Volume 5 of 5

Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan 

And

Final Environmental Impact Statement 

U.S. Department of the Interior 

Bureau of Land Management 

Billings Field Office, Montana 

June 2015 
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Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Table of Contents – Volume 5

APPENDICES

Appendix P: Visual Resource Management

Appendix Q: 1975 Memorandum between Montana and Wyoming – Administration of the 

Pryor Mountain Wild Horse Range

Appendix R: Wild and Scenic Rivers (WSR)

Appendix S: Range Allotments

Appendix T: Air Quality Resource Management Plan (ARMP)

Appendix U: Water Rights

Appendix V: Recreation Setting Characteristics

Appendix W: Pompeys Pillar National Monument

Appendix X: Implementation and Monitoring

Appendix Y: Air Emission Summaries

Appendix Z: Properly Functioning and Condition-Riparian

Appendix AA: Greater Sage Grouse and Sagebrush Habitats

Appendix AB: Billings and Pompeys Pillar National Monument RMP/EIS and the COT 

Report

Appendix AC: Billings and Pompeys Pillar National Monument Sign Plan

***********

Appendices A-B are located in Volume 3

Appendices C-O are located in Volume 4

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

List of Maps – Volume 5

1. BiFO Planning Area

1a. public land in BiFO

2. BiFO Mineral Estate

3. Air Quality Airsheds

4. Air Quality Non-Attainment Areas

5. Soil – Major Land Resource Area 

6. Soil – Wind Erodibility

7. Soil – T Factor 

8. Floodplain Areas

9. Vegetation

10. Riparian – Properly Functioning Condition 

Surveys

11. Riparian Priority Recovery Areas – Alternatives 

B and D

12. Riparian Priority Recovery Areas – Alternative 

C

13. Invasive Species and Noxious Weeds

14. Special Status Plants

15. Big Game Winter Ranges

16. Antelope Range Distribution

17. Bighorn Sheep Range Distribution

18. Elk Range Distribution

19. Mule Deer Range Distribution

20. White-tailed Deer Range Distribution

21. Grizzly Bear Habitat

22. Lynx Habitat

23. Sage Grouse PHMAs, RAs, and GHMAs

24. Sage Grouse PHMAs, RAs, and GHMAs 

overlay with RFD

25. Sprague’s Pipit

26. Red & Blue Ribbon Streams

27. Conservation Populations of YCT

28. YCT Suitable Recovery Habitat

29. PMWHR map

30. Herd Area Map

31. PMWHR – Alternative A 

32. PMWHR – Alternative B

33. PMWHR – Alternative C

34. PMWHR – Alternative D

35. Potential Fossil Yield Classification

36. Wildland fire locations

37. High potential fire damage hazard soils

38. VRI - Alternative A

39. VRM –Alternative B

40. VRM – Alternative C

41. VRM – Alternative D

42. LWC – Alternative A

43. LWC – Alternative B

44. LWC – Alternative C

45. LWC - Alternative D

46. Cave and Karsts

47. Coal Locations

48. Active Oil Fields

49. RFD map

50. Fluid Minerals – standard leasing terms –

Alternative A

51. Fluid Minerals – standard leasing terms –

Alternative B

52. Fluid Minerals – standard leasing terms –

Alternative C

53. Fluid Minerals – standard leasing terms –

Alternative D

54. Fluid Minerals - major/moderate constraints –

Alternative A

55. Fluid Minerals - major/moderate constraints –

Alternative B

56. Fluid Minerals - major/moderate constraints –

Alternative C

57. Fluid Minerals - major/moderate constraints –

Alternative D

58. Locatable Minerals – Alternative A

59. Locatable Minerals – Alternative B

60. Locatable Minerals – Alternative C

61. Locatable Minerals – Alternative D

62. Mineral Materials – Alternative A

63. Mineral Materials – Alternative B

64. Mineral Materials – Alternative C

65. Mineral Materials – Alternative D

66. Land Tenure

67. Withdrawals

68. ROW avoidance – Alternative A

69. ROW avoidance – Alternative B

70. ROW avoidance – Alternative C

71. ROW avoidance – Alternative D

72. ROW exclusion – Alternative A

73. ROW exclusion – Alternative B

74. ROW exclusion – Alternative C

75. ROW exclusion – Alternative D

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Proposed Resource Management Plan and Final Environmental Impact Statement

76. ROW Corridors – Alternatives A and B

77. ROW Corridors – Alternative C

78. ROW Corridors – Alternative D

79. Recreation Areas 

80. SRMA – Alternative A

81. SRMA – Alternative B

82. SRMA – Alternative C

83. SRMA – Alternative D

84. Sundance Lodge SMRA - Alternatives A, B, C, 

D

85. Four Dances Natural Area SRMA –

Alternatives A, B, C, D

86. Acton ERMA – Alternative A

86a. Acton SRMA, Alternatives B, C, D

87. Asparagus Point EMRA – Alternatives A and B

88. Asparagus Point SRMA – Alternatives C and D

89. Pryor Mountain ERMA – Alternative A

90. Pryor Mountain SRMA – Alternatives B, C, D

91. Shepherd Ah-Nei ERMA – Alternative A

92. Shepherd Ah-Nei SRMA – Alternatives B, C, D

93. South Hills ERMA – Alternatives A and B

94. South Hills SRMA – Alternatives C and D

95. 17 Mile ERMA – Alternatives A, B, D

96. 17 mile SRMA – Alternative C

97. Horsethief ERMA – Alternatives A and B

98. Horsethief SRMA – Alternatives C and D

99. Yellowstone River Corridor SRMA –

Alternatives C and D

99a. Yellowstone River Corridor ERMA –

Alternative B

100. Mill Creek/Bundy SRMA – Alternative C

100a. Mill Creek/Bundy ERMA – Alternative D

101.Bundy Island SRMA – Alternative B

102. Areas Closed to Target Shooting –

Alternative A

103. Areas Closed to Target Shooting –

Alternative B

104. Areas Closed to Target Shooting –

Alternative C

105. Areas Closed to Target Shooting –

Alternative D

106. Travel Management Areas

107. Gage Dome TMA – Alternative A*

108. Gage Dome TMA – Alternative B*

109. Gage Dome TMA – Alternative C*

110. Gage Dome TMA – Alternative D*

111.Horsethief TMA – Alternative A*

112.Horsethief TMA – Alternative B*

113.Horsethief TMA – Alternative C*

114.Horsethief TMA – Alternative D*

115.Acton TMA – Alternative A*

116.Acton TMA – Alternative B*

117.Acton TMA – Alternative C*

118.Acton TMA – Alternative D*

119.Shepherd Ah-Nei TMA – Alternative A*

120.Shepherd Ah-Nei TMA – Alternative B, C, 

D*

121.Pompeys Pillar NM, NHL, ACEC

122.Range Allotments 

123.Mill Creek/Bundy TMA – Alternative A*

124.Mill Creek/Bundy TMA – Alternative B*

125.Mill Creek/Bundy TMA – Alternative C*

126.Mill Creek/Bundy TMA – Alternative D*

127.South Hills TMA – Alternatives A and D

128.South Hills TMA – Alternative B

129.South Hills TMA – Alternative C

130.n/a

131.Tin Can Hill TMA – Alternative A 

132.Tin Can Hill TMA – Alternative B

133.Tin Can Hill TMA – Alternative C

134.Tin Can Hill TMA – Alternative D

135.Cottonwood/Weatherman Draw TMA –

Alternative A*

136.Cottonwood/Weatherman Draw TMA –

Alternative B*

137.Cottonwood/Weatherman Draw TMA –

Alternative C*

138.Cottonwood/Weatherman Draw TMA –

Alternative D*

139.Warren TMA – Alternative A*

140.Warren TMA – Alternative B*

141.Warren TMA – Alternative C*

142.Warren TMA – Alternative D*

143.Pryor Mountain TMA – Alternative A*

144.Pryor Mountain TMA – Alternative B*

145.Pryor Mountain TMA – Alternative C*

146.Pryor Mountain TMA – Alternative D*

147.Grove Creek TMA – Alternative A*

148.Grove Creek TMA – Alternative B*

149.Grove Creek TMA – Alternative C*

150.Grove Creek TMA – Alternative D*

151.Wind Potential

152.Wind Potential – BLM only

153.Renewable Energy – Alternative A

154.Renewable Energy – Alternative B

155.Renewable Energy – Alternative C

156.Renewable Energy – Alternative D

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157.Pompeys Pillar NM and ACEC - Alternative 

A

158.Pompeys Pillar NM and ACEC –

Alternatives B, C, D

159.ACECs 

160.Twin Coulee WSA

161.Pryor Mountain WSAs

162.Wild and Scenic River – Alternative A

163.Wild and Scenic River – Alternative B

164.Wild and Scenic River – Alternative C

165.Wild and Scenic River – Alternative D

166.National Historic Trails

167. Oil and Gas Provinces 1995

167a. Oil and Gas RFD with Federal 

Mineral Estate

168. BLM Sage Grouse Management Areas and 

MTFWP Sage Grouse Core Areas,

169. Sage Grouse Priority Habitat Management 

Areas

170. Highly Erodible Soils and Surface Water

171.Sage Grouse PHMA and GHMA and Fluid 

Mineral Allocations

172. Sage Grouse PHMA and GHMA and Lands 

Retention/Disposal Allocations

173. Sage Grouse PHMA and GHMA and 

Livestock Grazing Allocations

174. Sage Grouse PHMA and GHMA and 

Locatable Mineral Allocations

175. Sage Grouse PHMA and GHMA and Minor 

Rights-of-Way Allocations

176. Sage Grouse PHMA and GHMA and Major 

Rights-of-Way Allocations

177. Sage Grouse PHMA and GHMA and Rightof-Way Corridor Allocations

178. Sage Grouse PHMA and GHMA and NonEnergy Leasable Allocations

179. Sage Grouse PHMA and GHMA and 

Mineral Material Allocations

180.Sage Grouse PHMA and GHMA and Travel 

Management Allocations

181.Sage Grouse PHMA and GHMA and Solar 

Energy Allocations

182.Sage Grouse PHMA and GHMA and Wind 

Energy Allocations

* These 24 x 24 maps are too large to be printed as part of this document. They are available on the DVD.

Table of Contents iii
Petroglyph Canyon ACEC

APPENDICES P-Z, AA, AB, & AC
Appendix P P - i

Appendix P: 

Visual Resource Management Program
Appendix P P - ii

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Appendix P P - iii

Table of Contents

P. Visual Resource Management Program..........................................................................................1

P.1 Background .............................................................................................................................1

P.2 Inventory .................................................................................................................................2

P.3 Analysis....................................................................................................................................3

P.4 Design Techniques .................................................................................................................3
Appendix P P - iv

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Appendix P P - 1

P. Visual Resource Management Program

P.1 Background

The Bureau of Land Management (BLM) is entrusted with the care of 264 million acres of public 

lands containing many outstanding scenic landscapes. By law, BLM is responsible for managing 

these public lands for multiple uses. But BLM is also responsible for ensuring that the scenic 

values of these public lands are considered before allowing uses that may have negative visual 

impacts. BLM accomplishes this through its Visual Resource Management (VRM) system, a 

system which involves inventorying scenic values and establishing management objectives for 

those values through the resource management planning process, and then evaluating proposed 

activities to determine whether they conform to the management objectives. BLM has 

established VRM coordinators in each state and provides training in VRM so that this system is 

implemented effectively and consistently throughout the Bureau. The Bureau’s VRM system 

helps to ensure that the actions taken on the public lands today will benefit the landscape and 

adjacent communities in the future.

Responsibility

Over the past several years, the Western States have experienced rapid growth and development, 

and the public lands have been increasingly used for outdoor recreation and tourism. Many rural 

communities are reliant on tourism to sustain their economies. As a result, the management of 

the scenic values of public lands has become a much more important aspect of natural resource 

management to BLM.

BLM’s responsibility to manage the scenic resources of the public lands is established by law:

 The Federal Land Policy and Management Act of 1976 (FLPMA) states, 

“...public lands will be managed in a manner which will protect the quality of the 

scenic (visual) values of these lands.” 

 The National Environmental Policy Act of 1969 (NEPA) requires that 

measures be taken to “...assure for all Americans...aesthetically pleasing 

surroundings....” 

This responsibility is reinforced by BLM’s mission statement:

 “It is the mission of the Bureau of Land Management to sustain the health, 

diversity, and productivity of the public lands for the use and enjoyment of 

present and future generations.” 

BLM’s policy is that it has a basic stewardship responsibility to identify and protect visual values 

on all BLM lands. This policy is described in BLM Manual Section 8400 - Visual Resource 

Management. BLM has reemphasized this policy in various other internal directives as well, 

including Information Bulletin No. 98-135 and Instruction Memorandum No. 98-164.
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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:

 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 somewhat 

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. 

BLM’s VRM system provides a way to identify and evaluate scenic values to determine the 

appropriate levels of management. It also provides a way to analyze potential visual impacts and 

apply visual design techniques to ensure that surface-disturbing activities are in harmony with 

their surroundings.

Basically, BLM’s VRM system consists of two stages:

 Inventory (Visual Resource Inventory) 

 Analysis (Visual Resource Contrast Rating) 

P.2 Inventory

The inventory stage involves identifying the visual resources of an area and assigning them to 

inventory classes using BLM’s visual resource inventory process. The process involves rating 

the visual appeal of a tract of land, measuring public concern for scenic quality, and determining 

whether the tract of land is visible from travel routes or observation points. The process is 

described in detail in BLM Handbook H-8410-1, Visual Resource Inventory. The results of the 

visual resource inventory become an important component of BLM’s Resource Management 

Plan (RMP) for the area. The RMP establishes how the public lands will be used and allocated 

for different purposes, and it is developed through public participation and collaboration. Visual 

values are considered throughout the RMP process, and the area’s visual resources are then 

assigned to management classes with established objectives:

 Class I Objective: To preserve the existing character of the landscape. The level 

of change to the characteristic landscape should be very low and must not attract 

attention 

 Class II Objective: To retain the existing character of the landscape. The level of 

change to the characteristic landscape should be low 
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 Class III Objective: To partially retain the existing character of the landscape. 

The level of change to the characteristic landscape should be moderate. 

 Class IV Objective: To provide for management activities which require major 

modification of the existing character of the landscape. The level of change to the 

characteristic landscape can be high. 

P.3 Analysis

The analysis stage involves determining whether the potential visual impacts from proposed 

surface-disturbing activities or developments will meet the management objectives established 

for the area, or whether design adjustments will be required. A visual contrast rating process is 

used for this analysis, which involves comparing the project features with the major features in 

the existing landscape using the basic design elements of form, line, color, and texture. This 

process is described in BLM Handbook H-8431-1, Visual Resource Contrast Rating. The 

analysis can then be used as a guide for resolving visual impacts. Once every attempt is made to 

reduce visual impacts, BLM managers can decide whether to accept or deny project proposals. 

Managers also have the option of attaching additional mitigation stipulations to bring the 

proposal into compliance

P.4 Design Techniques

There are numerous design techniques that can be used to reduce the visual impacts from 

surface-disturbing projects. The techniques described here should be used in conjunction with 

BLM’s visual resource contrast rating process wherein both the existing landscape and the 

proposed development or activity are analyzed for their basic elements of form, line, color, and 

texture (FLCT).

This discussion of design techniques is broken down into two categories:

 Design fundamentals are general design principles that can be used for all forms 

of activity or development, regardless of the resource value being addressed. 

Applying these three fundamentals will help solve most visual design problems:

► Proper siting or location

► Reducing unnecessary disturbance

► Repeating the elements of form, line, color, and texture

 Design strategies are more specific activities that can be applied to address visual 

design problems. Not all of these strategies will be applicable to every proposed 

project or activity:

► Color selection

► Earthwork
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Appendix P P - 4

► Vegetative manipulation

► Structures

► Reclamation/restoration

► Linear alignment design considerations

The fundamentals and strategies are all interrelated, and when used together, can help resolve 

visual impacts from proposed activities or developments.

The techniques presented here are only a portion of the many design 

techniques available to help reduce the visual impacts resulting from surfacedisturbing activities or projects. Further research into planning and design 

references and/or consultation with professional designers and engineers will 

help to further reduce the visual impacts of any development.
Appendix Q Q - i

Appendix Q: 

Pryor Mountain Wild Horse Range
Appendix Q Q - ii

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Appendix Q Q - 1

1975 Memorandum between Montana and Wyoming -

Administration of the Pryor Mountain Wild Horse 

Range
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Appendix Q Q - 2
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Appendix Q Q - 3
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Appendix Q Q - 4

September 12, 1968 Federal Register Notice –

Establishment of Pryor Mountain Wild Horse Range
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Appendix Q Q - 5
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Appendix Q Q - 6

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Appendix R: 

Wild and Scenic Rivers
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SUMMARY OF ELIGIBILITY, SUITABILITY, AND TENTATIVE 

CLASSIFICATION DETERMINATIONS FOR RIVERS IN THE BILLINGS 

FIELD OFFICE

Billings Field Office

5001 Southgate Drive

Billings, Montana
Appendix R R - ii

TABLE OF CONTENTS

Executive Summary........................................................................................................................ 1

Introduction..................................................................................................................................... 1

What is a Wild and Scenic River?............................................................................................... 1

Steps in the Wild and Scenic Rivers Study Process.................................................................... 1

Eligibility Determination Considerations.................................................................................... 2

Is It a Free-Flowing River? ......................................................................................................... 2

Does It Have at Least One Outstandingly Remarkable Value? .................................................. 3

Tentative Classification Considerations...................................................................................... 3

Eligibility Determinations for Rivers in the Billings Field Office ................................................. 3

Review of Rivers Considered...................................................................................................... 3

Region of Consideration.............................................................................................................. 5

Summary of Determinations ....................................................................................................... 5

Documentation of Eligibility: Criteria for Determining Outstandingly Remarkable Values ..... 5

Eligibility Findings...................................................................................................................... 7

Suitability Determinations for Rivers in the Billings Field Office ............................................... 16

River Segment Suitability Discussion and Findings................................................................. 18

River Name: Bad Canyon Creek ........................................................................................... 18

River Name: Bear Canyon Creek .......................................................................................... 22

River Name: Crooked Creek above the Fish Barrier............................................................ 25

River Name: Crooked Creek below the Fish Barrier ............................................................ 30

River Name: Gyp Spring ....................................................................................................... 33

River Name: Piney Creek ...................................................................................................... 36

River Name: Yellowstone River, Pompeys Pillar ................................................................. 39

Wild and Scenic River Management Guidelines.......................................................................... 44

Interim Management of Suitable Segments.............................................................................. 44

Team Members...............................................................................................49

References (Selected, not inclusive)............................................................................................. 50
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Appendix R R - 1

Executive Summary

As part of the land use planning process for the Billings Resource Management Plan (RMP), a 

US Department of the Interior, Bureau of Land Management (BLM) interdisciplinary team and a 

contract team of Ecosystem Inc. staff analyzed all river and stream segments in the Billings Field 

Office administrative area (Planning Area) that were found to be eligible for inclusion in the 

National Wild and Scenic Rivers System (NWSRS). This included screening all Planning Area 

rivers to identify those with BLM surface ownership. These initial screening and identification 

efforts resulted in a list of rivers or river segments for further consideration in the inventory and 

study process.

Introduction

Section 5(d)(1) of the Wild and Scenic River (WSR) Act directs Federal agencies to consider 

potential wild and scenic rivers in their land and water planning processes (“..In all planning for 

the use and development of water and related land resources, consideration shall be given by all 

Federal agencies involved to potential national wild, scenic and recreational river areas”). To 

fulfill this requirement, whenever the BLM undertakes a land use planning effort (e.g., an RMP), 

it analyzes river and stream segments that might be eligible for inclusion in the NWSRS. The 

BLM, Billings Field Office, is revising its older land use plan. The revised RMP will provide a 

single, comprehensive land use plan that will guide management of public land administered by 

the Billings Field Office.

This report is a record of the wild and scenic river study that is being conducted concurrently 

with the Billings Field Office RMP revision. This report documents BLM’s examination of 

Billings Field Office river segments as they relate to eligibility, suitability, and classification 

criteria in the WSR Act.

This report incorporates the Eligibility phase work performed under contract by Ecosystem 

Management Inc. with BLM staff input and support and uses that data for analysis by BLM staff 

for the completion of the Suitability phase. The two separate reports, the 2009 Wild and Scenic 

River Eligibility Report and this Suitability report, comprise the complete Wild and Scenic River 

evaluations process for the Billings Field Office. 

What is a Wild and Scenic River? 

Congress enacted the WSR Act to provide a national policy for preserving and protecting 

selected rivers and river segments in their free-flowing condition for the benefit and enjoyment 

of present and future generations. The WSR Act provides criteria that must be considered during 

the analysis. No rivers in the Planning Area are currently managed under the WSR Act.

Steps in the Wild and Scenic Rivers Study Process

The wild and scenic river study process is comprised of two main components: the inventory 

phase and the study phase. The inventory phase includes identifying eligible river and stream 

segments, assigning tentative classification (Wild, Scenic, or Recreational), and describing 
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Appendix R R - 2

protective management for the eligible segments. The study phase includes determining the

suitability of eligible segments for inclusion in the NWSRS and describing interim management 

measures. The inventory is conducted during the data-gathering stage of RMP revision, and the 

study phase is done during formulation of the Draft RMP and Proposed RMP.

The inventory and evaluation process used by BLM to identify and evaluate river segments for 

potential inclusion into the National Wild and Scenic Rivers system is guided by the provisions 

of the Wild and Scenic Rivers Act and BLM planning guidance. Section 5(d) (1) of the Act 

directs federal agencies to consider potential wild and scenic rivers in the land and water 

planning processes. To fulfill this requirement, the BLM inventories and evaluates rivers when it 

develops comprehensive resource management plans for public lands in a specified area. A 

Notice of Intent to prepare the RMPs for the BiFO and Pompeys Pillar National Monument was 

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

BLM’s formal scoping process. 

The notice was followed by a news release announcing scoping. In addition, over 1,200 scoping 

packages were mailed to potential stakeholders, agencies, organizations and tribes. A website for 

the Billings and Pompeys Pillar National Monument RMP was launched that provides the public 

access to planning documents, calendars, information on the planning process, as well as a photo 

gallery of the planning area. The website will continue to be updated throughout the planning 

process. Another news release was issued and postcards distributed to the mailing list in July 

2008 announcing the dates, locations and times of seven public scoping open house meetings 

across the planning area. All of these outreach tools conveyed information about the planning 

process, preliminary planning issues, special designations and an overview of the planning area. 

The BLM hosted scoping open houses providing the public with opportunities to become 

involved, learn about the planning process, meet the RMP team members, provide scoping 

comments, and input on the plan.

In April 2009, BLM released the Final Wild and Scenic River Eligibility Report, Billings Field 

Office, Montana. Seven river segments were identified as eligible for further study in the land 

use plan. Additional information describing the inventory and evaluation process can be found in 

the report, which is also attached in Appendix R.

Eligibility Determination Considerations

The first part of BLM's wild and scenic river review process is to identify rivers that are eligible 

for NWSRS designation by Congress. To be eligible, a body of water must be a free-flowing 

river and must possess at least one outstandingly remarkable river-related value.

Is It a Free-Flowing River?

