2.4 Recreation Use

The economic influence of recreation use is related to the amount of recreation use on public 

lands and related local expenditures for such items as gasoline, lodging, meals, and supplies. To 

understand the local/regional economic influence of recreation use, it is important to 

understand what recreation activities occur on public lands because local/regional expenditures 

vary depending on the type of activity, whether the recreation use is from local residents or 

non-local residents, and whether the activity involves overnight stays. Local/regional 

expenditures related to recreation use support local/regional employment and labor income 

(standard economic indicators). Generally, employment related to recreation and tourism tends 

to be seasonal and relatively low paid, with a high portion of the labor force self-employed. The 

recreation opportunities available in the Planning Area play an important role in the quality of 

life of some local residents, as well as attracting visitors from elsewhere in the state and region. 

BLM public lands in the Planning Area received an estimated 218,000 recreation visits in FY 

2010. Pompeys Pillar National Monument received an additional 43,500 visits in FY 2010 

(BLM, RMIS, 2010). 

Nature-related recreation activities on BLM lands, e.g. fishing, hunting, and other wildlife 

related recreation use account 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. Recreation and tourism is not 

classified or measured as a standard industrial category. Components of recreation and tourism 

activities are instead captured in other industrial sectors, primarily the retail sales and services 

sectors. It is assumed that recreation-related expenditures would be split among the following 

economic sectors: lodging, restaurants, groceries, gas/oil, other transportation, activities, 

admissions/fees, and souvenirs. 

An annual total of 261,500 local and non-local visits support an estimated 136 local jobs and 

$3.9 million in labor income within the local economy. Government revenues received from 

the recreation program are associated with recreation use permits issued. In Fiscal Year 2009, 

recreation use permits and associated total annual federal revenue was about $47,000. None of 

these revenues from the Billings Field Office and Pompeys Pillar National Monument are 

distributed to the state or counties.

Pompeys Pillar National Monument (PPNM): PPNM received an estimated 36,000 visits in 

2009. This included about 1,800 school children and 26,600 other visits when the interpretative 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

3-282 Chapter 3: Affected Environment

center was open during the summer tourist season. It is estimated that PPNM received an 

additional 7,500 visits after hours and during the off season. Based on a BLM survey conducted 

in 2009, it is estimated that 65 percent of visitors are non-local (those visitors living more than 

50 miles from the site). Average party size for non-local visits was 2.7 people and average 

expenditure per party trip was $307.77. Visitor use fees collected at PPNM in Fiscal Year 2009 

were about $35,000. 

The estimated annual economic contribution to Yellowstone County of total annual visitation at 

PPNM is $1.79 million in total non-resident expenditures, 27 total jobs, and $822,000 in labor 

and proprietor’s income. The estimated annual economic contribution from BLM management 

in 2009 was 16 total jobs and $467,000 in total labor and proprietor’s income in Yellowstone 

County. The combined estimated annual economic contribution from visitation and BLM 

management to Yellowstone County is 43 jobs and $1.289 million in labor and proprietor’s 

income. This is less than one tenth of one percent of Yellowstone County employment and 

income.

3.32.2.5 Timber Harvest 

Timber harvest from BLM lands within the Planning Area is relatively small. Forest products 

harvested and sold are summarized in Table 3-79. Four percent of revenue from salvage sales 

and from timber sales on public domain lands goes to the state. 

Table 3-79 Forest Products Harvested and Sold in the Billings Field Office (1994-2008) 

Forest Product Unit Total Volume Average/Year Average Price/Unit Total

Saw timber: Douglas-fir & 

lodgepole pine ccf 2,522 180 $ 38/ccf $95,380 

Pulp wood ccf 1962 131 $ 1.00/ton $150 

Post and pole ccf 23.675 2

Biomass ccf 14,400 960 $ .01/ton $3.00 

Juniper lbs 16,530 1,102 $ .05/lb $100 

Fuelwood ccf 12 1 $ 5.00/cord $400 

Christmas Trees ea 0 0

3.32.2.6 Realty, Cadastral Survey, and Lands Actions 

InIn 2007, the BLM issued or renewed eight rights-of-way for infrastructure in support of 

economic activities within the Planning Area. Year 2007 is representative of the annual BLM 

rental revenues received for federal rights-of-way. These rights-of-way covered almost 6,097 

acres and the BLM received about $22,000 in rental income. Types of rights-of-way and 

amount of rental income by type are presented in Table 3-80. The most common types of 

rights-of-way were for oil and gas pipelines and power lines which generate the most rental 

income. None of these revenues are distributed to state, county, or local governments. It is 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-283 

important to recognize that while these rights-of-way may not generate much rental revenue, 

they do support infrastructure that is very important to local economic activity. 

Table 3-80 Federal Rights-of-Way Revenues by Type 

Type Annual Rental Income Number of ROWs Total Acres

Power Lines $2,281 8 120

Telecommunication Lines 27 2 1

Roads/Highways 232 5 10

Communication Sites 1,800 1 <1

O & G Pipelines 11,119 18 643

Water Facilities 86 4 4

Wind Energy 6,097 1 6,097

Total $21,642 39 6,877

Note: 

Source: Lands & Realty Database (LR2000) 

3.32.2.7 Direct BLM Contributions to Area Economic Activity

Billings Field Office operations and management make a direct contribution to area economic 

activity by employing people who reside in the area and by expending dollars on other nonpersonnel needs. Management of BLM lands and resources is carried out by professional and 

administrative employees who are stationed in Billings and Pompeys Pillar. In FY 2010, the 

Billings Field Office (including Pompeys Pillar National Monument) had 30 permanent 

employees and 8 other than permanent; the BLM spent $3.3 million for labor and $4.3 million 

on operations. Total expenditures for the Field Office (including Pompeys Pillar) were about 

$7.6 million. Annual public revenues from visitor fees collected by the BLM at Pompeys Pillar 

were about $35,000 and annual fees at Shepherd Ah-Nei were about $9,000.

3.32.2.8 Ecosystem Restoration 

Major activities associated with ecosystem restoration include treatment of invasive species and 

pest management, hazardous fuels treatments, and fire suppression and emergency 

stabilization. 

3.32.2.8.1 Weed Treatments 

Economic effects of invasive species and their treatments are related to their influence on range 

productivity, wildfire risk, and attractiveness for recreation and ultimately on how these 

impacts affect local employment, income, and government revenues. Between 2003 and 2007, 

about 9,660 acres of public lands were treated at a cost of $200,200. This averages about 1,932 

acres per year at an average cost of $40,038 per year. The treatment costs average about $20.72 

per acre. A portion of these funds are made available to counties for weed treatments. This 

amounts to an annual average of about $30,000 to counties per year. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

3-284 Chapter 3: Affected Environment

3.32.2.8.2 Fire Suppression and Fuels Treatments 

The cost of wildfire suppression within the Planning Area depends on the number and size of 

fires. Most wildfires are controlled in the initial attack, when they are relatively small. 

However, weather conditions, terrain, vegetation, and proximity to populated areas all 

contribute to the cost of fire suppression. In FY 2008, BLM spent almost $1.6 million on 

wildfire suppression ($388,000 labor and $1.2 million operations; BLM, Financial 

Management Information System, 2008). Operations costs associated with emergency 

stabilization following fire suppression were about $13,000. Since then, fire suppression costs 

have been considerably less. Restoration/fuel reduction efforts in Montana reduce fire hazard, 

improve ecological conditions of forested areas, and result in economic benefits that exceed the 

costs of reducing hazardous fuels (Keegan et.al., 2002). Table 3-81 is a summary of average 

annual fuel treatments and costs for the Billings Field Office. 

Table 3-81 Fuels Treatments (2003-2008) 

Treatment Type

Acres/Year

(2003-2008)

Contract/

Force Account Cost/Acre Totals/Year

Mechanical Treatment 

(WUI* and Non-WUI) 651

50% Contract $400/acre $130,200 

50% Force Account $300/acre $97,650 

Prescribed Fire WUI 395 Force Account $15 $5,903 

Prescribed Fire Non-WUI 1,095 Force Account $20 $21,900 

Totals 2141 $255,653 

Note: 

*Wildland Urban Interface (WUI) 

3.32.2.9 Payments to Counties

Payment to counties from BLM land management activities and public land and minerals uses 

are displayed in Table 3-82. Payments in lieu of taxes (PILT) and disbursement of mineral 

payments are the largest revenues that go to the counties. PILT payments are made to counties 

to compensate for federal lands that are exempt from local property taxes. Payment amounts 

are based on a complex formula that considers, among other things, revenue sharing from the 

previous year, county population, and acreage of a county in federal ownership. BLM portion 

of 2010 PILT payments to the eight counties in the Planning Area amounted to almost 

$620,000.

The Office of Natural Resource Revenue disburses a portion of the revenue received for 

mineral lease bonuses, rents, royalties and other mineral related revenues to the State of 

Montana. Montana redistributes a portion of these revenues to the counties of production. The 

revenues disbursed to the eight Montana counties in the Planning Area is about $580,000 per 

year. A portion (77.95 %) of the Montana Bentonite Production Tax is distributed to counties 

of production. Based on recent past production, the average is about $309,000 per year. 

An estimated average annual $224,000 has been provided to local governments and entities 

through community assistance agreements to reduce the risk of wildfire to communities. 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Chapter 3: Affected Environment 3-285

Total annual payments to counties average about $1.7 million per year. These payments 

support about 27 jobs and $1.2 million in labor income (IMPLAN, 2012) within the local 

economy. 

Table 3-82 Annual Payments to Counties from BLM-Related Land/Mineral Uses 

Weed 

Treatments

BLM Portion 

of 2010 PILT

Grazing Fees

(average annual )

Mineral Payments

(average annual)

Community 

Assistance

Total

(average annual)

$30,000 $618,639 $9,572 $889,312 $223,589 $1,771,112

3.32.2.10 Employment and Income 

Table 3-83 displays the current role of BLM-related contributions to the area economy by 

major BLM program area. The contributions are greater in some counties (generally where 

there are more public lands and minerals and resource uses) and less in others. Table 3-84

displays the current role of BLM-related contributions to the local economy. BLM-related 

contributions include 527 jobs which is 0.34% of the jobs in the local economy. 

Table 3-83 Billings BLM Related Employment, and Income by Major BLM Program 

Area 

Resource/Program Area BLM-Related Jobs BLM-Related Income ($1,000)

Grazing 71 $974

Minerals 193 $9,310

Recreation (including Pompeys Pillar) 136 $3,895

Timber <1 $26

Payments to States/Counties 27 $1,198

BLM Expenditures 100 $6,895

Total Resource Management 527 $22,298

Note: 

Source: IMPLAN 2012 

Table 3-84 Current Role of BLM-Related Contributions to the Area Economy

Employment Labor Income (thousands of 2009 dollars)

Employment 

(Area Total) BLM-Related

BLM Share of 

Total (%)

Income

(Area Total)* BLM-Related

BLM Share of 

Total (%)

155,363 527 0.34% 6,697,590 $22,298 0.33%

Note: 

Source: IMPLAN 2012 
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