To be considered a free-flowing river, it must be a flowing body of water, or estuary, or section, 

portion, or tributary thereof, including rivers, streams, creeks, runs, kills, rills, and small lakes. A 

river can be any size or length, and does not have to be floatable or boat-able. For purposes of 

eligibility determination, the volume of flow is sufficient if it is enough to maintain any 

outstandingly remarkable river-related values identified. The body of water must be existing or 
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Appendix R R - 3

flowing in a natural condition without major modification of the waterway such as 

channelization, impoundment, diversion, straightening, and rip-rapping. However, some minor 

modifications can be allowed such as low dams, diversion works, and minor structures. The river 

can lie between impoundments or major dams.

Does It Have at Least One Outstandingly Remarkable Value? 

The body of water must have at least one outstandingly remarkable river-related value, i.e., 

scenic, recreational, geologic, fish and wildlife, historic, cultural, or other similar values, such as 

biological, botanical, ecological, hydrological, and paleontological. In order to be assessed as 

"outstandingly remarkable," a river-related value must be a unique, rare, or exemplary feature 

that is significant at a regional or national level. A list of criteria used to help make this 

determination is included later in this appendix.

Tentative Classification Considerations

To protect wild and scenic values prior to Congressional designation, eligible river segments are 

tentatively classified and management measures instituted as necessary to ensure appropriate 

protection of the values supporting the eligibility and classification determinations. 

Section 2(b) of the WSR Act specifies three classification categories: wild, scenic, and 

recreational. Classification is based on the type and degree of human developments associated 

with the river and adjacent lands as they exist at the time of the evaluation. Classifications cannot 

overlap.

 Wild rivers are free of impoundments and are generally inaccessible except by trail, with 

watersheds or shorelines essentially primitive and waters unpolluted.

 Scenic rivers are generally free of impoundments, with shorelines or watersheds still 

largely primitive and shorelines largely undeveloped but accessible in places by roads.

 Recreational rivers are readily accessible by road or railroad, may have some 

development along their shorelines, and may have small diversions and dams.

Eligibility Determinations for Rivers in the Billings Field Office

Review of Rivers Considered

All water bodies in Billings Field Office were evaluated for possible eligibility. Sources used to 

identify water bodies included the Nationwide Rivers Inventory (NRI) (National Park Service, 

1982, 1986, 1988); any named stream found on a 1:100,000 map; the American Rivers 

Outstanding Rivers List: Montana (American Rivers, Inc., 1988). 

Additional information was gathered from other federal and state agencies from scoping letters, 

existing documents, and applicable rivers lists on the internet. A Notice of Intent to prepare the 

RMP for the Billings and Pompeys Pillar National Monument was published in the Federal 

Register on May 15, 2008. This notice served as the beginning of BLM’s formal scoping 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix R R - 4

process. The notice was followed by a news release announcing scoping. Over 1,200 scoping 

packages were mailed to stakeholders, agencies, organizations and tribes. News release and 

postcards were distributed in July 2008 announcing the dates, locations and times of seven public 

scoping open house meetings across the planning area. All of these outreach tools conveyed 

information about the planning process, preliminary planning issues, special designations and an 

overview of the planning area, including requests for information for special designations, 

including Areas of Critical Environmental Concern (ACECs) and Wild and Scenic River 

information and nominations. 

A total of 129 written submissions and e-mails were received by September 19, 2008. Only one 

scoping comment was received on wild and scenic rivers. The commenter requested that no 

rivers be designated.

The Draft Wild and Scenic Eligibility Report was prepared and submitted for review to the RMP 

cooperating agencies. Comments were received from Montana Fish, Wildlife and Parks 

(MFWP), the Yellowstone Conservation District and the Eastern Montana Resource Advisory 

Council (RAC).

MTFWP concurred with BLM’s findings regarding fish values. They also suggested that the 

entire Yellowstone River segment through the planning area met the criteria for outstandingly 

remarkable recreational values. BLM has no authority to determine eligibility of river segments 

that adjoin private, state, or other federally administered lands.

The Yellowstone Conservation District requested clarification on whether eligibility findings 

affect other lands. BLM clarified that the agency only considers values on segments adjacent to 

BLM-administered lands.

The Eastern Montana Resource Advisory Council (RAC) appointed several members to serve as 

liaisons to the planning process. The RAC liaison input with regard to the Bear Canyon Creek 

segment involved additional research and site visits. Through this process, it was determined 

that the Bear Canyon Creek segment length would be 1.6 miles (instead of 1⁄4 mile in the 

preliminary findings) to include the furthest extent of the intermittent cottonwood riparian zone.

In addition, the following other sources were used to identify potentially eligible rivers:

 Montana Department of Fish, Wildlife and Parks databases; 

 Forest Management Plans and Wild and Scenic Rivers Eligibility Assessments from the 

Custer and Gallatin National Forests.

From these sources and information, the BiFO developed an inventory list for consideration. The 

identification of river and stream segments evaluated for potential eligibility included 14 

individual river segments within the BiFO decision area. Refer to Billings Field Office Rivers 

and Streams Analyzed for Eligibility – Appendix D for a list of the results from the identification 

effort (http://www.blm.gov/mt/st/en/fo/billings_field_office/rmp/docs.html). 
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Region of Consideration

To be considered outstandingly remarkable, wild and scenic river values must be outstanding in 

a regional context. Each identified free-flowing river was considered in the context of which of 

the above regional types it flows within.

Summary of Determinations

The segments above were plotted on BLM 1:100,000 Surface Management Maps and measured. 

Based on the eight Outstandingly Remarkable Values (ORV) categories, a list of potential values 

was developed for each segment. For each value of each segment, information was developed 

then compared with similar values outside the general region and evaluated against the ORV 

criteria. The BLM resource specialists conducted this review for each of their areas of expertise 

using their knowledge, available inventory information and publications. A team review for all 

segments was conducted on three separate occasions to assure the information was accurate and 

met the criteria of the study. Seven of the 14 segments evaluated were determined eligible 

because they contained one or more ORVs. A complete list of all segments and the resource 

values that were evaluated is found in Appendix R under “Final Eligibility Report (April, 2009). 

This appendix displays all the resource values that were evaluated, whether they did or did not 

meet the ORV criteria and the rationale for the determination.

Documentation of Eligibility: Criteria for Determining Outstandingly 

Remarkable Values

1. Scenic. The landscape elements of landform, vegetation, water, color, and related factors 

must result in notable or exemplary river-related visual features and/or attractions within 

the geographic region. The BLM Visual Resource Inventory Handbook, H-8410-1, may 

be used in assessing visual quality and in evaluating the extent of development upon 

scenic values. The rating area must be scenic quality "A" as defined in the Handbook. 

However, scenic quality "A" does not, by itself, constitute an outstandingly remarkable 

value. When analyzing scenic values, additional factors such as seasonal variations in 

vegetation, scale of cultural modifications, and length of time negative intrusions are 

viewed may be considered. Scenery and visual attractions may be highly diverse over the 

majority of the river segment length and not common to other rivers in the geographic 

region.

2. Recreational. Recreational opportunities are or have the potential to be unusual enough 

to attract visitors to the geographic region. Visitors are willing to travel long distances to 

use the river resources for recreational purposes. River-related recreation opportunities 

could include, but not be limited to: sightseeing, wildlife observation, camping, 

photography, hiking, fishing, hunting, and boating. Interpretive opportunities may be 

exceptional and attract or have the potential to attract visitors from outside the geographic 

area. The river may provide or have the potential to provide settings for national or 

regional commercial usage or competitive events. In addition, the river may be eligible if 

it is determined to provide a critically important regional recreation opportunity or be a 

significant component of a regional recreation opportunity spectrum setting.
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3. Geologic. The river or the area within the river corridor contains an example(s) of a 

geologic feature, process, or phenomenon that is rare, unusual, or unique to the 

geographic region. The feature(s) may be in an unusually active stage of development, 

represent a textbook example, and/or represent a unique or rare combination of geologic 

features (erosional, volcanic, glacial, and other geologic structures).

4. Fish. Fish values may be judged on the relative merits of either fish populations or 

habitat, or a combination of these river-related conditions.

a) Populations. The river is nationally or regionally one of the top producers of resident, 

indigenous, and/or anadromous fish species. Of particular significance may be the 

presence of wild or unique stocks, or populations of State, federally listed, or 

candidate threatened and endangered species.

b) Habitat. The river provides exceptionally high-quality habitat for fish species 

indigenous to the region. Of particular significance is habitat for state, federally 

listed, or candidate threatened and endangered species.

5. Wildlife. Wildlife values may be judged on the relative merits of either river-related 

wildlife populations or habitat, or a combination of these conditions.

a) Populations. The river or area within the river corridor contains nationally or 

regionally important populations of resident or indigenous wildlife species dependent 

on the river environment. Of particular significance may be species considered to be 

unique or populations of state, federally listed, or candidate threatened and 

endangered species.

b) Habitat. The river or area within the river corridor provides exceptionally high-quality 

habitat for wildlife of national or regional significance, or may provide unique habitat 

or a critical link in habitat conditions for state, federally listed, or candidate 

threatened and endangered species. Contiguous habitat conditions are such that the 

biological needs of the species are met.

6. Cultural. The river or area within the river corridor contains a site(s) where there is 

evidence of river-related occupation or use by Native Americans. Sites must be rare, have 

unusual characteristics, or exceptional human interest value(s). Sites may have national 

or regional importance for interpreting prehistory, may represent an area where a culture 

or cultural period was first identified and described, may have been used concurrently by 

two or more cultural groups, or may have been used by cultural groups for rare or sacred 

purposes.

7. Historic. The river or area within the river corridor contains a site(s) or feature(s) 

associated with a significant river-related event, an important person, or a cultural activity 

of the past that was rare or unusual in the region. A historic site(s) and/or feature(s) in 

most cases is 50 years old or older. Sites or features listed in, or eligible for inclusion in, 

the National Register of Historic Places, may be of particular significance.
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8. Other Similar Values. While no specific evaluation guidelines have been developed for 

this category, additional values deemed relevant to the eligibility of the river segment 

include, but are not limited to, hydrologic, ecologic/biologic diversity, paleontological, 

botanic, and scientific study opportunities. They should be considered in a manner 

consistent with the foregoing guidance.

Eligibility Findings 

The resource specialists identified seven river segments (Figure 1) (for the entire list, see the 

Final Eligibility Report, section 3.1) that contain one or more ORVs and are determined eligible 

for study. These were the following: 

 Bad Canyon Creek

 Bear Canyon Creek

 Crooked Creek – Above Fish Barrier

 Crooked Creek – Below Fish Barrier

 Gyp Spring

 Piney Creek

 Yellowstone River – Pompeys Pillar

The following provides a brief description of each of the eligible segments that were evaluated 

for study. For more detailed overview and description of outstandingly remarkable values 

associated with each of the following seven segments, refer to the Billings Field Office Rivers 

and Streams Analyzed for Eligibility

(http://www.blm.gov/mt/st/en/fo/billings_field_office/rmp/docs.html). 
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Figure 1: Maps of River Segments 
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Figure 2: Bad Canyon
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Figure 3: Bear Canyon
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Figure 4: Crooked Creek – Above Fish Barrier
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Figure 5: Crooked Creek – Below Fish Barrier
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Figure 6: Gyp Springs
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Figure 7: Piney Creek
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Figure 8: Yellowstone River – Pompeys Pillar
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Suitability Determinations for Rivers in the Billings Field Office

Following the Eligibility Determination, the next step in the river assessment process is the 

determination of suitability. The purpose of the study phase is to determine whether eligible river 

segments are suitable or unsuitable for inclusion in the NWSRS, per WSR Act criteria. BLM 

Manual guidance identifies certain factors to be considered when completing the suitability 

study. The suitability determination is influenced by the unique characteristics and conditions 

associated with each particular river. Additional factors may be considered as they apply to a 

specific segment. 

The suitability evaluation does not result in actual designation but only a recommendation for 

those river segments identified as suitable for designation. Only Congress can designate a wild 

and scenic river. In some instances, the Secretary of the Interior may designate a wild and scenic 

river when the governor of a state, under certain conditions, petitions for a river to be designated. 

Congress would ultimately choose the legislative language if any suitable segments are presented 

to them. Water-protection strategies and measures to meet the purposes of the WSR Act would 

be the responsibility of Congress in any legislation proposed. Rivers found unsuitable would be 

dropped from further consideration and would be managed according to the objectives outlined 

in the RMP.

Suitability is designed to answer these questions:

1. Should the river’s free-flowing character, water quality, and ORVs be protected, or are 

one or more other uses important enough to warrant otherwise? 

2. Will the river’s free flowing character, water quality, and ORVs be protected through 

designation? Is it the best method for protecting the river corridor? In answering these 

questions, the benefits and impacts of WSR designation must be evaluated, and 

alternative protection measures considered.

3. Is there a demonstrated commitment to protect the river by any nonfederal entities that 

may be partially responsible for implementing protective management? 

As provided by Sections 4(a) and 5(c) of the Wild and Scenic Rivers Act, the following factors 

were considered and documented as appropriate, as the basis of the study: 

1. Characteristics which do or do not make the area a worthy addition to the National 

System.

2. The current status of land ownership, minerals (surface and subsurface), use in the area, 

including the amount of private land involved and associated or incompatible uses. 

Jurisdictional consideration must be taken into account to the extent that management 

would be affected.

3. The reasonably foreseeable potential uses of the land and water that would be enhanced 

foreclosed or curtailed if the area were included in the National System and the values 

which could be foreclosed or diminished if the area is not protected as part of the system.
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4. The federal agency that will administer the area should it be added to the National

System.

5. Federal, state, local, tribal, or other interests in designation or non-designation of the 

river, including the extent to which the agency proposes that administration of the river, 

including the costs thereof, are shared by state and local agencies. 

6. The estimated cost to the United States of acquiring necessary lands and interests in lands 

and of administering the area should it be added to the National System. Section 6 of the 

WSRA outlines policies and limitations of acquiring lands or interests in land by 

donation, exchange, consent of owners, easement, transfer, assignment of rights, or 

condemnation within and outside established river boundaries. 

7. A determination of the degree to which the state or its political subdivisions might 

participate in the preservation and administration of the river should it be proposed for 

inclusion in the National System. 

8. The federal agency’s ability or other mechanisms (existing or potential) to protect and 

manage the identified river related values other than WSR designation and the state/local 

government’s ability to manage and protect the ORVs on nonfederal lands. Such 

mechanisms may include, for example, statewide programs related to population growth 

management, vegetation management, water quantity or quality, or protection of riverrelated values such as open space and historic areas. 

9. An evaluation of the adequacy of local zoning and other land use controls in protecting 

the river’s ORVs by preventing incompatible development. This evaluation may result in 

a formal finding that the local zoning fulfills Section 6(c)’s requirements, which in turn 

preempts the federal government’s ability to acquire land through eminent domain if the 

river is designated.

10. Support or opposition to designation. Assessment of this factor will define the political 

context. The interest in designation or non-designation by federal, state, local and tribal 

governments and national and local publics should be considered, as well as the state’s 

political delegation.

11. Historical or existing rights which could be adversely affected. In determining suitability, 

consideration of any valid existing rights must be afforded under applicable laws 

(including the WSRA), regulations, and/or policies. 

12. The consistency of designation with other agency plans, programs or policies and in 

meeting regional objectives. Designation may help or impede the “goals” of other tribal, 

federal, state or local agencies. For example, designation of a river may contribute to 

state or regional protection objectives for fish and wildlife resources. Similarly, adding a 

river which includes a limited recreation activity or setting to the National System may 
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help meet statewide recreation goals. Designation might, however, limit irrigation and/or 

flood control measures in a manner inconsistent with regional socioeconomic goals. 

13. The contribution to river system or basin integrity. This factor reflects the benefits of a 

“systems” approach, i.e., expanding the designated portion of a river in the National 

System or developing a legislative proposal for an entire river system (headwaters to 

mouth) or watershed. Numerous benefits are likely to result from managing an entire 

river or watershed, including the ability to design a holistic protection strategy in 

partnership with other agencies and the public.

River Segment Suitability Discussion and Findings

River Name: Bad Canyon Creek 

Location, ORV description, and classification: 

The Bad Canyon Creek segment is located on the east side of the Beartooth Mountains in 

Stillwater County, approximately 34 miles northwest of Red Lodge, Montana (Figure 2). Most 

of the immediate surrounding lands are public lands managed by BLM. 

Bad Canyon Creek supports a population of Yellowstone Cutthroat Trout (YCT) (Oncorhynchus 

clarkii bouvieri) that has been designated a “core population” by the Interstate YCT 

Coordination Team. A core population is one that exhibits no hybridization and is essentially a 

genetically pure strain. This pure strain of YCT is very valuable in that they can be used to 

enhance other YCT populations or establish new populations in suitable waters. 

These fish values are recognized nationally by the fisheries community. The ecological and 

sociological impact of losing a pure strain species is significant in itself. YCT are also listed as a 

Species of Concern by the MFWP and a federally sensitive species by the BLM and U.S. Forest 

Service (USFS). The BLM, MFWP, and USFS reinforced a significant natural barrier to 

upstream migration of non-native species in 2003. This barrier is located approximately five 

miles upstream from the lower BLM boundary; therefore most of the segment is not safe from 

the potential for non-native hybridization. 

Access to the canyon is difficult resulting in little impact from adjacent land uses. High canyon 

walls, rock armoring, and limited access combine to provide excellent fish habitat and a setting 

that is primitive in nature. The presence of the core population of YCT in Bad Canyon Creek 

combined with the isolated, primitive setting of the canyon meets the criteria of an outstandingly 

remarkable value.

The proposed boundary is approximately 0.25 mile on from river bank on either side of the river. 

This river segment has been tentatively classified as scenic through the eligibility phase. 

 

The current status of land ownership, minerals (surface and subsurface), use in the area, 

including the amount of private land involved and associated or incompatible uses. 
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(Jurisdictional consideration must be taken into account to the extent that management 

would be affected.):

BLM Segment Length: 4.5 miles 

Total Segment Length: 5.0 miles

This stream originates in the USFS Custer National Forest and flows easterly to its confluence 

with the Stillwater River. The stream is too narrow and shallow for navigation by watercraft of 

any size. Access to the segment is limited by private land. Although there is a primitive road to 

the segment, the private landowner does not grant motorized access to public lands. Public 

access to Bad Canyon Creek on public lands is limited to walk-in access, requiring a strenuous 

hike on an unmarked and unmaintained 21⁄2 mile trail with 1,300 feet of elevation change. 

The BLM lands along this segment are available for livestock grazing. Private lands in the area 

are primarily used for livestock grazing.

It is free of impoundments although in the upper portion of the segment there is the small natural 

barrier noted above that was reinforced to serve as a fish barrier. The shoreline is mostly 

undeveloped and mostly primitive in nature. There are a few visible livestock fences that cross 

the segment and an ATV trail used by the local rancher for livestock management on his lands. 

There is one access road that that follows the creek a short distance near the upper end of the 

segment.

The lands were burned extensively during the Derby fire in 2006. This transformed much the 

lands from an extensively timbered landscape to a grassland complex. The fire burned the 

riparian zone as well as most infrastructures (range developments, an illegal cabin, etc.). Most of 

the large cottonwoods survived and there has been substantial natural rehabilitation all along the 

fire path.

There are no active oil and gas leases present. 

The reasonably foreseeable potential uses of the land and water which would be enhanced, 

foreclosed or curtailed if the area were included in the NWSRS, and the values which could 

be foreclosed or diminished if the area is not protected as part of the NWSRS:

The YCT core population could be further enhanced and protected. Existing cooperative efforts 

between BLM, Custer NF and MFWP have been managing the YCT core population in this 

segment. Efforts to further protect core populations could occur with or without inclusion in the 

NWSRS.

Potential opportunities exist to acquire additional lands or easements around this segment, with 

or without inclusion in the NWSRS. Possible, but not anticipated, increased visitation due to the 

inclusion in the NWSRS of this segment could jeopardize public access opportunities and/or 

create user/private landowner conflicts.
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Existing water rights could potentially impact management of this segment if included in the 

NWSRS 

Grazing on the BLM land could be subject to increased restrictions if the segment were included 

in the NWSRS. The BLM would monitor the effects of cattle access to the river to ensure that 

grazing use is not adversely affecting the outstandingly remarkable values. If restrictions are 

necessary to protect river values, the BLM would work with the grazing allotment permittee to 

establish adequate restrictions.

The federal agency or state agency that will administer the river and/or area should it be 

added to the NWSRS: 

The Bureau of Land Management would have sole responsibility for this segment; if the National 

Forest finds its segment suitable, the management may be shared. 

Federal, state, local, tribal, or other interests in the designation or non-designation of the 

river, including the extent to which the agency proposes that administration of the river, 

including the costs thereof, be shared by state, local, or other agencies and individuals: 

Local and State Government have not indicated whether they support or oppose designation of 

Bad Canyon Creek as a WSR segment. 

The USDA-Forest Service Gallatin/Custer NF may be interested in participating in joint 

management if their adjacent river segment is also designated. The BLM, MFWP and USFS 

already cooperate jointly in management actions for the protection of the YCT and this would 

continue.

The estimated cost to the United States of acquiring necessary lands and interest in lands 

and of administering the area should it be added to the NWSRS:

Any land acquisition would only be accomplished with willing sellers and it is unlikely that 

private land holders would be willing to sell the land. The BLM would be capable of managing 

for the protection and enhancement of the outstandingly remarkable values without acquiring any 

lands. However, if BLM seeks acquisition of this small parcel of private land in order to have a 

continuous 0.25-mile corridor, land prices would be set at current prices. Costs of administration 

would be minimal.

A determination of the degree to which the state or its political subdivisions might 

participate in the preservation and administration of the river should it be proposed for 

inclusion in the NWSRS:

It is not anticipated that the state or local governments would participate beyond what is 

currently being done for the protection of the YCT and the elimination of invasive weeds. 

MFWP would likely want to continue to manage for the recreational fisheries in this segment. 

This would be complimentary to the recreational outstandingly remarkable value that is linked to 

fishing opportunities.
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The federal agency’s ability or other mechanisms (existing or potential) to protect and 

manage the identified river-related values other than WSR designation and/or the 

state/local government’s ability to manage and protect the ORVs on non-federal lands: 

BLM is a cooperating agency in the YCT Conservation Strategy and existing agreements with 

MWFP and the Custer NF are in place to protect the species in this river segment. 

The BLM is able to manage its lands along the west bank of the segment for the protection of 

identified river-related values through its RMP. In this RMP a Class II VRM classification would 

protect the scenic and geologic values along the segment. This classification would not limit 

development but would provide protection through project design mitigation. Other methods of 

managing to protect values would be with-drawing the corridor from all mineral entry and 

proposing a No Surface Occupancy for Oil and Gas. 

The agency might also assist in placement of conservation easements on adjacent private lands.

An evaluation of the adequacy of local zoning and other land use controls in protecting the 

river’s ORVs by preventing incompatible development:

No local zoning for the private lands.

Support or opposition to designation:

During the scoping period for the RMP, no support or opposition to designation of this segment 

was submitted. The public review of the draft RMP provided an opportunity for other agencies 

and the public to review the preliminary findings and voice opposition or support. There was no 

opposition. The lands were also evaluated for their wilderness characteristics (Naturalness, 

Primitive Recreation, Outstanding Solitude and its unique resources – archeological, geological, 

wildlife, etc. ), and there was support for management for these attributes. 

Historical or existing rights which could be adversely affected:

There are water claims on Bad Canyon Creek for various uses along its entire length. It does not 

appear that there is a reserve water right on the creek to maintain a minimum flow. There are 

active grazing permits (Allotments 5492, 5585, 55548, 5562, and 5558) for the BLM land and 

grazing is the historic use of the private land along Bad Canyon Creek and these would be 

affected if there is a management decision to restrict this activity. There is a newly proposed (FY 

2014) 100 KV power line which is being prepared by Northwest Energy, the path of which 

would cross the canyon in T 4 S., R 16 E., Sections 9 and 10, and there is an existing 15 KV 

power-line owned by Beartooth Electric in T. 4 S., R. 16 E., section 14. 

The consistency of designation with other agency plans, programs or policies and in 

meeting regional objectives:

Designation of this segment would be consistent with the objectives of the BLM’s Billings Field 

Office RMP. Designation of this segment would complement the fisheries and recreational goals 

of the MFWP.

The USFS has not completed a study for this river unit. Designation would be consistent with the 

USFS eligibility determination, but successful management in part would depend on a similar 

suitability determination from USFS. 
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The contribution to river system or basin integrity:

From a practical standpoint it is likely in this case that a total system management strategy can 

be pursued with a focus on the total watershed in conjunction with the National Forest. Some 

benefits are likely to result from managing the entire river, including the ability to design and 

then implement a holistic protection strategy in partnership with other agencies and the public. 

The potential for water resources development: 

It is unlikely that further water impoundments would be installed on Bad Canyon Creek. It is 

unlikely flood control, hydropower facilities, dredging or diversions or channelization of Bad 

Canyon Creek will occur.

Non-suitable X

Rationale: Management policies, goals and objectives are already in place to protect the values 

of this segment. Existing agreements between local, state, and federal agencies are in place to 

specifically protect and further enhance the YCT core population.

River Name: Bear Canyon Creek 

Location, ORV description, and classification:

The Bear Canyon Creek segment is located at the south end of the Pryor Mountains in Carbon 

County approximately seven miles east of Warren, Montana (Figure 3). Water for this segment 

originates from a spring at the BLM-National Forest boundary. The length of flowing water in 

the canyon varies from 1⁄4 mile to over a mile depending upon moisture conditions and time of 

year. The stream is too narrow and shallow for navigation by watercraft of any size. Originally, 

the segment length was 1⁄4 mile; however, public comments during review of the draft report 

suggested the segment should be longer. After an on-site evaluation, the segment was 

lengthened to include the lower extent of the cottonwood intermittent riparian zone.

Visitors to Montana who want to see Blue-gray Gnatcatchers (Polioptila caerulea) and Blackthroated Gray Warblers (Dendroica nigrescens) visit Bear Canyon because this is only place in 

Montana where these birds can be seen. This opportunity receives international attention 

through the National Audubon Society via their website (http://mtaudubon.org/birds/areas.html).

Listed by the National Audubon Society as an IBA (important bird area), Bear Canyon supports 

breeding populations of more than a dozen species on the Montana Priority Bird Species List. In 

particular, Bear Canyon has the highest known number of nesting Blue-gray gnatcatcher in 

Montana. Bear Canyon and a few nearby foothill canyons at the base of the Pryor Mountains 

constitute the entire range in Montana of this bird species. The State of Montana ranks this 

species as “S1” or at high risk due to extremely limited and potentially declining numbers. Both 

the BLM and the Forest Service also consider the Blue-gray Gnatcatcher a sensitive species. The 

riparian area and adjacent uplands of Bear Canyon also support other State Sensitive bird species 

such as the Loggerhead Shrike (Lanius ludovicianus), Sage Thrasher (Oreoscoptes montanus), 

Common Poorwill (Phalaenoptilos nuttallii) and Pinyon Jay (Gymnorhinus cyanocephalus).
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Cultural elements in the landscape include a vision quest site, a buffalo kill site, tipi rings, 

petroglyphs, and habitation sites. The vision quest site was noted at the time of recording to 

have a vision quest structure on top of a rock formation. The evidence of occupation and use, 

especially for sacred purposes, meets the criteria for being an outstandingly remarkable value.

This segment has been tentatively classified as recreational through the eligibility phase process. 

The proposed boundary is approximately 0.25-mile on from river bank on either side of the river.

The current status of land ownership, minerals (surface and subsurface), use in the area, 

including the amount of private land involved and associated or incompatible uses. 

(Jurisdictional consideration must be taken into account to the extent that management 

would be affected.):

BLM Segment Length: 1.62 miles

Total Segment Length: 1.62 miles

All BLM lands in the proposed WSR segment are in public ownership and Custer NF forms the 

northern boundary of this segment. There are some possible valid existing rights (mining 

claims).

There are no active oil and gas leases present. 

A variety of opportunities currently exist in this area, including wildlife viewing, hunting, and 

dispersed recreation. It is free of impoundments. Livestock grazing is readily evident 

throughout the entire corridor. Public access is through a two-track road that parallels a portion 

of the lower segment, often within several hundred feet of the segment. There is a nonmotorized trail which follows the upper segment.

The reasonably foreseeable potential uses of the land and water which would be enhanced, 

foreclosed or curtailed if the area were included in the NWSRS, and the values which could 

be foreclosed or diminished if the area is not protected as part of the NWSRS:

Inclusion in the NWSRS could further protect the bird species (Audubon IBA); however, this 

may negatively impact hunting, if restricted. Dispersed recreation and primitive camping could 

be enhanced, while motorized recreation may be adversely affected if restricted. 

The federal agency or state agency that will administer the river and/or area should it be 

added to the NWSRS:

Bureau of Land Management

Federal, state, local, tribal, or other interests in the designation or non-designation of the 

river, including the extent to which the agency proposes that administration of the river, 

including the costs thereof, be shared by state, local, or other agencies and individuals:

Local and State Government have not indicated whether they support or oppose designation of 

Bad Canyon Creek as a WSR segment. No comments have been received through the planning 

process in either support or opposition to designation. 
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The USDA-Forest Service Gallatin/Custer NF may be interested in participating in joint 

management if their adjacent river segment upstream is also designated.

The estimated cost to the United States of acquiring necessary lands and interest in lands 

and of administering the area should it be added to the NWSRS:

No lands would need to be acquired since all lands are public and costs of administration would 

be minimal. 

A determination of the degree to which the state or its political subdivisions might 

participate in the preservation and administration of the river should it be proposed for 

inclusion in the NWSRS:

It is not anticipated that the state or local governments would participate beyond what is 

currently being done for the elimination of invasive weeds.

The federal agency’s ability or other mechanisms (existing or potential) to protect and 

manage the identified river-related values other than WSR designation and/or the 

state/local government’s ability to manage and protect the ORVs on non-federal lands:

The Billings RMP has identified some management measures which would protect the resources. 

These include closure of the existing vehicle route on the top end of the canyon and its 

designation as a non-motorized trail, an ongoing effort with the local county for invasive weed 

management, etc. 

An evaluation of the adequacy of local zoning and other land use controls in protecting the 

river’s ORVs by preventing incompatible development: Local zoning and other land use 

controls do not pertain to this segment because it is entirely located on Federal lands.

Support or opposition to designation:

There is support from certain non-governmental organizations (ex: Wilderness society, National 

Audubon Society, American Rivers, Pryor Coalition, etc.) to further acknowledge the important 

values associated with this segment. A finding of suitability may further their goals/objectives 

particularly for the bird species in this area. It is unknown whether the Native American tribes 

with affinity to this area would support or oppose a WSR designation. OHV users may object to 

designation due to the proximity of a major travel access in the lower reaches of the canyon and 

fear that its use may be restricted or lost. 

Local and State Government support or opposition is unknown. Neither viewpoint has been 

expressed in the planning responses.

Historical or existing rights which could be adversely affected:

There is an active grazing permit (Allotment 4115) for the BLM land and grazing is the historic 

use of the private land along Bear Canyon Creek and this would be affected if there is a 

management decision to restrict this activity. 

There are no ROWs present. 
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The consistency of designation with other agency plans, programs or policies and in 

meeting regional objectives:

BLM management policies address protection for cultural, wildlife and special status species. 

Current recreational use is compatible with the bird population. Motorized recreation is 

currently limited to designated routes and the trail within the upper canyon is only open for nonmotorized use with a major motorized route in proximity to the lower portion. Current BLM 

policies provide protection for the sensitive bird species and cultural resources. The designation 

would be consistent with the Billings RMP. 

The contribution to river system or basin integrity:

A limited contribution based on the size of the watershed and the size of the river segment. 

The potential for water resources development:

Not enough year-round flow to lead to water development. Direct recreational use of water 

(fishing, floating, etc.) is not a feature of the area or Bear Creek and is unlikely in the future.

Values foreclosed/diminished: 

Inclusion of this segment in the NWSRS could increase visitation and possibly this could impact 

the bird species in the IBA. Currently, visitation levels to the entire Pryor Mountain area are 

increasing as its resources are being actively marketed and are becoming better known. An 

additional designation may possibly attract additional users.

An increase in visitation to the area could adversely impact the integrity of the archeological 

sites.

Finding: Non-suitable X

Rationale: Current BLM policies provide protection for the sensitive bird species and cultural 

resources, while providing for the recreational opportunities and experiences. The motorized 

route along the lower portion of the river segment is a major access route into the Pryor 

Mountain and the type of activity is in conflict with the type of recreational activity expected for 

a suitable river segment. The upper portion which is a non-motorized trail along the river 

segment is the only portion appropriate to designation for the recreation ORV. 

River Name: Crooked Creek above the Fish Barrier

Location, ORV description, and classification:

Located in Carbon County, Crooked Creek originates in the southern portion of the Pryor 

Mountains within the Custer National Forest and flows south onto public lands and towards 

Wyoming (Figure 4). The stream is too narrow and shallow for navigation by watercraft of any 

size and is inaccessible except with extreme difficulty by foot. See map 3 in the Eligibility 

Section. 

This segment flows through the Burnt Timber Canyon Wilderness Study Area (WSA) and is 

rated as Class I for visual resource management. The current management objective is to 

maintain the existing character of the landscape. The deeply incised Crooked Creek Canyon cuts 
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through several hundred feet of the Pryor Mountain limestone strata. The combination of the 

dense riparian vegetation along Crooked Creek and the steep talus slopes of the canyon walls 

offer unique and outstandingly remarkable scenery. 

The Pryor Mountains offer a unique combination of resource values that attract local, regional,

and national visitors. This segment offers access to opportunities including fishing for a 

genetically pure strain of Yellowstone Cutthroat Trout, bushwhacking in a pristine riparian 

canyon, viewing Pryor Mountain wild horses at one of their limited watering sources and 

exploring for caves and bats in the canyon’s limestone walls.

The Crooked Creek – Above Fish Barrier segment supports a population of Yellowstone 

Cutthroat Trout (YCT) (Oncorhynchus clarkii bouvieri) that has been designated a “core 

population” by the Interstate YCT Coordination Team. A core population is one that exhibits no 

hybridization and is essentially a genetically pure strain. This pure strain YCT is very valuable 

in that fish can be used to enhance other YCT populations or establish new populations in 

suitable waters. These fish values are recognized nationally by the fisheries community. The 

ecological and sociological impact of losing a pure strain species is significant in itself. YCT are 

listed as a Species of Concern by the MFWP and a federally sensitive species by the BLM and 

U.S. Forest Service. A fish barrier at the downstream end of the segment will maintain the 

genetic purity of this YCT population. Adjacent land uses have had little effect on this segment 

because the segment is within the WSA. The fish habitat is in good condition. High canyon 

walls, rock armoring, and limited access combine to provide a setting that is primitive in nature. 

Although there is public motorized to within 1⁄4 mile of the canyon bottom, visitors must hike 

through dense brush with no trails to reach the canyon bottom. The presence of the core 

population of YCT in Crooked Creek combined with the isolated, primitive setting of the canyon 

meets the criteria of an outstandingly remarkable value.

The Crooked Creek – Above Fish Barrier segment has a landscape with significant 

archaeological properties. The Demijohn Flat Archaeological District was listed on the National 

Register of Historic Places (NRHP) in 1974 as District # 74001092 (24CB478). 

The Demijohn Flat Archaeological District retains archaeologically intact remnants of protohistoric period Crow tipi habitation. The size and relatively pristine nature of the site warrants 

protection. Beyond the registered archaeological district other sites include the petroglyphs 

(24CB205) and other nearby sites (additional tipi rings) possibly could be considered elements in 

a broad landscape associated with the archaeological district. This segment of the Crooked 

Creek Demijohn Flat Archaeological District retains unique qualities of outstanding scientific 

value on at least a regional level.

The tentative Classification is wild.

The proposed boundary is approximately 0.25-mile from river bank on either side of the river

segment.
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The current status of land ownership, minerals (surface and subsurface), use in the area, 

including the amount of private land involved and associated or incompatible uses. 

(Jurisdictional consideration must be taken into account to the extent that management 

would be affected.):

BLM Segment Length: 1.59 miles 

Total Segment Length: 1.59 miles

In a 1992 Forest Plan amendment, the Custer National Forest determined Crooked Creek as 

being eligible for WSR study with cultural, fisheries, geologic and scenic values being 

outstandingly remarkable. At the forest boundary Crooked Creek flows onto BLM-administered 

lands for three miles before entering private lands. This three-mile reach on BLM was segmented 

at a fish barrier which is located close to the middle of the reach. 

The area is currently used predominantly for recreational purposes such as hiking, camping, and 

providing access to climbing and caving areas. 

There are no private lands along the river segment. 

The BLM constructed the fish barrier for the protection of the native trout species. 

The BLM and partners have monitored the canyon for the presence and condition of several bat 

species. 

Extraction of minerals in the area does not currently occur in accordance with the WSA 

designation.

There are no active oil and gas leases present.

The reasonably foreseeable potential uses of the land and water which would be enhanced, 

foreclosed or curtailed if the area were included in the NWSRS, and the values which could 

be foreclosed or diminished if the area is not protected as part of the NWSRS:

If the lands continue to be a WSA or becomes a designated Wilderness, reasonably foreseeable 

potential land uses would be compatible with the protection and enhancement of the segment’s 

outstandingly remarkable values. If the WSA designation is removed by Congress without 

designating it as Wilderness, then the area could be opened to an array of potential land uses.

Inclusion in the NWSRS may attract additional visitation which could impair the values 

associated with the segment by potential introduction of aquatic nuisance and/or undesirable 

species. 

If the WSA designation was removed and the segment was designated in the NWSRS, mineral 

leasing and extraction would continue to be restricted under the RMP.
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The federal agency or state agency that will administer the river and/or area should it be 

added to the NWSRS:

The Bureau of Land Management for the public lands and the Custer/Gallatin National Forest for 

the river segment on their lands. 

Federal, state, local, tribal, or other interests in the designation or non-designation of the 

river, including the extent to which the agency proposes that administration of the river, 

including the costs thereof, be shared by state, local, or other agencies and individuals:

This segment is entirely within BLM-administered lands and adjacent to Custer NF lands in 

which Crooked Creek was determined to be eligible for further WSR study. Cost could be 

shared with the Custer National Forest if the entire stream length is acted upon and designated. It 

is not anticipated that State or Local Agencies would assume management responsibility. 

The estimated cost to the United States of acquiring necessary lands and interest in lands 

and of administering the area should it be added to the NWSRS:

All lands are public lands, so there are no acquisition costs. Costs of administration would be 

minimal.

A determination of the degree to which the state or its political subdivisions might 

participate in the preservation and administration of the river should it be proposed for 

inclusion in the NWSRS:

It is not anticipated that the state or local governments would participate in the preservation and 

administration of the river segment beyond the current management efforts (control of invasive 

species, management of sensitive species, etc.).

The federal agency’s ability or other mechanisms (existing or potential) to protect and 

manage the identified river-related values other than WSR designation and/or the 

state/local government’s ability to manage and protect the ORVs on non-federal lands:

BLM does not have the authority to regulate land uses upstream of the eligible segment, 

however, the Custer NF determined the Crooked Creek segment (on forest lands) to be eligible 

for further study. There are no non-federal lands present. 

The area is recognized as containing wilderness characteristics through the WSA designation and 

additional Lands with Wilderness Characteristics (LWC) inventory. With or without inclusion in 

the NWSRS, certain management policies are in place through the WSA and the Resource 

Management Plan decisions to protect the values associated with this segment.

Protection and enhancement of the recreational and scenic outstandingly remarkable values are 

currently provided by the areas designation as a WSA. The management goals and objectives 

within the WSA are compatible with management as an eligible segment. WSA designation is 

temporary. Congress has the ability to either designate the area as Wilderness under the 

Wilderness Act, or remove the WSA designation entirely. If WSA designation is removed, the 

area would be managed in accordance with the RMP. Removal of WSA designation, without 

making it a designated Wilderness area, could open the area to land uses such as timber harvest 

and mineral activity. Introduction of these land uses in the area could degrade the riparian 
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corridor and result in impacts on the recreational and scenic outstandingly remarkable values that 

make the segment a worthy addition to the NWSRS.

An evaluation of the adequacy of local zoning and other land use controls in protecting the 

river’s ORVs by preventing incompatible development:

Local zoning and other land use controls do not pertain to this segment because it is entirely 

located on Federal lands.

Support or opposition to designation:

There is support from a range of non-governmental entities for the potential designation of this 

segment of the rivers as a WSR. It is recognized as possessing significant resources and 

warranting protection. Local and State Governments have not made their position known, 

however they have been generally opposed to special designations of most kinds due to the 

perception of additional restrictions. Native American tribes with affinity to the area generally 

favor additional restrictions for cultural resources, however it is unknown whether they support 

or oppose designation.

Historical or existing rights which could be adversely affected:

There are no known historical or existing rights that could be adversely affected with 

designation. There are no Rights of Ways (ROWs) present. 

The consistency of designation with other agency plans, programs or policies and in 

meeting regional objectives:

These uses are compatible with the protection and enhancement of the segment’s outstandingly 

remarkable values. The Wilderness Study Area (WSA) protects the ORVs associated with this 

segment. WSA management policies protect the WSA values from impairment. Inclusion in the 

NWSRS could further enhance the ORVs, could be compatible with the Custer NF eligibility 

determination and would be compatible with the Billings FO RMP.

Existing cooperative efforts between BLM, Custer NF and MFWP have been managing the 

Yellowstone Cutthroat Trout core population in this segment. Efforts to further protect core 

populations could occur with or without inclusion in the NWSRS. The WSA Management 

Protection prescriptions found in the BLM Manual currently protects the ORVs associated with 

this segment. Lands within the PMWHR are also managed for the benefit of the wild horses and 

there are secondary values that the PMWHR are also managed for, including cultural, 

paleontological and wildlife values. 

The contribution to river system or basin integrity:

Some benefits are likely to result from managing the entire river, including the ability to design 

and then implement a holistic protection strategy in partnership with other agencies and the 

public. 

The potential for water resources development:

The flows in the river segment are generally low except for the spring runoff. The potential for 

water resource development is low. It is unlikely flood control, hydropower facilities, dredging 

or diversions or channelization of will occur.
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Finding: Suitable X NonRationale: existing management, WSA, PMWHR, YCT Conservation strategy, etc.) currently

protects wilderness characteristics and ORVs, should Congress release the WSA from further 

study, the area would be managed as an ACEC. Inclusion in the NWSRS has the potential to 

attract regional/national visitation to the area and may negatively impact the ORVs but BLM 

management measures are in place to control the use. Additional visitation could also be positive 

in terms of marketing the resources and acquiring funding. The river segment should be 

designated as “wild” due to its inclusion in the existing WSA, the quantity, diversity, and quality 

of the resources present. Existing agreements between local, state, and federal agencies are in 

place to specifically protect and further enhance the YCT core population. 

River Name: Crooked Creek below the Fish Barrier

Location, ORV description, and classification:

Located in Carbon County, Montana, Crooked Creek originates in the southern portion of the 

Pryor Mountains within the Custer National Forest (
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Figure 5). The creek flows out of the national forest onto BLM-administered lands for 

approximately three miles before entering private lands. The stream is too narrow and shallow 

for navigation by watercraft of any size, and is inaccessible except by foot with extreme 

difficulty. This three-mile reach on BLM was segmented above and below an existing fish 

barrier. This segment is below the fish barrier and is shown on Map 3.

This segment flows through the Burnt Timber Canyon Wilderness Study Area (WSA) and is 

rated as Class I for visual resource management. The current management objective is to 

maintain the existing character of the landscape. The deeply incised Crooked Creek Canyon cuts 

through several hundred feet of the Pryor Mountain limestone strata. The combination of the 

dense riparian vegetation along Crooked Creek and the steep talus slopes of the canyon walls 

offer unique and outstandingly remarkable scenery.

The Pryor Mountains offer a unique combination of resource values that attract local, regional 

and national visitors. This segment offers access to opportunities including bushwhacking in a 

pristine riparian canyon, viewing Pryor Mountain wild horses at one of their limited watering 

sources and exploring for caves and bats in canyon’s limestone canyon walls. 

The Crooked Creek – Below Fish Barrier segment has a landscape with significant 

archaeological properties. The Demijohn Flat Archaeological District was listed on the NRHP in 

1974 as District # 74001092 (24CB478). The Demijohn Flat Archaeological District retains 

archaeologically intact remnants of proto-historic period Crow tipi habitation. The size and 

relatively pristine nature of the site warrants protection. Beyond the registered district other sites 

include the petroglyphs (24CB205) and other nearby sites (additional tipi rings) possibly could 

be considered elements in a broad landscape associated with the district area. This segment of 

the Crooked Creek Demijohn Flat Archaeological District retains unique qualities of outstanding 

scientific value on at least a regional level.

This segment has been tentatively classified as scenic through the eligibility phase of the process. 

The proposed boundary is approximately 0.25-mile on from river bank on either side of the river.

The current status of land ownership, minerals (surface and subsurface), use in the area, 

including the amount of private land involved and associated or incompatible uses. 

(Jurisdictional consideration must be taken into account to the extent that management 

would be affected.):

BLM Segment Length: 1.56 miles

Total Segment Length: 1.56 miles

This segment is entirely within the Burnt Timber Canyon WSA and has motorized public access 

to within less than 1⁄4 mile of the canyon rim. It is free of impoundments, although there is a 

man-made fish barrier at the beginning of the segment. The shoreline is undeveloped and 

primitive. There is little evidence of livestock grazing. There are no improvements or evidence 

of man (except for the old road which has been designated as a non-motorized trail).
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This segment is currently managed as a WSA and part of the Pryor Mountain Wild Horse Range 

PMWHR).

There are no active oil and gas leases present.

The reasonably foreseeable potential uses of the land and water which would be enhanced, 

foreclosed or curtailed if the area were included in the NWSRS, and the values which could 

be foreclosed or diminished if the area is not protected as part of the NWSRS:

The Wilderness Study Area (WSA) generally protects the ORVs associated with this segment. 

Management policies protect the WSA values from impairment and restrict actions which could 

have adverse effects on WSR values. Inclusion in the NWSRS could further enhance the ORVs, 

similarity, enhance and protect the WSA values, and could be compatible with the Custer NF 

eligibility determination.

No additional restrictions would likely occur (the WSA designation provides management to 

protect the values of the area). 

Potential exists to create user conflicts if or not included in the NWSRS with the private 

landowners on the southern boundary of this segment. (Note: Members of the public expressed 

concern regarding the tentative management classification of this segment (scenic) and felt it 

qualified to be classified as “wild”, considering it is already within a WSA).

The federal agency or state agency that will administer the river and/or area should it be 

added to the NWSRS:

The Bureau of Land Management for the public lands and the US Forest Service for the river 

segment on adjacent FS lands managed by them. 

Federal, state, local, tribal, or other interests in the designation or non-designation of the 

river, including the extent to which the agency proposes that administration of the river, 

including the costs thereof, be shared by state, local, or other agencies and individuals:

This segment is entirely within BLM administered public lands. This segment terminates on the 

southern boundary at private property.

The estimated cost to the United States of acquiring necessary lands and interest in lands 

and of administering the area should it be added to the NWSRS:

Acquisition of lands or interest in lands (willing buyer/willing seller) is possible but not likely 

and would not be necessary.

A determination of the degree to which the state or its political subdivisions might 

participate in the preservation and administration of the river should it be proposed for 

inclusion in the NWSRS:

MFWP is actively involved in a cutthroat trout restoration and protection program with the BLM 

and USFS in this river segment. It is expected that their involvement in the protection and 

enhancement of the fisheries outstandingly remarkable values would continue.
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The federal agency’s ability or other mechanisms (existing or potential) to protect and 

manage the identified river-related values other than WSR designation and/or the 

state/local government’s ability to manage and protect the ORVs on non-federal lands:

The WSA Management Protection policies currently protect the ORVs associated with this 

segment. Lands within the PMWHR are managed for the benefit of the wild horses as well as 

other resources. There are secondary values that the PMWHR are managed for, including 

cultural, paleontological and wildlife.

The Custer NF determined the Crooked Creek segment (on forest lands) to be eligible for further 

study. The area is recognized as containing wilderness characteristics through the WSA 

designation. With or without inclusion in the NWSRS, management policies are in place 

through the WSA and PMWHR management prescriptions to protect the values associated with 

this segment. Other methods of managing to protect values would be with-drawing the corridor 

from all mineral entry and proposing a No Surface Occupancy for Oil and Gas.

An evaluation of the adequacy of local zoning and other land use controls in protecting the 

river’s ORVs by preventing incompatible development:

Local zoning and other land use controls do not pertain to this segment because it is entirely 

located on Federal lands.

Support or opposition to designation:

There is both support and opposition to the potential designation of this segment as a WSR. It is 

recognized as having significant resources and warranting some level of protection, including the 

adjacent landowner, but there are also individuals and organizations opposed for a variety of 

reasons, chiefly for the perceived consequences of designation. It is unknown whether the Native 

American tribes with affinity to this area would support or oppose a WSR designation.

Historical or existing rights which could be adversely affected:

There are no known historical or existing rights that would be adversely affected by designation.

There are no Rights of Ways (ROWs) present. 

The consistency of designation with other agency plans, programs or policies and in 

meeting regional objectives:

Designation would be consistent with the Billings BLM RMP and the work being done with 

other agencies regarding management of this segment. 

The contribution to river system or basin integrity:

Some benefits are likely to result from managing the entire river, including the ability to design 

and then implement a holistic protection strategy in partnership with other agencies and the 

public. 

The potential for water resources development:

The flows in the river segment are generally low except for the spring runoff. The potential for 

water resource development is low. It is unlikely flood control, hydropower facilities, dredging 

or diversions or channelization of will occur.
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Finding: Suitable X NonRationale: Although current management prescriptions (WSA, PMWHR, LWC, etc.) currently 

protects wilderness characteristics and ORVs, should Congress release the WSA from further 

study, the area would be managed as an ACEC, but not necessarily protect other values. 

Inclusion in the NWSRS has the potential to attract regional/national visitation to the area and 

may negatively impact the ORVs but management prescriptions are in place to protect the 

resources. The inclusion of the river segment as suitable would be consistent with WSA, 

PMWHR, and LWC prescriptions. Existing agreements between local, state, and federal 

agencies are in place to specifically protect and further enhance the YCT core population.

River Name: Gyp Spring

Location, ORV description, and classification:

The Gyp Springs segment is located in Carbon County, approximately 12 miles southeast of 

Warren, Montana (Figure 6). This segment originates from Gyp Springs, an important source of 

livestock and wildlife water. The stream is too narrow and shallow for any navigation by 

watercraft of any size. Access to segment is through well maintained county and BLM graveled 

roads. . 

In 1864, Jim Bridger, famed early trapper and mountain man, and later guide for the Captain 

William Reynolds Exploration military and emigrant parties, blazed what would become known 

as Bridger Cutoff, an alternative route for a section of the Bozeman Trail emigrant route. The 

present day Gyp Springs Road (still in-use) follows generally along the Bridger Cutoff through 

the Gyp Springs area. The trail passes directly through and continues west of Gyp Springs. The 

spring was likely used historically as a watering and camp site and was an integral part of 

Bridger Cutoff of the Bozeman Trail. The trail was designated as site number 24CB1242 within 

the Montana portion in 1991 (Taylor 1991) beginning below Gyp Springs, following Gyp 

Springs Creek north from the border with Wyoming and continuing along the creek, through the 

springs, and then continuing to the northwest. The Bridger Cutoff was determined eligible for 

inclusion to the NRHP on a state level. The trail has at least regional significance because it is 

associated with events that have made a significant contribution to the broad pattern of European 

settlement and it is associated with the lives of persons significant in the past.

Gyp Springs and the immediate vicinity retain archaeological evidence of both historic and 

prehistoric use and it is documented as site 24CB604. Confirmed substantial surface and 

subsurface cultural remains indicate possible long, intensive and continued use of the springs in 

prehistoric through historic periods. The prehistoric component is comprised of artifact scatter 

and intact subsurface deposits indicative of a habitation site. Diagnostic materials indicate an 

occupation or occupations as early as late Paleolithic/archaic period up to late prehistoric period. 

A Recreation Site Inventory and Evaluation Form completed by BLM before 1969 indicates a 

consideration of Gyp Springs and “Tipi Rings Area nearby” as contributing to the recreational 

attraction for the Crooked Creek Program Area. The “Tipi Rings Area” was recorded as 

24CB604 in 1967. The combination of the historic and prehistoric values makes the cultural 

values outstandingly remarkable.
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This segment has been tentatively classified as recreational through the eligibility phase. 

The current status of land ownership, minerals (surface and subsurface), use in the area, 

including the amount of private land involved and associated or incompatible uses. 

(Jurisdictional consideration must be taken into account to the extent that management 

would be affected.):

BLM Segment Length: 0.46 miles,

Total Segment Length: 0.46 miles

It is free of impoundments. Livestock grazing, livestock fences, and the adjacent access road are 

readily evident along much of this short segment. 

The segment is heavily infested with exotic invasive Russian olive trees. The most common 

concern expressed regarding this segment was the need to preserve the character of the corridor 

and that the current weed infestation was the largest threat. Weed infestation is apparent 

throughout the river corridor. Weeds are threatening scenic values, adjacent land and watersheds, 

and ecological functions within the river area.

Valid existing rights (mining claims) may be present. There are no active oil and gas leases 

present. 

The amount and timing of stream flow is dependent on the climate and fluctuates yearly and 

seasonally.

The entire Gyp Springs site is eligible for the National Register of Historic Places for cultural 

and historic values. This area is being considered in the DRMP/DEIS as an RNA/ACEC and 

management actions would protect the cultural and historic values identified.

This segment is entirely within BLM-administered lands. The area below the segment is private 

and used for grazing.

The reasonably foreseeable potential uses of the land and water which would be enhanced, 

foreclosed or curtailed if the area were included in the NWSRS, and the values which could 

be foreclosed or diminished if the area is not protected as part of the NWSRS:

Valid existing rights (mining claims) may be present. Inclusion of this segment into the NWSRS 

would not enhance any of the uses (livestock grazing, dispersed recreation). Direct recreational 

use of water (fishing, floating, etc.) is not a feature of the area or this river segment and is 

unlikely to be so in the future. The historical and cultural values could potentially be diminished 

by inclusion in the NWSRS by increased visitation and potential vandalism. 

The federal agency or state agency that will administer the river and/or area should it be 

added to the NWSRS:

Bureau of land Management
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Federal, state, local, tribal, or other interests in the designation or non-designation of the 

river, including the extent to which the agency proposes that administration of the river, 

including the costs thereof, be shared by state, local, or other agencies and individuals:

Interest in designation or non-designation of this particular segment appears to be very low. No

comments have been received. It is unknown whether the Native American tribes with affinity 

to this area would support or oppose a WSR designation

The estimated cost to the United States of acquiring necessary lands and interest in lands 

and of administering the area should it be added to the NWSRS:

No costs relating to acquiring lands since none are proposed for acquisition. Recurring activities 

such as patrols and monitoring would continue with or without designation. There would be no 

change in annual costs from current administration.

A determination of the degree to which the state or its political subdivisions might 

participate in the preservation and administration of the river should it be proposed for 

inclusion in the NWSRS:

Any costs associated with the administration of this segment would be the sole responsibility of 

the BLM.

The federal agency’s ability or other mechanisms (existing or potential) to protect and 

manage the identified river-related values other than WSR designation and/or the 

state/local government’s ability to manage and protect the ORVs on non-federal lands:

This area will be considered as an ACEC (Pryor Mountain Foothills RNA /ACEC) and has 

identified management actions to protect historical and cultural values.

An evaluation of the adequacy of local zoning and other land use controls in protecting the 

river’s ORVs by preventing incompatible development:

Local zoning and other land use controls do not pertain to this segment because it is entirely 

located on Federal lands.

Support or opposition to designation:

Public comment showed little interest or support either for or against designation.

Historical or existing rights which could be adversely affected:

There are no Rights of Ways (ROWs) present. 

There is an active grazing permit (Allotment 4105) for the BLM land and grazing is the historic 

use of the private land along and south of the Gyp Springs segment and these would be affected 

if there is a management decision to restrict this activity.

The consistency of designation with other agency plans, programs or policies and in 

meeting regional objectives:

Existing agreements and management policies are in place to protect and enhance the ORVs of 

this segment, particularly the portion located on the PPNM, which overlaps the Lewis and Clark 

NHT (which cover the entire segment). 
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The contribution to river system or basin integrity:

A limited contribution based on the size of the watershed and the size of the river segment as 

well as its physical location. 

The potential for water resources development:

It is unlikely that water impoundments would be installed on the river segment. It is unlikely 

flood control, hydropower facilities, dredging or diversions or channelization will occur.

Finding: Non-suitable X

Rationale: The entire Gyp Springs site is eligible for the National Register for cultural and 

historic values. This area is being considered in the DRMP/DEIS as an RNA/ACEC, and 

management actions would protect the cultural and historic values identified. Non designation 

would be more consistent with current management efforts and the long term goals found in the 

RMP, while management prescriptions in the RMP are in place to protect the river segment. The 

human impacts from the major travel routes all along the west boundary of the river segment 

substantially detract from the wild and scenic river values. 

River Name: Piney Creek

Location, ORV description, and classification:

The Piney Creek segment is located in the southern Pryor Mountains in Carbon County 

approximately four miles northeast of Warren, Montana (Figure 7). Piney Creek flows for about 

1⁄4 mile on the Custer National Forest before entering BLM-administered land at the upper end of 

the segment. The stream is too narrow and shallow for any navigation by watercraft of any size, 

and heavy brush prevents even foot access along most of the segment. 

The Piney Creek segment supports a population of Yellowstone Cutthroat Trout (YCT) 

(Oncorhynchus clarkii bouvieri) that has been designated a “core population” by the Interstate 

YCT Coordination Team. A core population is one that exhibits no hybridization and is 

essentially a genetically pure strain. YCT are listed as a Species of Concern by the MFWP and a 

federally sensitive species by the BLM and U.S. Forest Service. This pure strain YCT is very 

valuable in that they can be used to enhance other YCT populations or establish new populations 

in suitable waters. These fish values are recognized nationally by the fisheries community. The 

ecological and sociological impact of losing a pure strain species is significant in itself. These 

unique fish are recognized nationally within the fisheries community. The creek is accessible by 

road and the habitat is in fair condition. The threats to this population are the small size of the 

population, the irrigation diversion immediately downstream of the segment and the fact that it is 

an isolated stream. The presence of the core population of YCT meets the criteria of an 

outstandingly remarkable value. 

This segment has been tentatively classified as recreational. 

The current status of land ownership, minerals (surface and subsurface), use in the area, 

including the amount of private land involved and associated or incompatible uses. 

BLM Segment Length: 0.16 miles

Total Segment Length: 0.16 miles
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There is vehicle access to and along (within 1⁄4 mile) the segment; there is no legal public access 

although current access across private property is currently unrestricted. An improved dirt road 

parallels the entire segment within 1⁄4 mile. 

The river segment is free of impoundments. 

Livestock grazing is readily evident along the entire river segment.

 

There is a scattered land ownership pattern along Piney Creek which includes: BLM, Custer NF, 

state lands and private. 

There are no active oil and gas leases present. 

The reasonably foreseeable potential uses of the land and water which would be enhanced, 

foreclosed or curtailed if the area were included in the NWSRS, and the values which could 

be foreclosed or diminished if the area is not protected as part of the NWSRS:

No foreseeable changes or values diminished.

The federal agency or state agency that will administer the river and/or area should it be 

added to the NWSRS:

Bureau of Land Management

Federal, state, local, tribal, or other interests in the designation or non-designation of the 

river, including the extent to which the agency proposes that administration of the river, 

including the costs thereof, be shared by state, local, or other agencies and individuals:

The BLM manages only 0.16 miles of Piney Creek. Management of this segment, if included in 

the NWSRS would be difficult.

The estimated cost to the United States of acquiring necessary lands and interest in lands 

and of administering the area should it be added to the NWSRS:

Potential opportunities to acquire lands or interest in lands (willing buyer/willing seller) exist but 

are unlikely to occur. 

A determination of the degree to which the state or its political subdivisions might 

participate in the preservation and administration of the river should it be proposed for 

inclusion in the NWSRS:

It is anticipated that costs associated with the administration of this segment would be the sole 

responsibility of the BLM.

The federal agency’s ability or other mechanisms (existing or potential) to protect and 

manage the identified river-related values other than WSR designation and/or the 

state/local government’s ability to manage and protect the ORVs on non-federal lands:

Due to the limited BLM public land ownership and length of this segment, the YCT core 

population would not necessarily be enhanced by inclusion in the NWSRS. Recurring activities 

such as patrols and monitoring would continue with or without designation.
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An evaluation of the adequacy of local zoning and other land use controls in protecting the 

river’s ORVs by preventing incompatible development:

Local zoning and other land use controls do not pertain to this segment because it is entirely 

located on Federal lands.

Support or opposition to designation:

Interest in designation or non-designation of this particular segment appears to be very low.

Historical or existing rights which could be adversely affected:

Historical or valid existing rights may be impacted through inclusion in the NWSRS. There is an 

active grazing permit (Allotment 4115) for the BLM land and grazing is one of the historic uses

of the State, Forest and public lands along or on this segment and these would be affected if there 

is a management decision to restrict this activity. There is a telephone line Right of Way (Quest 

ROW Case File 57657 and a Big Horn Electrical 7.2 KV overhead line (Case File 74878). 

The consistency of designation with other agency plans, programs or policies and in 

meeting regional objectives:

Current partnerships and management is working to protect the YCT core population of this 

segment. Existing agreements and management policies are in place to protect and enhance the 

ORV (YCT core population) of this segment.

The contribution to river system or basin integrity:

A limited contribution based on the size of the watershed and the size of the river segment as 

well as its physical location.

The potential for water resources development:

It is unlikely that water impoundments would be installed on the river segment. It is unlikely 

flood control, hydropower facilities, dredging or diversions or channelization will occur.

Finding: Non-suitable X

Rationale: Due to the limited BLM public land ownership and length of this segment, the YCT 

core population would not necessarily be enhanced by inclusion in the NWSRS. Existing 

agreements between local, state, and federal agencies are also in place to specifically protect and 

further enhance the YCT core population. The road along the river segment and the travel on it 

would detract from the recreational opportunity and experience since the types of activities on 

the river segment and on the roadway are very different. 

River Name: Yellowstone River, Pompeys Pillar

Location, ORV description, and classification:

The Yellowstone River – Pompeys Pillar is located in Yellowstone County approximated 25 

miles northeast of Billings, Montana (Figure 8). The Yellowstone River flows over 500 miles 

through Montana from the Montana-Wyoming border near Gardiner, northeasterly to the 

Montana-North Dakota boundary northeast of Sidney. About 180 miles of the river flows 
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through the BiFO planning area. Within this 180-mile river reach BLM administers 

approximately 30 miles of shoreline and islands, most of which are small, scattered parcels. 

Recreational opportunities attract local, regional, national and international visitors. In addition 

to being part of the Lewis and Clark National Historic Trail (NHT), this segment includes the 

Pompeys Pillar National Monument which provides visitors the unique and rare opportunity to 

view one of the most important landmarks along the entire Lewis and Clark NHT - Captain 

William Clark’s signature and date of passage carved in the soft sandstone. Wildlife viewing, 

especially birding, is exceptional and attracts local and regional visitors.

The Pillar is a prominent sandstone outcrop separated by erosion from the bluffs on the north 

side of the Yellowstone River. No other similar geologic features are found along Yellowstone 

River between Livingston, Montana and the confluence with the Missouri River.

Pompeys Pillar National Historic Landmark was designated in 1996, and the National Monument 

was designated in 2001. Pompeys Pillar itself is a massive sandstone outcrop with tall vertical 

cliffs, and is marked with over 5,000 inscriptions including petroglyphs, pictographs and historic 

names and dates. Native Americans of prehistoric and historic periods considered Pompeys 

Pillar a notable place on the river. It served as a viewpoint and a camping area, as well as ritual 

location. The location is known to have been a Crow encampment according to the diaries and 

memoirs and stories of both the Crow people and the Euro-Americans. Euro-American 

explorers, trappers and the military used the area as a convenient stopping place on the river. 

Described in diaries by Francois Antoine Larocque, followed by Lewis and Clark and members 

of their expedition, James P. Beckwourth and others, the rock becomes the focus of a variety of 

historic events. Pompeys Pillar is recorded as archaeological site 24YL0176. A rock shelter at 

the pillar may have been a burial area. The Lewis and Clark National Historic Trail is 

documented here with Clarks name and date of July 25, 1806 carved on the pillar during his 

return trip from the west. Clark’s name and date carved on the pillar represents the only 

remaining on-site physical evidence of one of this nation’s most important historical events. 

Cultural Values: Pompeys Pillar has been a natural landmark for the native people of the 

northern plains through the region’s more than 11,000 years of occupation. Most recently it was 

acknowledged as within the homeland of the Crow people. There is archaeological evidence the 

Pillar was used for religious and burial purposes.

The proposed Boundary is approximately 0.25-mile on from river bank on the south side of the 

river. The tentative classification is Recreational.

The current status of land ownership, minerals (surface and subsurface), use in the area, 

including the amount of private land involved and associated or incompatible uses. 

(Jurisdictional consideration must be taken into account to the extent that management 

would be affected.):

BLM Segment Length: 4.19 miles 

Total Segment Lengths: 4.46 miles
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The Pompeys Pillar segment is accessible by road and the river. Development along the segment 

is confined to the area near the Pillar, which includes a large visitor center and associated 

administrative facilities and two bridges. Public land on Bundy Island has been developed by 

MFWP into a Fishing Access Site with a gravel parking area, unpaved boat ramp and vault toilet. 

The river is free of impoundments. Although most of the shoreline is undeveloped, the facilities 

associated with the Pompeys Pillar National Monument constitute substantial evidence of human 

activity. There is active farming on some of the public lands within the corridor. There are two 

bridge crossings. One provides northbound motorized travel and the other is an abandoned 

highway bridge converted to foot traffic.

BLM-administered lands are primarily located along south bank of this segment with one parcel 

of private lands. Pompeys Pillar is currently managed within various zones, including an ACEC 

and a separate National Monument, which already affords protective management. Bundy Island 

is a proposed Special Recreation Management Area, and would be considered no surface 

occupancy (oil and gas) to protect the values of the area. MFWP currently holds a right-of-way 

to maintain a Fishing Access Site. The north bank of this segment is privately owned except for 

a small stretch east of the Pillar; current primary uses include grazing, and residential 

development. 

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 and ACEC, they are withdrawn 

through a Secretarial Withdrawal which was put in place when the BLM acquired the National 

Monument and ACEC. 

There are no active oil and gas leases present.

There are two major bridges which cross the river at this location. One is an abandoned highway 

structure and the other is newer bridge which replaced it. It is the major access portal in the area

north of the river. 

The reasonably foreseeable potential uses of the land and water which would be enhanced, 

foreclosed or curtailed if the area were included in the NWSRS, and the values which could 

be foreclosed or diminished if the area is not protected as part of the NWSRS:

There are multiple local, state and federal agency jurisdictional authorities that partner to address 

impacts to the Yellowstone River. This segment of the Yellowstone River is a part of the 

Huntley Project Irrigation District (which was established in the early 1900s) and there are valid 

existing rights associated with municipal water supplies and irrigation (diversions, distribution 

and return flows) and there are likely incompatible uses already in place. Many of these 

agencies have differing goals and objectives for management and inclusion of this segment in the 

NWSRS could potentially conflict with those mandates and policies.

The existing multi-agency task force sponsored by the United States Army Corps of Engineers 

(USCOE) is addressing management and development along the entire Yellowstone River 

corridor. The goals of this task force are to enhance river values and protect the river 
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Proposed Resource Management Plan and Final Environmental Impact Statement

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environment. There could be some partnership opportunities to provide additional river 

management with MFWP, Yellowstone County, Crow Tribe, USCOE, Bureau of Reclamation 

and local communities or organizations. Concern has been expressed (through Yellowstone 

County Conservation District) about impacts to water rights from any designation. Yellowstone 

County Growth Plan addresses river-related values through their management goals and 

objectives. There are existing regulations in place for floodplain management. 

If this segment is included in the NWSRS it could potentially attract more visitors to Pompeys 

Pillar and Bundy Island and could provide economic benefits to the local communities. The 

facilities are such that the area could accommodate increased visitation at Pompeys Pillar 

without impacting the resource values, as well as increase access opportunities to the 

Yellowstone River in this segment. The overall visitation to the area that may be generated as a 

result of a NWSRS designation is likely to be slight, but could diminish the current recreation 

experience, displace wildlife and create user conflicts. Peak visitation to the area occurred in 

2006 during the Lewis and Clark Bicentennial celebration with visitation nearly 200% of typical 

levels. Since the bicentennial visitation has returned to pre-event levels and is increasing at less 

than 1% per year.

The federal agency or state agency that will administer the river and/or area should it be 

added to the NWSRS:

Bureau of Land Management

Federal, state, local, tribal, or other interests in the designation or non-designation of the 

river, including the extent to which the agency proposes that administration of the river, 

including the costs thereof, be shared by state, local, or other agencies and individuals:

The interest in designation or no designation by federal, state, local and tribal governments and 

national and local publics, as well as the State’s political delegation, is beyond the scope of this 

RMP to consider. It is unknown whether the Native American tribes with affinity to this area 

would support or oppose a WSR designation

The estimated cost to the United States of acquiring necessary lands and interest in lands 

and of administering the area should it be added to the NWSRS:

The BLM has expressed interest in acquiring lands or interest in lands (willing buyer/willing 

seller basis) in the vicinity of Pompeys Pillar. This would enhance the opportunity to manage 

river-related values. 

Several small scattered tracts located south of Interstate 94 have been identified for sale of 

exchange if the opportunity arises to consolidate land tenure patterns.

The interest in designation or no designation by federal, state, local and tribal governments 

and national and local publics, as well as the State’s political delegation, is beyond the 

scope of this RMP to consider. 

The interest in designation or no designation by federal, state, local and tribal governments and 

national and local publics, as well as the State’s political delegation, is beyond the scope of this 

RMP to consider. 
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The federal agency’s ability or other mechanisms (existing or potential) to protect and 

manage the identified river-related values other than WSR designation and/or the 

state/local government’s ability to manage and protect the ORVs on non-federal lands:

Other methods of managing to protect values would be withdrawing the corridor from all mineral 

entry and proposing a No Surface Occupancy for Oil and Gas. All lands along the corridor could 

be placed in a retention zone or the agency could assist in placing conservation easements on 

adjacent private lands. Establishing all lands as VRM class II would help in preserving all values 

along the segment. This classification would not limit development but would provide protection 

through project design mitigation. Historic values could be protected through current historic 

preservation law. Historic and cultural properties could be better protected by providing 

additional educational and interpretive materials for the public. An evaluation of the adequacy of 

local zoning and other land use controls in protecting the river’s ORVs by preventing 

incompatible development:

Support or opposition to designation:

The interest in designation or no designation by federal, state, local and tribal governments and 

national and local publics, as well as the State’s political delegation, is beyond the scope of this 

RMP to consider. 

Historical or existing rights which could be adversely affected:

There are number of existing Rights of Ways (ROWs) which cross the Yellowstone River at this 

location. These rights may be impacted through inclusion in the NWSRS. These include the 

following:

 Case File 27180, a 50’ wide ROW for a 69 KV Power-line owned by Yellowstone Valley 

Electric Co., located in Section 22.

 Case File 94051, an underground ROW owned by Yellowstone Valley Electric Co., 

located in Section 21.

 Case File 90329, a 4.5 ‘wide ROW in Section 21 for the PPNM Visitor Center and 

associated facilities.

 A 7.2 KV Power-line for Yellowstone Valley Electric Co. in Section 20.

 Case File 82286 for the Sikes Act Habitat Agreement in Section 21.

The consistency of designation with other agency plans, programs or policies and in 

meeting regional objectives:

Designation may help or impede the goals of other tribal, federal, State, or Local agencies. 

Designation may contribute to some resource management actions, such as federal, state, or 

regional protection objectives for fish, wildlife, or cultural and historical resources. Similarly, the 

river or a segment portion such as this segment may have a limited recreation activity or setting 

that might better meet statewide, local, or regional goals. In this case as well however, 

designation might limit irrigation and/or flood control measures inconsistent with some regional 

socioeconomic goals. The designation for the public lands described in this river segment would 

be consistent and complementary with the BLM Billings RMP, as well as the Lewis and Clark 

National Historic Trail and the Pompeys Pillar National Monument designations by Congress. 

The PPNM Proclamation is number 7396, with a date of 1/17/2001 and is Case File 91363. 
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The contribution to river system or basin integrity:

Many benefits are likely to result from managing the entire river, including the ability to design 

and then implement a holistic protection strategy in partnership with other agencies and the 

public. The Yellowstone River is the longest undammed river in the lower 48 states of the USA 

and has significant resources and activities occurring all along its entire course. BLM 

management responsibilities in the Billings Field Office are very limited and in most cases 

limited only to the public lands it directly manages (with exceptions such as the Lewis and Clark 

National Historic Trail). 

The potential for water resources development:

The intent of the Act is to preserve selected waters from what would be considered harmful 

effects of water development projects. A designation could limit development of water resource 

projects as diverse as irrigation and flood control measures, hydropower facilities, dredging, 

diversion and channelization. None of these types of projects are being considered on the public 

lands in this segment since the lands have already been reserved as a National Monument and an 

ACEC to protect resource values. However, these projects could be proposed elsewhere on the 

Yellowstone River.

Finding: Non-suitable X

Rationale: All relevant ORVs are provided protection through existing BLM designations and 

other agency management policies. Recreational opportunities could continue to be enhanced 

with or without inclusion in the NWSRS. The human improvements which cross the river 

(ROWs and the two bridges) substantially affect the suitability factor for the tentative

recreational classification. The existence of large agricultural fields and private residences on 

private lands within the corridor on both sides of the river also affects the determination. 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix R R - 45

Wild and Scenic River Management Guidelines

Interim Management of Suitable Segments

The WSR Act requires that interim management measures be developed to protect the free 

flowing nature, outstandingly remarkable values, and recommended classification of suitable 

segments until Congressional action regarding designation is taken. 

The Billings RMP ID Team met in the summer of 2009 to study the seven (7) river segments in 

consideration of the suitability criteria. Discussions from this meeting, as well as other public 

comment form the basis of this suitability assessment. For maps of the river segments, refer to 

the maps at the end of the Eligibility section of this Appendix (above).

Wild and scenic rivers shall be managed with plans prepared in accordance with the 

requirements of the Act, other applicable laws, and the following general management 

principles. Management plans will state: General principles for any land acquisition which may 

be necessary; the kinds and amounts of public use which the river area can sustain without 

impact to the values for which it was designated; and specific management measures which will 

be used to implement the management objectives for each of the various river segments and 

protect esthetic, scenic, historic, archaeological and scientific features. 

If the classification or classifications determined in the management plan differ from those stated 

in the study report, the management plan will describe the changes in the existing condition of 

the river area or other considerations which required the change in classification. 

General Management Principles Section 10(a) states:

“...Each component of the nation’s wild and scenic rivers systems shall be 

administered in such a manner as to protect and enhance the values which caused 

it to be included in said system without, insofar as is consistent therewith, limiting 

other uses that do not substantially interfere with public use and enjoyment of 

these values. In such administration primary emphasis shall be given to 

protecting its esthetic, scenic, historic, archaeologic and scientific features. 

Management plans for any such component may establish varying degrees of 

intensity for its protection and development on the special attributes of the area.”

This section is interpreted as stating a non-degradation and enhancement policy for all 

designated river areas, regardless of classification. Each component will be managed to protect 

and enhance the values for which the river was designated, while providing for public recreation 

and resource uses which do not adversely impact or degrade those values. Specific management 

strategies will vary according to classification but will always be designed to protect and enhance 

the values of the river area. Land uses and developments on private lands within the river area 

which were in existence when the river was designated may be permitted to continue. New land 

uses must be evaluated for their compatibility with the purposes of the Act. 

The management principles which follow stem from section 10(a). Managing principles will be 

implemented to the fullest extent possible under their general statutory authorities and existing 

Federal, State and local laws. Because of these limitations, however, implementation of the 
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Proposed Resource Management Plan and Final Environmental Impact Statement

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principles may differ among and within components of the system depending on whether the 

land areas involved are federally, State, locally or privately owned. 

Carrying Capacity: Studies will be made during preparation of the management plan and 

periodically thereafter to determine the quantity and mixture of recreation and other public use 

which can be permitted without adverse impact on the resource values of the river area. 

Management of the river area can then be planned accordingly. 

Public Use and Access: Public use will be regulated and distributed where necessary to protect 

and enhance (by allowing natural recovery where resources have been damaged) the resource 

values of the river area. Public use may be controlled by limiting access to the river, by issuing 

permits, or by other means available to the managing agency through its general statutory 

authorities. 

Basic Facilities: The managing agency may provide basic facilities to absorb user impacts on the 

resource. Wild river areas will contain only the basic minimum facilities in keeping with the 

“essentially primitive” nature of the area. If facilities such as toilets and refuse containers are 

necessary, they will generally be located at access points or at a sufficient distance from the river 

bank to minimize their intrusive impact. In scenic and recreational river areas, simple comfort 

and convenience facilities such as toilets, shelters, fireplaces, picnic tables and refuse containers 

are appropriate. These, when placed within the river area, will be judiciously located to protect 

the values of the popular areas from the impacts of public use. 

Major Facilities: Major public use facilities such as developed campgrounds, major visitor 

centers and administrative headquarters will, where feasible, be located outside the river area. If 

such facilities are necessary to provide for public use and/or to protect the river resource, and 

location outside the river area is infeasible, such facilities may be located within the river area 

provided they do not have an adverse effect on the values for which the river area was 

designated. 

Motorized Travel: Motorized travel on land or water is generally permitted in wild, scenic and 

recreational river areas, but will be restricted or prohibited where necessary to protect the values 

for which the river area was designated. 

Agricultural and Forestry Practices: Agricultural and forestry practices should be similar in 

nature and intensity to those present in the area at the time of designation. Generally, uses more 

intensive then grazing and hay production are incompatible with river classification. Row crop 

production and timber harvest may be practiced in recreational and scenic river areas. 

Recreational river areas may contain an even larger range of agricultural and forestry uses. 

Timber harvest in any river area will be conducted so as to avoid adverse impacts on the river 

area values. 

Other Resource Management Practices: Resource management practices will be limited to those 

which are necessary for protection, conservation, rehabilitation or enhancement or the river area 

resources. Such features as trail bridges, fences, water bars and drainage ditches, flow 

measurement devices and other minor structures or management practices are permitted when 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix R R - 47

compatible with the classification of the river area and provided that the area remains natural in 

appearance and the practices or structures harmonize with the surrounding environment. 

Water Quality: Consistent with the Clean Water Act, water quality in wild, scenic and 

recreational river areas will be maintained or, where necessary, improved to levels which meet 

Federal criteria or federally approved State standards for aesthetics and fish and wildlife 

propagation. River managers will work with local authorities to abate activities with the river 

area which are degrading or would degrade existing water quality. 

Additional management principles stem from other sections of the Act as follows: 

 Land Acquisition: Section 6 

 Water Resource Development: Section 7 

 Mining: Section 9 

 Management of Adjacent Federal Lands: Section 12(a) 

 Hunting and Fishing: Section 13(a) 

 Water Rights: Section 13(b)-(f) 

 Rights-of-Way: Section 13(a) 

The following policies are consistent with and supplement the management principles stated in 

the Act:

Land Use Controls: Existing patterns of land use and ownership should be maintained, provided 

they remain consistent with the purposes of the Act. Where land use controls are necessary to 

protect river area values, the managing agency will utilize a full range of land-use control 

measures including zoning, easements and fee acquisition.

Rights-of Way: In the absence of reasonable alternative routes, new public utility rights-of-way 

on Federal lands affecting a Wild and Scenic River area or study area will be permitted. Where 

new rights-of-ways are unavoidable, locations and construction techniques will be selected to 

minimize adverse effects on scenic, recreational, fish and wildlife and other values of the river 

area. 

Other legislation applicable to the various managing agencies may also apply to wild and scenic 

river areas. Where conflicts exist between the provisions of the Wild and Scenic Rivers Act and 

acts applicable within the system, the more restrictive provisions providing for protection of the 

river values shall apply.
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An interdisciplinary team of BLM resource specialists prepared this 

Suitability Study.

List of Preparers

Name Role/Responsibility

Tim Finger Recreation, WSR, Visual Resources, Wilderness, 

Travel and Transportation Management

Jay Parks Wildlife, Special Status Species

Larry Padden Noxious and Invasive Species

Sheila Cain GIS

Carolyn Sherve-Bybee Cultural Resources, NEPA, Special Designation 

Areas

Jared Bybee Wild Horses and Burros, Pryor Mountain Wild 

Horse Range 

Dustin Crowe Range, Soils

Ernie McKenzie Riparian, Fisheries

Craig Drake Assistant Field Manager - Consistency Review

Jim Sparks Field Manager

References (Selected, not inclusive)

1986. Bureau of Land Management Handbook, H-8410-1, Visual Resource Inventory, January 

17, 1986.

1992. Wild and Scenic Rivers—Policy and Program Direction for Identification, Evaluation, and 

Management. BLM Manual 8351. Rel. 8-61, May 19, 1992. BLM, Washington DC.

2003. Wild and Scenic Rivers—Policy and Program Direction for Identification, Evaluation, and 

Management. Changes made to original Manual Section 8351. BLM, Washington, DC.

2004a. Instruction Memorandum No. 2004-196, Clarification of Policy in the BLM Manual 

Section 8351, Wild and Scenic Rivers, with Respect to Eligibility Criteria and Protective 

Management. June 21, 2004. BLM, Washington, DC.

Huntington, M.H., and J.D. Echeverria. 1991. The American Rivers Outstanding Rivers List. 

American Rivers, Inc. Washington, D.C.

MFWP (Montana Fish, Wildlife, and Parks). 2004a. MFWP Stream Fishery Classification, 1999 

Final Sport Fisheries Value, Class I and II Streams. Internet Web site: 

http://www.fwp.state.mt.us/fishing/class1and2.pdf.
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Proposed Resource Management Plan and Final Environmental Impact Statement

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2004b. Statewide Comprehensive Outdoor Recreation Plan. Internet Web site: 

http://www.fwp.state.mt.us/parks/scorp/default.asp..

NPS (U.S. Department of the Interior, National Park Service). 2004. Rivers and Trails 

Conservation Assistance Program. Nationwide Rivers Inventory – Montana Segments. Internet 

Web site: http://www.nps.gov/ncrc/programs/rtca/nri/states/mt.html.

BLM (US Department of the Interior) Montana Statewide Wilderness Study Report. September 

1991. Volume II.

Audubon Society Internet Website: http://audubon.org/bird/iba

Forest Service (US Department of Agriculture, National Forest Service) Forest Plan, Gallatin 

National Forest, 1987. Montana.

Interagency Wild and Scenic Rivers Coordinating Council. 1999. The Wild and Scenic River 

Study Process, Technical Report. Washington, D.C.

Lower Yellowstone River Conservation Unit Implementation Team. 2000. Yellowstone 

Cutthroat Trout Management Program within the State of Montana.

American Rivers, Inc. 1991. The American Rivers Outstanding Rivers List. Compiled and Edited 

by M. H. Huntington and J. D. Echeverria, Second Edition, May 1991. American Rivers, Inc., 

Washington, DC.

American Whitewater 2006. Internet Website: 

http://www.americanwhitewater.org/content/River/state-summary/state/MT

BLM Master Title Plats (MTPs):

T. 9 S., R. 27 E.

T. 9 S., R. 26 E.

T. 4 S., R. 16 E.

T. 8 S., R. 26 E.

T. 3 N., R. 30 E.

BLM Range Allotment Files

BLM Right of Way (ROW) Case Files
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Appendix S S - i

Appendix S: 

Livestock Grazing and Range Allotments
Appendix S S - ii

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Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 1

Incorporating GRSG RMP Decisions into Grazing Authorizations 

Purpose

The purpose is to provide recommended language; outline the process for prioritizing the review 

and processing of grazing permits/leases to determine if modification is necessary (prior to 

renewal and in accordance with prioritization criteria); provide direction for including specific 

management thresholds and defined responses that will allow adjustments to livestock grazing 

within the terms and conditions of permits; and provide a process for prioritizing compliance 

monitoring within Sagebrush Focal Areas (SFAs) and Priority Habitat Management Areas 

(PHMAs).

Background

The BLM manages approximately 18,000 livestock grazing permits and leases on the public 

lands. Livestock grazing is an integral part of the BLM multiple-use mission and is authorized 

by the Taylor Grazing Act (1934), the Federal Land Policy Management Act (1976) and the 

Public Rangeland Improvement Act (1978). By statute and regulation, grazing leases and 

permits are normally issued for 10-year periods. Annually, a range of 1,200 to 3,200 grazing 

permits expire and the BLM receives 500 to 1,500 grazing permit/lease transfer requests. 

The BLM currently issues permits/leases in accordance with:

 All applicable law, regulation, policy (NEPA, consultation, proposed/final grazing 

decision-also known as a fully processed permit); or

 Various appropriation authorities enacted between 1999 and 2014 extending terms and 

conditions of expiring or transferred permits/leases that the BLM is unable to fully 

process before their expiration; or 

 Section 402(c)(2) of FLPMA (as amended by Public Law 113-291, enacted December 

19, 2014).

Congress has acted to ensure that grazing permittees could continue to graze if the BLM is 

unable to complete the environmental analysis mandated by the NEPA and other applicable laws. 

Since 1999, a provision (“the rider”) has been included in the Interior Appropriations bill that, in 

various forms, GHMAly authorizes the BLM to renew grazing permits and leases under their 

same terms and conditions until it fully processes the permit renewal in compliance with NEPA, 

ESA, and other legal or regulatory requirements. The most recent rider is contained in Section 

411, Public Law 113-76.1 The FLPMA amendment to Section 402 (c) allows BLM to renew 

 

1 The Consolidated Appropriations Act, 2014 includes the provision Section 411 which states: “Section 415 of 

division E of Public Law 112–74 is amended by striking ‘‘and 2013’’ and inserting ‘‘through 2015.’’ The terms and 

conditions of section 325 of Public Law 108-108 (117 stat. 1307), regarding permits at the Department of the 

Interior and the Forest Service, shall remain in effect through fiscal year 2015. A grazing permit or lease issued by 

the Secretary of the Interior for lands administered by the Bureau of Land Management that is the subject of a 

request for a grazing preference transfer shall be issued, without further processing, for the remaining time period in 

the existing permit or lease using the same mandatory terms and conditions. If the authorized officer determines a 

change in the mandatory terms and conditions is required, the new permit must be processed as directed in section 

325 of Public Law 108-108.” Where a FO is unable to fully process a permit renewal in compliance with all 

applicable laws prior to the permit expiration, Section 411 extends the authority to renew the grazing permit with the 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 2

grazing permits and leases under the same terms and conditions. This relieves the BLM’s 

renewal processing workload, allowing the BLM to prioritize permit processing based on 

sensitivity of the resources at issue.2

The BLM may modify terms and conditions of a permit or lease at any time following 

completion of appropriate analysis and consultation, cooperation, and coordination with the 

affected lessees or permittees, the State having lands or responsible for managing resources 

within the area, and the interested public. 3 Under 43 C.F.R. 4160.1, the BLM must serve a 

proposed decision on any affected applicant, permittee or lessee, any agent and lien holder of 

record. Copies of the decisions are provided to the interested publics. 

Recommended Language to be incorporated as Livestock Grazing Management Actions 

within the GRSG ADPPs:

 The BLM will prioritize the review of grazing permits/leases, including those prior to 

renewal to determine if modification is necessary, and processing of grazing permits 

and leases, in Sagebrush Focal Areas (SFAs) followed by PHMAs outside of the SFAs. 

In setting workload priorities, precedence will be given to existing permits/leases in 

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 conditions (ex., fire) and legal obligations.

 The NEPA analysis for renewals and modifications of livestock grazing permits/leases 

that include lands within PHMAs will include specific management thresholds based on 

GRSG Habitat Objectives Table and Land Health Standards (43 CFR 4180.2) and 

defined responses that will allow the authorizing officer to make adjustments to 

livestock grazing without conducting additional NEPA.

 Allotments within PHMAs, and focusing on those containing riparian areas, including 

wet meadows, will be prioritized for field checks to help ensure compliance with the 

terms and conditions within 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 

will consider whether the public lands where that permitted use was authorized should 

 

same terms and conditions as the expiring permit. Section 325 provides the process for authorizing grazing until a 

permit or lease is issued in compliance with all applicable law and regulatory processes.

2 The newly amended section 402(c) of FLPMA provides permanent authority to BLM to renew expiring permits. 

That section states, “The terms and conditions in a grazing permit or lease that has expired, or was terminated due to 

a grazing preference transfer, shall be continued under a new permit or lease until the date on which the Secretary 

concerned completes any environmental analysis and documentation for the permit or lease required under the 

National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.) and other applicable laws.”

3

43 CFR 4130.3-3 states: Following consultation, cooperation and coordination with the affected lessees or 

permittees, the State having lands or responsible for managing resources within the area, and the interested public, 

the authorized officer may modify terms and conditions of the permit or lease when the active grazing use or related 

management practices are not meeting the land use plan, allotment management plan or other activity plan, or

management objectives, or is not in conformance with the provisions of subpart 4180 (Fundamentals of Rangeland 

Health and Standards and Guidelines for Grazing Administration). 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 3

remain available for livestock grazing or be used for other resource management 

objectives.

Addressing GRSG RMP Amendments/Revisions Objectives in Grazing Permits/Leases 

BLM will develop criteria to prioritize the workload to process permits/leases (either fully 

processed or reauthorized based on the Appropriations rider, or issued under Section 402(c)(2) of 

FLPMA) and determine whether modification is necessary prior to renewal within PHMAs, 

beginning with those in SFAs. In setting priorities, those containing riparian areas and areas not 

meeting Land Health Standards (43 C.F.R. 4180) will take precedence. Potential criteria for 

prioritizing permit modifications could include:

 Are there riparian areas or wet meadows in the permit/lease area?

 Was current livestock grazing identified as a causal factor for not meeting Land Health 

Standards?

 Since the last allotment/watershed evaluation, is there current monitoring information to 

determine that the watershed/allotment is currently achieving or making significant 

progress towards achieving land health standards?

 Does the permit have terms and conditions adequate to ensure proper grazing practices to 

meet GRSG habitat objectives found in the Special Status Species section of the land use 

plan? 

 Is there data that indicates that the GRSG habitat objectives, including the Habitat 

Objectives table, found in the Special Status Species section of the land use plan are 

being met? 

 Is there a request from the permittee to modify the terms and conditions of his/her 

permit?

Additionally, if an existing permit/lease within PHMAs requires modification because current 

grazing is a significant causal factor for not meeting the Land Health Standards, the BLM will 

prepare the appropriate NEPA analysis and issue the proposed/final grazing decision under 43 

C.F.R. Subpart 4160, subject to administrative appeal and potential judicial challenge.

The NEPA analysis for renewals and modifications of livestock grazing permits/leases that 

include lands within SFAs and PHMAs will include specific management thresholds based on 

GRSG Habitat Objectives Table and Land Health Standards (43 CFR 4180.2) and defined 

responses that will allow the authorizing officer to make adjustments to livestock grazing 

without conducting additional NEPA. Adjustments to meet seasonal Sage-Grouse habitat 

requirements could include: 

o Season or timing of use;

o Numbers of livestock (includes temporary non-use or livestock removal);

o Distribution of livestock use;

o Intensity of use; and

o Type of livestock (e.g., cattle, sheep, horses, llamas, alpacas and goats).
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 4

Compliance Monitoring 

The BLM will monitor grazing permits/leases renewed or modified in accordance with the 

direction contained in this guidance as follows: Allotments within SFAs, followed by those in 

other PHMA, and focusing on those with riparian areas, will be prioritized for monitoring to 

ensure compliance with the terms and conditions in the permits. The BLM will collect, at a 

minimum, the following monitoring data: 

 Vegetation Condition

 Actual Use

 Utilization 

 Use Supervision

Concerning Voluntary Relinquishments

All ADPPs will include the following language:

At the time a permittee or lessee voluntarily relinquishes a permit or lease, the BLM will 

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.

For completing this, BLM offices should use WO IM 2013-184 Relinquishment of Grazing 

Permitted Use or the most recent policy guidance.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 5

S. Range Allotments

Allotment 

Number

Public 

Acres

Public 

AUMs

Management 

Status1

Livestock 

Kind2

Land Health Status3

Threatened, Endangered, and 

Special Status Species5

Sage Grouse Status4 Determination/ Standard/ Causal

Factor/ Year

1 38313 50 AUMS 

120 AML

M C

WH/B

Not Meeting / 1,2,5/wild horses/ 

2004

FM, PB, TBEB, MP, PF, YCT, 

DR, DM, MPP, LB, OEP, PC, 

SHOSH, SM, WM, YB

None

955 40 6 C C None WO, GB None

960 1533 213 M C None BTPD, GSG RA

970 640 146 C C None None

978 40 6 C C None GB None

1460 1493 192 M C None TBEB, GSG, RHW None

1555 320 72 C C Meeting 2009 BTPD, WTPD, BO, GSG PHMA

3114 40 4 C C None GSG RA

3155 320 45 M C None BTPD None

3195 474 81 C C None TBEB, RHW None

4100 230 48 C C SPT /1,5/ weeds/ 2008 BTPD, GSG, MS GHMA

4101 6013 1253 I C Meeting 2002 BTPD, BO, GE, GSG, MP PHMA

4103 50 15 C C SPT/1,5/weeds/2009 GSG, GSHL None

4104 540 63 C C Meeting 2010 GSG None

4105 20216 614 I C Meeting 2002 FM, PB, TBEB, BGG, BRSP, 

CCL, GSG, MP, ST, LS, YCT, 

GSHL, DR, DD, DM, GEM, MPP, 

OEP, SC, SH, WRM, YB

PHMA

4106 200 36 C C Meeting 2009 GSHL, YB None

4107 120 20 C C Meeting 2008 None
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 6

Allotment 

Number

Public 

Acres

Public 

AUMs

Management 

Status1

Livestock 

Kind2

Land Health Status3

Threatened, Endangered, and 

Special Status Species5

Sage Grouse Status4 Determination/ Standard/ Causal

Factor/ Year

4108 20 5 C C Meeting 2008 None

4109 880 210 C C Meeting 2009 BTPD, GSG, MS GHMA

4110 320 21 C C Meeting 2007 TBEB, MP, DM, GEM, WRM, YB None

4111 1475 228 I C Meeting 2009 GSG, GSHL, MS PHMA

4112 520 40 C C Meeting 2006 GSG, GSHL PHMA

4113 3331 453 I C Meeting 2011 BO, GSG, DM PHMA

4114 1000 161 M C Meeting 2009 WTPD, BTPD, BO, GSG PHMA

4115 17101 1767 M C Meeting 2002 TBEB, BGG, BRSP, GSG, BO, 

ST, LS, MP, YCT, GSHL, DD, 

NA, SC, SMBU, SH

PHMA

4116 200 37 C C Meeting 2011 None

4117 20 5 C C Meeting 2008 None

4118 1088 110 M C Meeting 2007 GSG PHMA

4119 1320 309 M C Meeting 2007 GSG, GSHL PHMA

4120 505 76 M C SPT/1,5/weeds/2009 GSG, GSHL PHMA

4122 520 132 C C Meeting 2000 None

4123 80 16 C C Meeting 2009 None

4124 280 34 M C Meeting 2002 BGG, BRSP, GSG, BO PHMA

4125 468 76 C C Meeting 2002 None

4126 1338 218 M C Meeting 2003 TBEB, GSHL, GM, PC None

4127 320 32 C C Meeting 2008 GSG, PS PHMA

4128 240 37 C C SPT/1,5/weeds/2008 GSG GHMA

4129 880 146 M C Meeting 2007 GSG, MS, PS PHMA

4131 1894 275 M C Meeting 2007 BGG, GSG, PS PHMA
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 7

Allotment 

Number

Public 

Acres

Public 

AUMs

Management 

Status1

Livestock 

Kind2

Land Health Status3

Threatened, Endangered, and 

Special Status Species5

Sage Grouse Status4 Determination/ Standard/ Causal

Factor/ Year

4132 960 107 M C Meeting 2002 BGG, GSG, BRSP, LS, ST, LBC, 

YCT, GSHL

PHMA

4133 1380 196 M C Meeting 2002 BGG, BRSP, GSG, LBC, ST, LS PHMA

4134 720 7 C C Meeting 2003 None

4135 4943 432 I C Meeting 2011 BGG, BOB, BO, GSG, ST PHMA

4136 80 28 C C Meeting 2002 BO, GSG PHMA

4137 963 288 M C Meeting 2003 FH, GE, GSG PHMA

4138 40 7 C C Meeting 2009 None

4140 1635 456 C C Meeting 1999 GE, GSG PHMA

4141 480 127 M C Meeting 2009 BTPD, GSG GHMA

4142 40 12 C C Meeting 2004 BE GHMA

4143 608 158 M C Meeting 2002 GSG PHMA

4144 2658 443 M C Meeting 2010 GSG GHMA

4145 160 55 C C Meeting 2000 None

4147 40 4 C C Fail/1,5/livestock/2009 GSG PHMA

4148 840 77 I C None CL, GB, WO, GSG, BLFG PHMA

4150 890 94 C C Meeting 2002 GSG PHMA

4151 160 46 M C Meeting 2002 GSG PHMA

4152 1818 169 M C Meeting 2002 BTPD, BE, GSG, SA, SS RA

4153 160 30 C C Meeting 2003 GSG RA

4154 200 30 C C Meeting 2003 BTPD, BE, GSG, RHW, SA, SS RA

4156 369 58 C C Meeting 2009 GB, PF None

4157 160 16 C C Meeting 2011 None
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 8

Allotment 

Number

Public 

Acres

Public 

AUMs

Management 

Status1

Livestock 

Kind2

Land Health Status3

Threatened, Endangered, and 

Special Status Species5

Sage Grouse Status4 Determination/ Standard/ Causal

Factor/ Year

4158 240 37 C C Meeting 2006 BTPD None

4159 640 94 M C Meeting 2004 None

4160 1440 388 I C Fail/1,5/livestock/2002 BTPD, GSG RA

4161 3275 281 I C Meeting 2011 GSG PHMA

4162 80 16 C C Meeting 2003 YBC None

4163 40 8 C C Meeting 2003 YBC None

4165 640 180 M C SPT/1,5/livestock/2008 None

4166 120 24 C C Meeting 2001 None

4167 7515 427 I C SPT/1,5/livestock/2005 BRSP, GE, GSG, LS, GSHL, YB PHMA

4168 40 5 C C Meeting 2009 GB, WO, NG None

4169 265 44 C C Meeting 2008 GSG None

4170 320 47 C C Meeting 2010 GSG RA

4171 290 57 C C Meeting 2011 None

4172 40 4 C C None BE None

4173 40 5 C C None GB, WO None

4175 40 8 C C None GSG PHMA

4803 35 9 C C Meeting 2011 GSG, GSHL None

4804 300 20 M C Meeting 2011 GSG PHMA

4808 472 111 C C Meeting 2009 GE, GSG PHMA

4903 6734 1752 M C Meeting 2008 FH, GE, GSG PHMA

4904 40 10 C C Meeting 2009 GSG PHMA

4905 2160 508 M C Meeting 2006 GSG, GSHL PHMA

4907 2562 528 I C SPT/1,5/livestock/2010 BTPD, BRSP, GE, GSG, ML, MP PHMA
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 9

Allotment 

Number

Public 

Acres

Public 

AUMs

Management 

Status1

Livestock 

Kind2

Land Health Status3

Threatened, Endangered, and 

Special Status Species5

Sage Grouse Status4 Determination/ Standard/ Causal

Factor/ Year

4908 160 62 M C Meeting 2007 GSG GHMA

4911 960 275 C C Meeting 2009 BTPD, GE, GSG PHMA

4912 40 6 C C Meeting 2007 None

4913 187 31 C C Meeting 2008 BRSP, GE, GSG, LS, ST, LIB PHMA

4914 80 17 C C Meeting 2010 GSG PHMA

4915 80 12 C C Meeting 2002 BTPD, GSG PHMA

4916 40 9 C C Meeting 2006 GSG PHMA

4917 200 48 C C Meeting 2008 BTPD, BO, GSG GHMA

4919 40 12 M C Meeting 2002 BTPD, GE, GSG, GSHL GHMA

4920 1120 133 M C Meeting 2009 BTPD, GE, GSG, GSHL GHMA

4921 833 234 I C Meeting 2002 BTPD, GSG PHMA

4922 317 102 M C Meeting 2008 GSG PHMA

4924 1320 305 M C Meeting 1999 BTPD, BO, GSG PHMA

4926 1021 304 M C Fails/1,5/livestock/2009 BTPD, GE, GSG PHMA

4929 600 168 M C Meeting 2009 GSG PHMA

4930 200 45 M C Meeting 2009 GSG GHMA

4931 702 208 M C Meeting 2002 GSG GHMA

4932 160 37 M C Meeting 2006 GSG GHMA

4933 320 74 M C Meeting 2009 None

4934 2073 516 M C Meeting 2006 TBEB, GSG GHMA

4935 800 230 M C Meeting 2009 None

4936 680 69 M C SPT/1,5/weeds/2008 None

4937 640 210 M C STP/1/livestock/2005 GSG PHMA
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 10

Allotment 

Number

Public 

Acres

Public 

AUMs

Management 

Status1

Livestock 

Kind2

Land Health Status3

Threatened, Endangered, and 

Special Status Species5

Sage Grouse Status4 Determination/ Standard/ Causal

Factor/ Year

4938 160 39 M C Meeting 2000 GSG PHMA

4939 1400 315 I C SPT/1,5/livestock/2008 None

4940 2840 580 M C Meeting 2010 None

4941 2212 649 M C Meeting 2010 BTPD, BO, GSG, MP PHMA

4942 70 12 C C Meeting 2003 SS None

4943 1759 489 M C Meeting 2009 GSG PHMA

4944 160 47 M C Meeting 2008 TBEB, GSG None

4945 1911 531 I C Meeting 2009 GSG GHMA

4947 7454 1825 M C Meeting 2009 GSG PHMA

4948 640 178 M C Meeting 2009 GSG GHMA

4949 5135 1298 M C Meeting 2008 BTPD, BRSP, BO, GE, GSG, ML, 

MP

PHMA

4950 967 259 I C STP/1/livestock/2005 GSG PHMA

4951 1800 415 I C SPT/1,5/livestock/2008 GSG PHMA

4952 160 41 M C Meeting 2008 None

4953 655 167 M C Meeting 2002 None

4954 1170 305 I C Meeting 2000 GSG GHMA

4955 40 10 C C SPT/1/livestock/2009 GSG GHMA

4968 1280 369 M C Meeting 2006 GSG PHMA

4969 960 264 I C None GSG GHMA

4970 640 137 M C Meeting 2003 GSG PHMA

4971 2561 731 I C Meeting 2002 BO, BRSP, CCL, GE, GSG, LBC, 

ML, RHW, ST

PHMA

4972 5776 1626 M C Meeting 2011 BTPD, FH, GSG PHMA
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 11

Allotment 

Number

Public 

Acres

Public 

AUMs

Management 

Status1

Livestock 

Kind2

Land Health Status3

Threatened, Endangered, and 

Special Status Species5

Sage Grouse Status4 Determination/ Standard/ Causal

Factor/ Year

4974 1180 401 M C Meeting 1999 BTPD, GSG, FH GHMA

4975 800 288 I C Meeting 2008 FH, GSG, ML PHMA

4976 320 114 M C Meeting 2006 FH, GSG GHMA

4978 40 12 C C Meeting 2000 GSG GHMA

4979 640 245 M C Meeting 2002 BRSP, CCL, GSG, LBC, ML, 

RHW, ST

PHMA

4980 320 125 M H Meeting 1998 GSG GHMA

4981 6520 1344 I C Meeting 2004 BTPD, BO, FH, GSG, ML PHMA

4982 320 96 M C Meeting 2001 GSG GHMA

4983 200 47 M C Meeting 2002 GE, GSG PHMA

4984 664 257 M C Meeting 2006 GSG GHMA

4985 160 50 C C Meeting 2008 BRSP, CCL , GSG, ML, LBC, 

RHW, ST

GHMA

4986 40 9 C C Meeting 2002 WHNS None

4987 40 9 C C Meeting 2009 GSG, WHNS PHMA

4988 2986 734 I C Meeting 2002 BTPD, BO, FH, GSG, ML PHMA

4989 1011 193 C C Meeting 1999 BTPD, GSG PHMA

4991 800 169 M C Meeting 2002 GSG PHMA

4992 492 174 M C Meeting 2002 GE, GSG PHMA

4994 520 102 C C SPT/1/weeds/2009 BTPD, GE, GSG PHMA

4995 240 55 C C Meeting 2009 BTPD, BO ,GSG PHMA

4996 480 94 C C Meeting 2009 BTPD, GE, GSG PHMA

4997 120 22 C C Meeting 2002 GSG PHMA

4998 200 48 C C Meeting 2002 GSG, WHNS PHMA
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 12

Allotment 

Number

Public 

Acres

Public 

AUMs

Management 

Status1

Livestock 

Kind2

Land Health Status3

Threatened, Endangered, and 

Special Status Species5

Sage Grouse Status4 Determination/ Standard/ Causal

Factor/ Year

4999 40 4 C C Meeting 2007 GSG PHMA

5000 158 41 C C Meeting 2000 BTPD, GSG PHMA

5002 512 110 C C Meeting 2007 GSG PHMA

5004 80 24 C C Meeting 2009 GSG PHMA

5006 160 36 C C Meeting 2004 BRSP, CCL, GSG, LS, ST PHMA

5007 80 12 C I Meeting 2004 BTPD, BRSP, CCL, GSG, ST PHMA

5008 160 17 C C Meeting 2009 BE, GSG PHMA

5012 160 36 C C Meeting 2009 BTPD, GSG PHMA

5020 640 150 C C Meeting 2009 BRSP, GSG, LS, ST PHMA

5200 200 40 C C SPT/1,5/weeds/2008 GE, GSHL GHMA

5201 40 7 C C None None

5202 17447 1430 I C Meeting 2003 BRSP, GE, GSG, LS PHMA

5203 9552 1021 I C Meeting 2004 CL, GB, WO, GE, GSG, LS, PS, 

BLFG, SHOSH

PHMA

5204 1340 88 M C Meeting 2009 BRSP, GSG, ST PHMA

5205 32 5 C C Meeting 2008 GSG PHMA

5206 200 20 C S SPT/1,5/weeds/2008 GSHL None

5207 80 7 C C Meeting 2002 GE, GSG, GSHL PHMA

5208 720 132 C C Meeting 2009 GSG PHMA

5209 1115 127 M C Meeting 2003 GSG PHMA

5210 10272 748 I C SPT/1,2/livestock/2006 BRSP, GE, GSG, LS, ST PHMA

5212 40 13 C S Fails/1/livestock/2008 GSG GHMA

5213 5940 481 M C SPT/1,5/livestock/1999 GSG, GSHL, MS, PS PHMA
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 13

Allotment 

Number

Public 

Acres

Public 

AUMs

Management 

Status1

Livestock 

Kind2

Land Health Status3

Threatened, Endangered, and 

Special Status Species5

Sage Grouse Status4 Determination/ Standard/ Causal

Factor/ Year

5214 1970 151 M C SPT/1/livestock/2009 BTPD, GSG PHMA

5215 480 60 C C Fails/1,5/livestock/2009 GSG, GSHL PHMA

5217 6961 442 M C Meeting 2002 WTPD, BO, GSG, GM, OEP PHMA

5219 200 24 C C Meeting 2008 GE, GSG, GSHL PHMA

5220 80 16 C H Meeting 2009 WO None

5221 520 68 M C SPT/1,5/livestock/2003 GSG PHMA

5222 80 16 C C Meeting 2000 GSHL None

5223 35 12 C C Meeting 2006 GSG None

5224 1395 90 M C Meeting 2004 GSG PHMA

5225 15294 1295 I C Meeting 2003 GB, WO, BRSP, GE, GSG, LS, 

LBC, PF, ST, GSHL, 

BLFG,SHOSH

PHMA

5228 240 30 C C Meeting 2004 GSHL None

5229 1837 201 C C Meeting 2002 BRSP, GE, GSG, LS, LBC PHMA

5231 160 40 C H Meeting 2004 None

5232 1040 120 I C Meeting 2007 GSG GHMA

5233 255 52 M C None BRSP, GSG, LBC PHMA

5235 6369 425 I C Meeting 2004 GE, GSG, LS, GSHL, MS, DM PHMA

5300 5240 856 I C Meeting 2006 BTPD, GSG RA

5302 2147 344 I C Meeting 2006 BTPD, BO, GSG, GSHL, MS RA

5304 3035 351 I C Meeting 2010 BTPD, BE, SA, SS None

5307 960 130 M C Meeting 1999 GSG None

5308 380 134 C C Meeting 2001 None

5309 400 78 C C Meeting 2009 BTPD, BO, GSG RA
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 14

Allotment 

Number

Public 

Acres

Public 

AUMs

Management 

Status1

Livestock 

Kind2

Land Health Status3

Threatened, Endangered, and 

Special Status Species5

Sage Grouse Status4 Determination/ Standard/ Causal

Factor/ Year

5310 839 146 C C Meeting 2003 BTPD, BE, GSG, SA, SS RA

5311 3275 455 I C Meeting 2006 BE, GSG RA

5312 2480 300 M C Meeting 2006 TBEB, GSG RA

5314 1910 610 M C Meeting 2009 BTPD, GSG RA

5318 1355 175 M C Meeting 2008 GSG None

5320 1577 222 I C Meeting 2006 BTPD None

5322 638 89 M C Meeting 2006 BTPD, GSG RA

5324 80 15 C C Meeting 2011 GSG None

5326 480 70 M C Meeting 2004 BTPD, BE, GSG, SA, SS RA

5329 120 12 C C Meeting 2006 BTPD, BE, GSG RA

5330 184 24 C C Meeting 2011 None

5331 200 36 M C Meeting 2010 BTPD, GSG None

5332 960 248 M C Meeting 2002 None

5333 160 37 M C Meeting 2001 None

5335 320 36 C C Meeting 2008 None

5337 1082 111 M C Meeting 2006 TBEB, RHW None

5338 1033 166 M C Meeting 2006 BTPD, GSG RA

5339 1600 266 M C Meeting 2002 RA

5340 640 92 M C Meeting 2003 GE, GSG RA

5341 4000 542 M C Meeting 2006 BTPD, BE, GSG, SA, SS None

5342 80 15 C C Fails/1,5/livestock/2009 BE, BO None

5344 640 45 M C SPT/1/OHV/2009 GSG None

5345 1465 79 C C Meeting 2010 GSG RA
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 15

Allotment 

Number

Public 

Acres

Public 

AUMs

Management 

Status1

Livestock 

Kind2

Land Health Status3

Threatened, Endangered, and 

Special Status Species5

Sage Grouse Status4 Determination/ Standard/ Causal

Factor/ Year

5346 320 50 C C Meeting 2001 None

5347 320 55 C C Meeting 2000 GSG RA

5348 1916 384 M C Meeting 2000 None

5349 136 16 C C Meeting 2000 None

5350 1980 273 I C Meeting 2006 BTPD, BE, BO, GSG RA

5353 1258 180 C C Meeting 2006 GE, GSG RA

5354 40 21 C C Meeting 2006 BTPD, GSG, LS RA

5355 1760 313 M C Meeting 2007 BTPD, GSG RA

5356 3559 483 I C Meeting 2010 BTPD, GSG RA

5357 37 8 C C Meeting 2008 None

5361 320 48 M C Meeting 2008 BTPD, GSG RA

5362 560 72 M C SPT/1,5/livestock/2010 BE, GSG, SA, SS RA

5363 320 53 M C Meeting 2006 GSG RA

5370 4039 679 M C Meeting 2006 BTPD, GSG RA

5371 980 169 M C Meeting 2006 BTPD, GSG RA

5372 640 100 M C Meeting 2006 GSG None

5375 68 24 C C Meeting 2008 GSG, GSHL RA

5377 233 34 C C Meeting 2002 GSG RA

5378 1280 213 M C Meeting 2002 RA

5379 1708 290 M C Meeting 2003 BTPD, GSG, GSHL RA

5380 1672 347 M C Meeting 2003 BTPD, BE, GSG, SA, GSHL, SS RA

5403 80 17 C C Fail/1/livestock/2010 BE, GE None

5404 40 10 C C Meeting 2004 None
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 16

Allotment 

Number

Public 

Acres

Public 

AUMs

Management 

Status1

Livestock 

Kind2

Land Health Status3

Threatened, Endangered, and 

Special Status Species5

Sage Grouse Status4 Determination/ Standard/ Causal

Factor/ Year

5405 132 30 C C Meeting 2010 None

5407 80 12 C C Meeting 2000 BOB None

5409 896 184 C C Meeting 2006 GSG GHMA

5414 388 75 M C Meeting 2009 CL, GB, WO None

5416 80 23 C C Meeting 2004 None

5417 80 16 C C Meeting 2004 None

5418 40 8 C C Meeting 2006 None

5419 120 24 C C Meeting 2000 None

5424 78 12 C C Meeting 2010 None

5426 97 15 C C Meeting 2003 BE, GSHL None

5427 119 24 C C Meeting 2008 GSG, PF GHMA

5432 40 10 C C Meeting 2008 None

5434 160 50 C C Meeting 2008 GB, BOB, GSG GHMA

5435 80 15 C C SPT/1,5/weeds/2008 BE, BOB None

5437 308 60 C C Meeting 2001 GB, WO, GSG None

5438 40 13 C C Meeting 2008 None

5439 360 24 C C Meeting 2009 CL, GB, WO None

5440 60 10 C C SPT/1,5/weeds/2008 BE, BOB None

5441 40 8 C C SPT/1,5/weeds/2008 None

5444 120 29 C C Meeting 2006 None

5446 40 8 C C Meeting 2006 None

5449 40 10 C C Meeting 2007 BE None

5451 414 62 C C Fail/1,5/livestock/2009 BE, GE None
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 17

Allotment 

Number

Public 

Acres

Public 

AUMs

Management 

Status1

Livestock 

Kind2

Land Health Status3

Threatened, Endangered, and 

Special Status Species5

Sage Grouse Status4 Determination/ Standard/ Causal

Factor/ Year

5453 215 49 C C Meeting 2008 GSG GHMA

5454 320 36 C C Meeting 2003 GSG, YBC GHMA

5458 80 20 C C Meeting 2002 None

5460 80 17 C C Meeting 2008 BOB None

5461 480 24 C C Meeting 2001 GB, WO None

5466 826 72 C C Meeting 2011 GB, WO None

5467 40 14 C Y Fail/1,5/weeds and fire/2007 None

5470 160 36 C C Meeting 2008 GSG GHMA

5471 674 120 C C Meeting 2009 None

5472 40 6 C C Meeting 2008 NONE

5474 533 163 C C Meeting 2009 GSG GHMA

5476 160 20 C C Meeting 2003 FM, GB, WO None

5477 640 114 C C Meeting 2009 GSG, PF GHMA

5483 91 8 C C Meeting 2009 None

5485 80 11 C C Meeting 2008 GB, PF None

5486 40 9 C C Meeting 2008 BASP, LBC None

5488 481 70 C C SPT/1,5/weeds/2008 None

5490 567 103 C C Meeting 2009 BE, GE, PF None

5492 1197 266 C C Meeting 2003 GB, WO, YCT None

5498 240 24 C C Meeting 2010 None

5500 81 18 C C Meeting 2009 None

5501 560 14 C C Meeting 2009 CL, GB, WO None

5502 40 6 C C SPT/1,5/weeds and fire/2008 GB, WO None
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 18

Allotment 

Number

Public 

Acres

Public 

AUMs

Management 

Status1

Livestock 

Kind2

Land Health Status3

Threatened, Endangered, and 

Special Status Species5

Sage Grouse Status4 Determination/ Standard/ Causal

Factor/ Year

5503 520 63 C C Meeting 2009 GB, WO None

5504 87 8 C C Meeting 2001 None

5505 120 24 C C Meeting 2002 GB None

5508 40 7 C C SPT/1,5/weeds/2008 BE, BOB, PF None

5510 160 35 C C Meeting 2004 WO None

5511 40 15 C C Meeting 2004 GHMA

5512 80 17 C C Meeting 2008 None

5515 80 20 C C Meeting 2008 None

5516 337 58 C C Meeting 2001 None

5517 1040 180 C C SPT/1,5/OHV/2010 YCT, GSHL, MS, SS, WHNS None

5520 609 120 C C Meeting 2010 BE None

5521 160 32 C C Meeting 2001 None

5522 843 133 C C Meeting 1999 GB, WO, BOB, GSG None

5523 480 88 C C Meeting 2009 None

5524 160 34 C C Meeting 2008 GSG GHMA

5525 40 9 C C Meeting 2006 GSG GHMA

5532 107 42 C C Meeting 2008 GSG GHMA

5533 72 28 C C Meeting 2004 BOB, GSG, PF GHMA

5534 360 58 C H Meeting 2009 None

5535 40 8 C C Meeting 2004 None

5537 30 5 C C Meeting 2006 YBC None

5539 40 8 C C Meeting 2008 None

5540 40 13 C C Meeting 2008 BOB, GSG, PF None
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 19

Allotment 

Number

Public 

Acres

Public 

AUMs

Management 

Status1

Livestock 

Kind2

Land Health Status3

Threatened, Endangered, and 

Special Status Species5

Sage Grouse Status4 Determination/ Standard/ Causal

Factor/ Year

5543 345 75 C C Meeting 2010 GB, WO, GSG None

5544 160 20 C C Meeting 2002 GSG GHMA

5545 685 215 C C Meeting 2000 None

5546 80 16 C C SPT/1,5/weeds & livestock/2008 MS None

5547 2867 566 M C Meeting 2002 GE, GSG PHMA

5548 710 139 I C Meeting 2009 GB None

5549 40 12 C C Meeting 2008 FH, GSG GHMA

5550 140 23 C C Meeting 2003 GB, WO None

5552 802 167 C C SPT/1,5/weeds & fire/ 2008 GB, WO None

5553 79 20 C C Meeting 2008 MS None

5555 303 66 C C Meeting 2009 None

5556 120 10 C C Meeting 2003 BE None

5557 240 14 C C Meeting 2003 CL, GB, WO None

5558 320 62 C C Meeting 2010 GB None

5559 141 19 C C Meeting 2006 GSG GHMA

5560 120 24 C C Meeting 2008 None

5562 240 46 C C Meeting 2004 GB, PF None

5565 25 6 C C Meeting 2010 GSG GHMA

5566 40 8 C H Meeting 2008 GSG GHMA

5567 40 24 C C Meeting 2004 None

5568 40 5 C C None None

5569 80 24 C C Meeting 2006 GSG GHMA

5571 80 10 C C Meeting 2006 BE None
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 20

Allotment 

Number

Public 

Acres

Public 

AUMs

Management 

Status1

Livestock 

Kind2

Land Health Status3

Threatened, Endangered, and 

Special Status Species5

Sage Grouse Status4 Determination/ Standard/ Causal

Factor/ Year

5572 640 97 C C Meeting 2008 GSG GHMA

5573 110 36 C C Meeting 1999 GSG GHMA

5580 280 39 C C Meeting 2002 None

5581 160 26 C C SPT/1,5/weeds & fire/ 2008 GB None

5582 40 10 C C Fail/3/unknown/2009 GSG GHMA

5585 480 50 C C Meeting 2003 GB, YCT None

5586 40 8 C C Meeting 2008 None

9648 40 7 C C Meeting 2009 GSG GHMA

9652 40 14 C C Meeting 2008 LBC, MP None

9654 40 13 C C Meeting 2006 None

9660 39 13 C C SPT/1,5/fire/2008 BE None

9661 440 139 C C Meeting 2008 None

9667 160 26 C C Meeting 2010 GSG GHMA

9678 205 35 C C Meeting 2008 None

9680 320 64 C C Meeting 2008 TBEB None

9682 80 13 C C Meeting 2010 None

9686 40 6 C C Meeting 2006 None

9712 200 62 C C SPT/1,5/weeds/2009 GSG, WHNS GHMA

9719 160 22 C C Fails/2/livestock/2009 SS None

9720 40 12 C C Meeting 2008 BE None

9734 213 64 C C Meeting 2006 None

9736 80 21 C C Meeting 2001 SS None

9737 80 16 C C Meeting 2009 None
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 21

Allotment 

Number

Public 

Acres

Public 

AUMs

Management 

Status1

Livestock 

Kind2

Land Health Status3

Threatened, Endangered, and 

Special Status Species5

Sage Grouse Status4 Determination/ Standard/ Causal

Factor/ Year

9740 65 13 C C Meeting 2009 None

9744 520 121 M C Meeting 2008 None

9765 200 44 C C Meeting 2004 WO None

9768 40 8 C C Meeting 2008 WO None

9781 162 38 C C Meeting 2001 LBC None

9789 31 8 C C Meeting 2008 None

9791 1042 336 M C Meeting 2009 BTPD, GE, GSG PHMA

9792 38 10 C C Meeting 2008 LBC, MP None

9805 160 64 C C Meeting 2001 None

9824 80 15 C C Meeting 2008 GSHL None

9837 80 18 C C Meeting 2000 None

9840 169 37 C C Meeting 2008 None

9843 241 33 C C Meeting 2009 None

9844 240 54 C C Meeting 2009 GSG PHMA

9845 320 102 C C Meeting 2010 None

1003* 20968 1642 M C None WTPD, BRSP, GE, GSG, ST, PS PHMA

1005* 5413 455 M C Fail/1,2,3,4/livestock/2011 WTPD, GSG, LS, PS, DD, GEM 

MC, OEP, SMBU, SH

PHMA

1011* 2660 140 C C None PB, TBEB, WTPD, BGG, BRSP, 

GSG, LS, MP, ST, GSHL, SH, 

DM

PHMA

*Allotments administered by the Cody Field Office, but contain public lands located in Montana
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 22

1. Management Status

“I” means that the allotment is in an “Improve Status”. Major goals and objectives are for improvement of ecological conditions.

“M” means that the allotment is in a “Maintain Status”. Major goals and objectives are to maintain current acceptable ecological conditions.

“C” means that the allotment is in a “Custodial Status”. Custodial allotments are typically small, isolated and unfenced parcels of public land with little or no 

management opportunity.

2. Livestock Kind 

 “C” = Cattle

“H” = Horses

“I” = Indigenous

“S” = Sheep

“Y” = Yearling (cattle)

“WH/B” = Wild Horse and Burro

3. Land Health Status

This column lists the results of the most recent monitoring data collected on the grazing allotment, and the year the determination was made. 

Determination

Meeting- All standards for rangeland health are being achieved.

SPT- All standards other than those listed are achieving standards. The standard(s) listed is making significant progress towards 

meeting standards.

Fail- All standards other than those listed are achieving standards. The standard(s) listed are failing to achieve the standard.

None- No monitoring data has been collected on this allotment.

Standards

Montana standards for rangeland health Wyoming standards for rangeland health

1. Upland health 1. Soil health

2. Riparian and wetlands 2. Riparian and wetland vegetation

3. Water quality 3. Upland vegetation

4. Air quality 4. Habitat

5. Habitat 5. Water quality

 6. Air quality

Causal Factor

The influence(s) occurring or that has occurred on an allotment which has led to one or more of the standards not being achieved.

4. Sage Grouse Status

This column lists the Greater sage-grouse management status that an allotment occurs in. Allotments were categorized by the management status that afforded 

the most protection to the Greater sage-grouse. No consideration was made for percent acreage within a management category. For example, if an allotment had 

1% of its public lands in a PHMA, and 99% of its public lands in GHMA habitat. The allotment was considered a PHMA.

PHMA= Priority Habitat Management Area
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 23

RA= Restoration Area

GHMA=General Habitat Management Area

None=No Greater sage-grouse habitat occurs on public lands

5. Threatened, Endangered, Candidate, & Special Status Species

This column lists the symbol for threatened, endangered, candidate, and special status species which occur on public lands within the grazing allotments. The 

common name, scientific name, and symbol used in the table above. The symbols used for these tables are not the official species codes. Rows that do not 

contain an entry do not have threatened, endangered, candidate, or special status species identified on public lands.

Common Name Scientific Name Symbol Common Name Scientific Name Symbol

Baird’s sparrow Ammodramus bairdii BASP Miner’s candle Cryptantha scoparia MC

Bald Eagle Haliaeetus leucocephalus BE Mountain plover Charadrius montanus MP

Beartooth large-flowered 

goldenweed

Pyrrocoma carthamoides Var. 

subsquarrosa

BLFG Nama Nama densum NA

Black-tailed prairie dog Cynomys ludovicianus BTPD Northern goshawk Accipiter gentiles NG

Blue-gray gnatcatcher Polioptial caerulea BGG Obscure evening-primrose Camissonia andina OEP

Bobolink Dolichonyx orysivorus BOB Pallid bat Antrozous pallidus PB

Brewer’s sparrow Spizella breweri BRSP Peregrine falcon Falco peregrinus PF

Burrowing owl Athene cuncularia BO Plains spadefoot Spea bombifrons PS

Canada lynx Lynx canadensis CL Platte Cinquefoil Potentilla plattensis PC

Chestnut-collared longspur Calcarius ornatus CCL Red-headed woodpecker Melanerpes 

erythrocephalus

RHW

Daggett rockcress Arabis demissa var. languida DR Sage thrasher Oreoscoptes montanus ST

Dwarf mentzelia Mentzelia pumila DM Sauger Stizostendion canadense SA

Ferruginous hawk Buteo regalis FH Shoshonea Shoshonea pulvinata SHOSH

Fringed myotis Myotis thysanodes FM Small Camissonia Camissonia parvula SC

Geyer’s Milkvetch Astragalus geyeri GEM Smooth Buckwheat Stenogonum 

salsuginosum

SMBU

Golden eagle Aquila chrysaetos GE Spiney Softshell Apalone spinifera SS

Gray’s milkvetch Astragalus grayi GM Spiny hopsage Grayia spinosa SH
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix S S - 24

Common Name Scientific Name Symbol Common Name Scientific Name Symbol

Greater sage-grouse Centrocercus urophasinus GSG Sweetwater milkvetch Astragalus aretioides SM

Greater Short Horned Lizzard Phrynosoma hernandesi GSHL Torrey’s desert dandelion Malacothrix torreyi DD

Grizzly bear Ursus arctos horribilis GB Western hog nosed snake Heterodon nasicus WHNS

Indian breadroot Pediomelum hypogaeum LIB White-tailed prairie dog Cynomys leucurus WTPD

Lesica’s Bladderpod Physaria lesicii LB Windriver Milkvetch Astragalus oreganus WM

Loggerhead shrike Lanius ludovicianus LS Wolvorine Gulo gulo WO

Long-billed curlew Numenius americanus LBC Yellow beeplant Cleome lutea YB

Mat Prickley Phlox Leptodactylon caespitosum MPP Yellow-billed cuckoo Coccyzus americanus YBC

McCown’s longspur Calcarius mccownii ML Yellowstone cutthroat trout Oncorhynchus clarki 

bouvieri

YCT

Milk Snake Lampropeltis triangulum MS
Appendix T: 

Air Quality Resource Management Plan: Adaptive 

Management Strategy for Oil and Gas Resources
Appendix T Appendix T - ii

This page left intentionally blank
Appendix T T - iii

Table of Contents

Appendix T: Air Quality Resource Management Plan: Adaptive Management Strategy for Oil 

and Gas Resources........................................................................................................................... i

1.0 INTRODUCTION................................................................................................................... 1

1.1 Purpose of the Air Resource Management Plan............................................................... 1

1.2 Revision of the Air Resource Management Plan ............................................................. 2

1.3 Current Air Quality .......................................................................................................... 2

1.4 Background of the AQTW and the MOU Regarding Air Quality Analyses and 

Mitigation for Federal Oil and Gas Decisions Through the NEPA Process............................... 2

1.5 MDEQ Air Quality Management and BLM Mitigation Measures.................................. 3

1.5.1 MDEQ Air Quality Programs................................................................................... 3

1.5.2 MDEQ Oil and Gas Emission Control Requirements .............................................. 4

1.5.3 BLM Air Resource Management and MDEQ Coordination .................................... 5

1.6 Relationship to the Montana SEIS ROD ARMP ............................................................. 5

2.0 OIL AND GAS ACTIVITY ASSESSMENT ......................................................................... 8

3.0 AMBIENT AIR QUALITY MONITORING SUPPORT....................................................... 9

4.0 AIR QUALITY AND AQRV ASSESSMENT..................................................................... 10

4.1 Annual NAAQS and MAAQS Assessment ................................................................... 10

4.2 Preliminary Ozone Assessment...................................................................................... 11

4.3 Annual AQRV Assessment............................................................................................ 12

5.0 FUTURE MODELING ......................................................................................................... 13

5.1 Photochemical Grid Modeling ....................................................................................... 13

5.1.1 Data Acquisition ..................................................................................................... 13

5.1.2 PGM Schedule ........................................................................................................ 14

5.1.3 MDEQ and AQTW and IWG Review and Input to PGM...................................... 15

5.1.4 Availability of PGM Results................................................................................... 15

5.2 Post- PGM Modeling ..................................................................................................... 15

6.0 MITIGATION....................................................................................................................... 16

6.1 Initial Mitigation Actions............................................................................................... 16

6.2 Monitoring-Based Mitigation......................................................................................... 17

6.2.1 Monitoring-Based Thresholds Before PGM Completion....................................... 17

6.2.2 Determination of Enhanced Mitigation Measures Before PGM Completion......... 18

6.2.3 Monitoring-Based Thresholds After PGM Completion ......................................... 20

6.2.4 Determination of Enhanced Mitigation Measures After PGM Completion ........... 20

6.3 Modeling-Based Mitigation ........................................................................................... 21

6.3.1 Modeling-Based Thresholds................................................................................... 21

6.3.2 Modeling-Based Enhanced Mitigation Measures................................................... 21

7.0 BIBLIOGRAPHY ................................................................................................................. 22

List of Tables

Table 1. Ambient Air Quality Standards ..................................................................................... 11

Table 2. Data Acquisition and PGM Schedule ............................................................................ 14
Appendix T T - iv

Acronyms

APD Application for Permits to Drill

AQRV Air quality related value

AQTW Air Quality Technical Workgroup

ARMP Air Resource Management Plan

ARTSD Air Resource Technical Support 

Document

BACT Best available control technology

BiFO Billings Field Office

BLM Bureau of Land Management

CAMx Comprehensive Air Quality Model with 

Extensions

CBNG Coal bed natural gas

CFR Code of Federal Regulations

CO Carbon monoxide

EPA U.S. Environmental Protection Agency

FS U.S. Forest Service

FLPMA Federal Land Policy and Management 

Act

FLIR Forward looking infrared

FWS U.S. Fish and Wildlife Service

hp Horsepower

IWG Interagency Working Group

IR Indian Reservation

MAAQS Montana Ambient Air Quality 

Standards

MAQP Montana Air Quality Permits

μg/m3 Micrograms per cubic meter

MDEQ Montana Department of Environmental 

Quality 

MOU Memorandum of Understanding

NAA Nonattainment area

NAAQS National Ambient Air Quality 

Standards

NEPA National Environmental Policy Act

NO Nitric oxide

NO2 Nitrogen dioxide

NOx Nitrogen oxides

NPS National Park Service

NSR New Source Review

O3 Ozone

Pb Lead

PGM Photochemical grid modeling

PM10 Particulate matter with a diameter less 

than or equal to 10 microns

PM2.5 Particulate matter with a diameter less 

than or equal to 2.5 microns

POD Plan of Development

ppb Parts per billion

ppm Parts per million

PSD Prevention of Significant Deterioration 

REC Reduced emissions completion

ROD Record of Decision

RMP Resource Management Plan

SEIS Supplemental Environmental Impact 

Statement

SLAMS State or Local Air Monitoring Station

SO2 Sulfur dioxide

tpy Tons per year

USDI U.S. Department of the Interior

VOC Volatile organic compound

WRAP Western Regional Air Partnership

WRF Weather and Research Forecasting
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix T T - 1

1.0INTRODUCTION

1.1 Purpose of the Air Resource Management Plan

The Bureau of Land Management (BLM) Billings Field Office (BiFO) Air Resource Management Plan 

(ARMP) for oil and gas activities describes the air quality adaptive management strategy that would be 

used to assess future air quality and Air Quality Related Values (AQRVs) and identify mitigation 

measures to address unacceptable impacts that may could potentially be associated with future oil and gas 

development. The adaptive management strategy focuses on oil and gas activity because aggregated 

emissions from multiple small sources at well sites can potentially cause significant air quality and 

AQRV impacts under certain circumstances. 

The BLM works collaboratively with the Montana Department of Environmental Quality (MDEQ) to 

promote air quality monitoring near oil and gas activity areas and will work closely with the MDEQ on 

any future emission mitigation considered under this ARMP. Many of these small oil and gas emission 

sources are not required to obtain air quality permits from the Montana Department of Environmental 

Quality (MDEQ), unlike large stationary sources such as coal mines that are permitted and inspected by 

the MDEQ. The oil and gas adaptive management strategy was prepared by the BLM in collaboration 

with or with input from the U.S. Environmental Protection Agency (EPA) and three federal land 

management agencies under the Memorandum of Understanding Among the U.S. Department of 

Agriculture [USDA], U.S. Department of the Interior [DOI], and U.S. Environmental Protection Agency, 

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

Environmental Policy Act [NEPA] Process (DOIUSDA 2011). This Memorandum of Agreement (MOU) 

is described in more detail in Section 1.4 of this appendix. Although not a signatory to the MOU, the 

MDEQ participates in the Air Quality Technical Workgroup (AQTW) that was established to implement 

the MOU process for the Proposed Resource Management Plan (PRMP) and Environmental Impact 

Statement (EIS).

This agreement is described in more detail in Section 1.4.

As described in Chapter 3 of the PRMP/EIS, the MDEQ and EPA implement the Clean Air Act within 

non-tribal portions of the planning area, while EPA implements the Act in tribal areas. State and federal 

emission control regulations and air quality permitting programs apply to many oil and gas sources. 

However, some of the smallest oil and gas emission sources are not required to obtain air quality permits. 

Facilities that have the potential to emit less than 25 tons per year of a regulated air pollutant are generally 

not required to obtain state or federal air quality permits or register their facilities with MDEQ. At these 

smallest facilities, certain activities and equipment are subject to state and federal emission control 

regulations. The ARMP provides a means for the BLM to satisfy its statutory responsibility under NEPA 

and FLPMA to protect air quality and other natural resources. Under the ARMP, the BLM will take 

appropriate management action if monitoring data for local areas with BLM-authorized oil and gas 

activity indicate that additional emission reductions may be needed to maintain good air quality. Due to 

the fragmentation of surface and mineral estate within the planning area, the BLM and MDEQ would 

seek a consistent emission control approach throughout an area of concern.

The ARMP includes both near-term actions and long-term actions. In the near-term, the ARMP sets forth 

initial actions to maintain good air quality until regional modeling can be performed to further assess 

potential impacts to air quality and AQRVs. In the long-term, the ARMP provides ongoing management 

strategies to assess and adapt to new air quality and AQRV ambient monitoring and modeling data during 

the life of this Resource Management Plan (RMP).
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix T T - 2

The ARMP includes a multifaceted approach involving the following activities.

 Oil and gas activity assessment

 Ambient air quality monitoring support

 Air quality and AQRV assessment

 Future air quality and AQRV modeling

 Mitigation

Pollutant emissions addressed by the ARMP include the criteria air pollutants listed below.

 Carbon monoxide (CO)

 Nitrogen dioxide (NO2)

 Ozone (O3)

 Particulate matter with a diameter less than or equal to 10 microns (PM10)

 Particulate matter with a diameter less than or equal to 2.5 microns (PM2.5)

 Sulfur dioxide (SO2)

Lead emissions are not included because high concentrations of this pollutant are unlikely to occur from 

oil and gas development within the planning area.

The ARMP also addresses modeling and mitigation for the following AQRV assessments. 

 Deposition of sulfur and nitrogen

 Lake acid neutralizing capacity

 Visibility

The adaptive management strategy for oil and gas resources provides the flexibility to respond to 

changing conditions that could not have been predicted during RMP development. The strategy also

allows for the use of new technology and methods that may minimize or reduce impacts.

1.2 Revision of the Air Resource Management Plan

This ARMP may be modified as necessary to comply with law, regulation, and policy and to address new 

information and changing circumstances. Changes to the goals or objectives set forth in the BiFO 

RMP/EIS would require maintenance or amendment of the RMP while changes to implementation, 

including modifying this ARMP, may be made without amending the RMP.

1.3 Current Air Quality

Based on available monitoring data in the BiFO, air quality is generally good, except for industrial areas 

influenced by emissions from some refineries. See Chapter 3 for a description of air quality within the 

BiFO. Federal air quality standards for criteria air pollutants are known as National Ambient Air Quality 

Standards (NAAQS), while state-based standards are known as the Montana Ambient Air Quality 

Standards (MAAQS). 

1.4 Background of the AQTW and the MOU Regarding Air Quality Analyses and 

Mitigation for Federal Oil and Gas Decisions Through the NEPA Process

The Air Quality Technical Workgroup (AQTW) is required to include representatives from the following 

agencies: the BLM, EPA, U.S. Forest Service (FS), U.S. Fish and Wildlife Service (FWS), and the 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix T T - 3

National Park Service (NPS). Each of these agencies is a party to the Memorandum of Understanding 

Among the U.S. Department of Agriculture, U.S. Department of the Interior, and U.S. Environmental 

Protection Agency, Regarding Air Quality Analyses and Mitigation for Federal Oil and Gas Decisions 

Through the National Environmental Policy Act Process (USDA 2011) (herein referred to as the MOU). 

This agreement is designed to “. . . facilitate the completion of NEPA environmental analyses for Federal 

land use planning and oil and gas development decisions [USDA 2011].” Additional entities may also 

participate in the AQTW, such as the MDEQ and tribal entities.

The BLM asked the MDEQ to join the AQTW. The MDEQ has primary authority to protect air quality 

within the state. Although the MDEQ is not a signatory to the national MOU, successful air quality 

management of BLM-authorized oil and gas activities depends on a close working relationship between 

the BLM and the MDEQ. The two agencies have worked together to improve air quality monitoring and 

will continue to cooperate by sharing data, planning modeling efforts, and working together to identify 

emission reduction measures needed to maintain good air quality in areas with oil and gas activity.

The MOU sets forth collaborative procedures that the AQTW agencies use to analyze potential air quality 

and AQRV impacts. The agencies also work together to identify potential mitigation measures that may 

be needed to reduce impacts to air quality and AQRVs. The lead agency (the BLM in this case), in 

collaboration with the other agencies, has the responsibility to identify reasonable mitigation and control 

measures to address adverse impacts to air quality. Mitigation measures may also address impacts to 

AQRVs at Class I areas and at sensitive Class II areas that have been identified by the BLM, FS, FWS, 

and NPS.

The AQTW provided input to this ARMP and will continue to work collaboratively on future modeling 

efforts associated with this RMP. Provisions of the MOU continue to apply to future oil and gas activities 

in the planning area. In some cases, air quality and AQRV modeling performed under this ARMP may be 

sufficient to address modeling needs for future oil and gas projects that would otherwise require 

additional modeling under the MOU. However, the ARMP in no way replaces provisions of the MOU. 

Determinations of existing modeling adequacy for future oil and gas activities that trigger the MOU 

would be made collaboratively by the AQTW using the procedures included in the MOU.

1.5 MDEQ Air Quality Management and BLM Mitigation Measures 

Primary air quality management authority and responsibility for the planning area rest with the MDEQ 

(for non-tribal areas of the planning area) and the EPA for tribal areas. However, the BLM also plays a 

role in protecting air resources under the Federal Land Policy and Management Act (FLPMA) and NEPA. 

Due to the nature of NEPA analyses for land use planning, the BLM’s air resource management role is 

forward-looking because air resource impacts are analyzed for future activities that may or may not occur.

1.5.1 MDEQ Air Quality Programs

The MDEQ has been delegated Federal Clean Air Act authority from EPA to regulate air quality and air 

emissions requirements within the non-tribal areas of Montana. The MDEQ also implements state 

ambient air quality standards for additional air pollutants and has established more stringent standards for 

some criteria air pollutants, as shown in Table 1. As part of NAAQS implementation, the MDEQ 

operates air quality monitors through Montana.

The MDEQ has State Implementation Plan approved New Source Review (NSR) permitting programs, 

which include Prevention of Significant Deterioration (PSD), Nonattainment Area (NAA), and minor 

source programs. The MDEQ’s PSD and NAA permitting programs impose controls on major stationary 

sources in order to control emissions of regulated pollutants. Emission controls are typically required 
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through the application of Best Available Control Technology (BACT) or Lowest Achievable Emission 

Rate, depending on the applicable NSR permitting program. In addition, the MDEQ implements a minor 

source NSR permitting program (e.g., minor source Montana Air Quality Permits [MAQP] and 

registrations). The MDEQ’s minor source NSR program requires sources with a potential to emit greater 

than 25 tons per year (tpy) of any regulated air pollutant to apply for a permit to construct pursuant to the 

MAQP requirements or register with the MDEQ pursuant to the registration requirements under the 

Administrative Rules of Montana (ARM). To ensure compliance with the NAAQS, MDEQ’s minor NSR 

program contains regulatory requirements that track activity and require the application of BACT. 

Additionally, the ARM require reasonable precautions to limit fugitive particulate emissions from all 

activities in Montana (i.e., permitted, registered, and those facilities that do not require a 

permit/registration). MDEQ’s NSR program not only provides the emission benefits necessary to attain 

Montana’s air quality goals, but also includes many features that provide regulatory certainty while still 

allowing flexibility in the implementation of Montana’s air quality programs. 

1.5.2 MDEQ Oil and Gas Emission Control Requirements

The MDEQ minor source permitting and registration program for oil and gas facilities includes a robust 

set of emission controls. MDEQ rules require oil or gas well facilities to control emissions from the time 

the well is completed until the source is registered or permitted. Facilities that choose to register must 

meet the emission control requirements contained in Administrative Rules of Montana (ARM) 17.8.17. If 

a source cannot meet these requirements it must apply for an MAQP. The MAQP requires a case-by-case 

BACT analysis. A case-by-case BACT analysis may include design, equipment, work practice, or 

operational standards in place of or in combination with an emission limitation.

Examples of MDEQ emission control requirements for oil and gas facilities (defined as those with a 

potential to emit more than 25 tpy of any airborne pollutant) include the following measures to limit 

emissions.

 Each piece of oil or gas well facility equipment containing volatile organic compound (VOC) 

vapors (as defined in the permitting or registration regulations) with a potential to emit 15 tpy or 

more must be routed to a gas pipeline or to air pollution control equipment with 95 percent or 

greater control efficiency (registered facilities). This requirement applies to the following 

equipment.

o Oil and gas wellhead production equipment including, but not limited to, wellhead assemblies, 

amine units, prime mover engines, phase separators, heater treatment units, dehydrator units, 

storage tanks, and connector tubing

o Transport vehicle loading operations

 Hydrocarbon liquids must be loaded into transport vehicles using submerged fill technology.

 Stationary internal combustion engines greater than 85 brake horsepower must be equipped with 

nonselective catalytic reduction (for rich burn engines) or oxidation catalytic reduction (for lean 

burn engines) or equivalent emission reduction technologies.

 Piping components containing VOCs must be inspected for leaks each month. The first attempt 

to repair any leaking VOC equipment must occur within 5 days and the repair must be completed 

no later than 15 days after the leak is initially detected unless facility shutdown is required. 

Facilities are required to maintain monthly leak inspection and repair records.

Although MDEQ emission control requirements do not mention greenhouse gas (GHG) emissions, the 

VOC emission control measures would also reduce methane emissions, while the engine emission 

controls would reduce nitrous oxide emissions.
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The MDEQ oil and gas emission control requirements have successfully protected air quality throughout 

the planning area, as evidenced by ambient air quality monitoring data that indicate good air quality in oil 

and gas activity areas.

1.5.3 BLM Air Resource Management and MDEQ Coordination

The BLM’s authority to address air resources derives primarily from FLPMA and NEPA. Under 

FLPMA, the BLM must “provide for compliance with applicable pollution control laws, including State 

and Federal air, water, noise, or other pollution standards or implementation plans” in the development 

and revision of land use plans (Section 202 (c)(8)). FLPMA also authorizes the BLM to manage public 

lands “in a manner that will protect the quality of scientific, scenic, historical, ecological, environmental, 

air and atmospheric, water resource, and archeological values” (Section 102 (8)).

Under NEPA, the BLM ensures that information on the potential environmental and human impact of 

Federal actions is available to public officials and citizens before decisions are made and before actions 

are taken. One of the purposes of the Act is to “promote efforts which will prevent or eliminate damage 

to the environment and biosphere,” and to promote human health and welfare (Section 2). NEPA requires 

that BLM and other federal agencies prepare a detailed statement on the environmental impact of the 

proposed action for major Federal actions expected to significantly affect the quality of the human 

environment (Section 102 (C)).

The BLM’s authority under the Clean Air Act primarily derives from the requirement that BLMauthorized activities comply with the Clean Air Act. BLM-authorized activities may not violate the Clean 

Air Act or federal and state regulations and State Implementation Plans issued to implement the Act. 

When air quality or AQRV modeling performed during NEPA analysis predicts potential violations of the 

Clean Air Act or unacceptable AQRV impacts, the BLM evaluates the data and determines whether 

mitigation measures are needed. For example, the initial mitigation measure requiring drill rig engines to 

meet Tier 4 emission standards reduces NO2 emissions and was demonstrated via modeling to prevent 

NAAQS violations from multiple large drill rig engines that may operate on one well pad. The mitigation 

measure includes an exception that allows use of drill rig engines meeting Tier 1, 2, or 3 emission 

standards if future modeling or near-field monitoring demonstrates compliance with the NAAQS.

When determining whether mitigation measures are needed, the BLM reviews current and proposed 

federal, state, and local regulations to determine whether mitigation will occur due to other agency 

actions. If the BLM determines that additional mitigation is needed while implementing this ARMP, the 

BLM will work closely with the MDEQ to coordinate future mitigation measures for BLM-authorized 

activities.

1.6 Relationship to the Montana SEIS ROD ARMP

This ARMP integrates and supplements earlier ARMP provisions within the Record of Decision (ROD) 

for the Supplement to the Montana Statewide Oil and Gas Environmental Impact Statement and 

Amendment of the Powder River and Billings Resource Management Plans (BLM 2008b). Provisions of 

the Montana Statewide Supplemental Environmental Impact Statement (SEIS) ARMP are currently in 

effect and were developed to address substantial predicted growth in coal bed natural gas (CBNG) drilling 

and production in the Powder River Basin. Based on extensive air quality and AQRV far-field modeling, 

predicted impacts described in the Supplemental Air Quality Analysis (BLM 2007, BLM 2008a) were 

associated primarily with projected emission increases from the operation of additional compressor 

engines. Consequently, increases in total compression horsepower were determined to be an indicator of 

oil and gas activity growth that could potentially degrade air quality and AQRVs.
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ARMP provisions included in the SEIS ROD are summarized below.

 Emission Mitigation

o Fugitive dust controls are required to reduce PM10 and PM2.5 emissions from unpaved 

roads.

o The number of wells connected to each compressor must be maximized and natural-gasfired or electrical compressors or generators are required.

o Operators within 5 miles of the Northern Cheyenne Indian Reservation (IR) and the Crow 

IR may be required to restrict the timing or location of CBNG development if monitoring 

or modeling by the MDEQ finds their CBNG development is causing or threatening to 

cause noncompliance with applicable local, state, tribal, and federal air quality laws, 

regulations, and standards, as well as state implementation plans developed by the 

MDEQ.

 Activity and Emission Monitoring

o Compression horsepower associated with CBNG is required to be reviewed.

o Annual emission inventory reports for CBNG operations are required to be submitted by 

operators.

 Ambient Air Quality Monitoring

o The BLM will develop monitoring plans to track regional cumulative impacts to air 

quality and establish programmatic mitigation at predetermined action levels.

o Ambient concentration data from the Billings St. Luke’s monitoring site (and potential 

future sites) will be used to meet ambient monitoring requirements included in Table 

MON-1 of the SEIS ROD.

 Air Quality Impact Review

o Oil and gas operators are required to provide information necessary for the BLM to 

conduct an analysis of air quality impacts when submitting exploration Applications for 

Permits to Drill (APDs) or field development project plans for CBNG development. 

BLM uses the information to determine the individual and cumulative impact on tribal air 

quality; disclose the analysis results in the appropriate NEPA document; and consult with 

the Tribe when the analysis shows impacts from a specific drilling or development 

proposal. 

o An Interagency Working Group (IWG) was formed consisting of the BLM, EPA, NPS, 

and FS and other federal agencies, state agencies, and tribal authorities to address CBNG 

development in the Montana portion of the Powder River Basin and its impacts to air 

quality. In addition to other resource responsibilities, the IWG is responsible for 

developing and recommending the monitoring and mitigation measures needed for each 

agency to ensure its actions achieve compliance with applicable air quality standards 

across jurisdictional boundaries.
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 Air Quality and Visibility Modeling

o The MDEQ agreed to complete an annual cumulative air quality impact model to track 

air quality impacts of CBNG development, including relevant CBNG development in 

Wyoming.

o The BLM and the MDEQ will perform additional visibility modeling to assess visibility 

impacts when horsepower (hp) requirements for new CBNG wells in the Montana portion 

of the Powder River Basin exceed 133,956 hp.

The above requirements are being integrated into this ARMP. Some provisions are being updated to 

reflect the current state of knowledge, while other provisions are being expanded to provide for a more 

comprehensive adaptive management strategy. Modeling provisions within the SEIS ARMP are being 

revised to reflect an improved modeling approach (described in Section 5.0) that would provide a more 

comprehensive assessment of visibility and criteria pollutants, including ozone. CBNG development in 

the Montana portion of the Powder River Basin did not materialize as predicted at the time of the SEIS. 

According to the MDEQ, CBNG compression within the Montana portion of the Powder River Basin has 

decreased by 1,676 hp since January 1, 2010 (MDEQ 2011). Due to the lack of CBNG development and 

with no new compression equipment emissions to model, the MDEQ determined that additional ambient 

air quality monitoring would be the best air quality indicator. With funding provided by the BLM, two 

new monitoring stations were installed in the Powder River Basin east of the planning area near Birney 

(Rosebud County) and Broadus (Powder River County) in 2009. 

The remainder of this ARMP describes each of the provisions being carried forward from the SEIS 

ARMP.
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2.0 OIL AND GAS ACTIVITY ASSESSMENT

Each year, the BLM would track the number and locations of new oil and gas wells drilled on federal 

mineral estate and the number of new and abandoned producing wells on federal mineral estate. These 

numbers would be compared to the planning area Reasonably Foreseeable Development (RFD) and to the 

level of oil and gas development identified in the proposed alternative.

In addition, the BLM would estimate oil and gas emissions from federal mineral estate every three years 

for oil and gas wells drilled and producing after the ROD is signed. Emission estimates would be based 

on well types, well numbers, and knowledge of typical equipment and operations. Emission estimation 

methods are expected to improve over time as better data become available. The emission estimates 

would also account for implemented mitigation measures and for new emission control regulations as 

they become effective. Each three-year oil and gas emission inventory would be compared to emission 

estimates for the RFD and the proposed alternative. The BLM would collect additional data related to oil 

and gas equipment and operations to improve emission inventory quality. One area identified for 

improvement involves acquiring better data on oil and gas equipment used in the planning area. In order 

to improve fugitive dust emission estimates, the number, type, and length of vehicle trips in high-activity 

areas would also be assessed.

For the portion of the Powder River Basin located in the BIFO, increases in compressor horsepower 

would be tracked annually using data provided by the MDEQ. 

Each three-year oil and gas emission inventory would be compared to emission estimates for the RFD and 

the proposed alternative.
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3.0 AMBIENT AIR QUALITY MONITORING SUPPORT

The MDEQ Air Resources Management Bureau has primary responsibility for siting and operating 

ambient air quality monitors within Montana and for reporting monitoring data to the EPA and to the 

public. As described in its annual Air Quality Monitoring Network Plan (MDEQ 2012), the MDEQ 

identifies monitoring objectives for assessing ambient concentrations of criteria air pollutants and 

assessing compliance with the NAAQS and MAAQS. 

MDEQ-operated monitors in the planning area are limited to two monitors located in Billings. Of these, 

PM2.5 concentration data from the Billings St. Luke’s monitor (20-111-0085) would be considered to be 

representative of air quality in the planning area. The Billings Coburn Road monitor (30-111-0066) 

measures SO2 concentrations near two refineries within 3 kilometers of the monitoring site. Due to the 

close proximity of the refineries, SO2 concentrations from the Coburn Road site are not representative of 

SO2 concentrations in rural oil and gas activity areas and data from this monitor would not be reviewed 

under this plan.

Due to the area’s low concentrations of NO2, ozone, and PM10, these pollutants are not currently 

monitored in the planning area. If, in future years, additional MDEQ-operated monitoring stations are 

installed and operated for the purpose of assessing air quality impacts from oil and gas activity, ambient 

monitoring data from these monitors would be used for ambient air quality assessments under this plan. 
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4.0 AIR QUALITY AND AQRV ASSESSMENT

The BLM would assess air quality and AQRVs on an annual basis using quality-assured data from the 

EPA, MDEQ, FS, FWS, NPS, and other sources. In addition, if ozone monitoring data become available 

for the planning area, a preliminary assessment of ozone concentrations would be performed on a weekly 

basis using data provided by the MDEQ. 

4.1 Annual NAAQS and MAAQS Assessment

Based on the representative monitor(s) listed in Section 3.0, the BLM would assess air quality monitoring 

data annually and would share the results of the assessment with the MDEQ and AQTW. The purposes 

of the annual assessment are to compare monitored data to NAAQS and MAAQS and to identify seasonal 

and long-term trends in air pollutant concentrations. The BLM would complete the annual assessment by 

May 31 of each year in order to ensure that quality-assured data are available for review. Monitoring data 

associated with exceptional events, typically due to wildfires, would be excluded from the assessment. 

NAAQS and MAAQS are provided in Table 1. Montana standards are shown only if they are more 

stringent than the NAAQS. 

Although most of the pollutants are not currently monitored in the planning area, the standards are 

provided to illustrate the framework for assessing monitoring data that may become available in the 

future. The standards shown in Table 1 would be revised to reflect future regulatory changes.

The BLM would use design values to compare ambient monitoring data to the NAAQS. Design values 

reflect the form of the NAAQS; they define the statistical metric used to compare monitoring data to 

federal standards. Depending on the pollutant and averaging time being assessed, a NAAQS is typically 

stated in terms of the maximum or second maximum concentration, average concentration, or a percentile 

of the standard. The form of a standard also states whether the design value is determined based on one 

or more years of monitoring data. EPA-calculated design values serve a critically important regulatory 

purpose; they determine whether areas are designated attainment or nonattainment. As such, EPA’s 

design value determinations may take more than one year to finalize.

In order to review air quality trends more quickly, the BLM would determine “mitigation design values” 

by May 31 of each year for the previous calendar year(s). The mitigation design value would be a metric 

calculated by the MDEQ or BLM that uses procedures similar to EPA’s regulatory design value 

calculation methodology, with the advantage that the MDEQ/BLM-calculated mitigation design values 

can be determined more quickly. The timing allows the MDEQ adequate time to quality assure 

monitoring data. However, the MDEQ may not yet have EPA concurrence on data that have been flagged 

by the MDEQ due to exceptional events, such as wildfires. Consequently, the MDEQ/BLM-calculated 

mitigation design values would exclude monitoring data associated with MDEQ-identified exceptional 

events. Each BLM annual assessment would look back the requisite number of years for each pollutant 

and include data from the time period prior to ROD issuance for the first several annual BLM 

assessments. Additional information concerning design value calculations is provided in Section 6.2.3. 

The BLM will work closely with the MDEQ to ensure that only data certified by the MDEQ and 

procedures consistent with MDEQ procedures are used in design value calculations.
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Table 1. Ambient Air Quality Standards

Pollutant

Averaging 

Period

Federal NAAQS 1 MAAQS 2

Concentration

Standard 

Type

Form of NAAQS Primary 

Standard Concentration

CO 1-hour 35 ppm Primary Second maximum 23 ppm5

8-hour 9 ppm Primary Second maximum ---

NO2

1-hour 100 ppb Primary 3-year average of the 98th

percentile concentrations 0.30 ppm

Annual 53 ppb Primary, 

Secondary Annual mean 0.05 ppm 7

Ozone

1-hour --- --- --- 0.12 ppm 7

8-hour 0.075 ppm Primary, 

Secondary

3-year average of the fourth 

highest daily maximum 8-

hour average

---

PM2.5

24-hour 35 μg/m3 Primary, 

Secondary 3

3-year average of the 98th

percentile concentration ---

Annual 12.0 μg/m3Primary 3-year average of the 

annual mean

---

Annual 15.0 μg/m3 3Secondary 3-year average of the 

annual mean

---

PM10

24-hour 150 μg/m3 Primary, 

Secondary

NTBE more than one per 

year on average over 3 

years

---

Annual Revoked 4--- --- 50 μg/m3 5

SO2

1-hour 75 ppb Primary 3-year average of the 99

th

percentile concentrations 0.50 ppm

3-hour 0.5 ppm Secondary --- ---

24-hour --- Primary --- 0.10 ppm5

Annual --- Primary --- 0.02 ppm6

CO carbon monoxide

μg/m3 micrograms per cubic meter

MAAQS Montana Ambient Air Quality 

Standards

NAAQS National Ambient Air Quality 

Standards

NO2 nitrogen dioxide

NTBE Not to be exceeded

PM2.5 particulate matter less than or equal 

to 2.5 microns

PM10 particulate matter less than or equal 

to 10 microns

ppb parts per billion

ppm parts per million

SO2 sulfur dioxide

1 NAAQS are codified in Title 40 of the Code of Federal 

Regulations (CFR), Part 50.

2 Montana AAQS are codified in Title 17, Chapter 8, Subchapter 

2 of the Ambient Air Quality in the Administrative Rules of 

Montana.

3 EPA proposed a new secondary standard for PM2.5 visibility of 

28 or 30 deciviews (equivalent to 24 or 19 kilometers [15 or 12 

miles] standard visual range). 

5 The annual PM10 NAAQS was revoked October 17, 2006.

6 Based on annual second maximum. 

7 Not to be exceeded in the averaging period specified.

8 State violation when exceeded more than once during any 12 

consecutive months.

4.2 Preliminary Ozone Assessment

If an MDEQ-operated ozone monitor is installed and operated in the planning area, the BLM would 

perform weekly preliminary ozone concentration reviews to determine if high ozone events occur. If a 

high-ozone event occurs, the BLM would document meteorological and other conditions that may have 

contributed to the event. Because high-ozone events in other rural parts of the nation are not well 

understood and contributing factors can be site-specific, the BLM would gather data to develop baseline 
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information relevant to any high-ozone events that may occur within the planning area. Relevant baseline 

information includes capturing meteorological data for each event, determining the amount of snow on 

the ground (if applicable), and identifying any other data that may help describe circumstances associated 

with the event. For the purposes of this effort, high-ozone events would be defined to be days for which 

the maximum 8-hour average ozone concentration is at or above 0.065 ppm.

In order to quickly ascertain relevant circumstances, the preliminary ozone assessments would use nonquality-assured data provided by the MDEQ. As part of the annual NAAQS assessment, quality-assured 

ozone data would be reviewed to determine if the preliminary ozone monitoring data were valid or if 

monitored high ozone concentrations were due to monitor malfunctions.

If high-ozone events occur within the planning area, a summary of events and a discussion of relevant 

meteorological data and circumstances would be developed as part of the annual NAAQS assessment. 

These summaries and the underlying data may provide important information that can be used to predict 

potential occurrences of high-ozone events and to identify mitigation measures and/or proactive measures 

that could prevent future events. 

4.3 Annual AQRV Assessment

Federal land managers track the status, condition, and trends of AQRVs for Class I and sensitive Class II 

areas under their jurisdictions. Consequently, the BLM would request visibility, sulfur and nitrogen 

deposition, and lake acid neutralizing capacity data from the FS, FWS, and NPS and would include 

agency-submitted data in the BLM’s annual review of AQRV trends. The annual review would also 

include AQRV data from any Class I or sensitive Class II areas under BLM jurisdiction.

Based on these reviews, the BLM would maintain an awareness of AQRV trends. However, it should be 

noted that the reviews would not necessarily link AQRV trends to oil and gas development. AQRV 

impacts are often associated with pollutants that can be transported long distances from many different 

types of sources. For example, visibility degradation in eastern Montana primarily results from large 

stationary sources such as electric generating units and cement kilns, as addressed in the Montana 

Regional Haze Federal Implementation Plan (EPA 2012b).

Photochemical grid modeling (PGM) would be completed after the ROD is signed and would provide

additional information concerning the potential impact BLM-authorized of oil and gas emissions and 

cumulative emissions on AQRVs.
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5.0 FUTURE MODELING

The BLM committed to perform PGM in order to assess regional air quality and AQRV impacts. Due to 

insufficient monitoring and regional emissions data available during development of the RMP, PGM will

not be completed prior to issuance of the RMP/EIS and the ROD. In order to complete PGM 

expeditiously, the BLM began data acquisition and initiated steps needed to proceed with PGM. When 

PGM is completed and the results assessed, the BLM may identify additional emission mitigation 

measures for oil and gas activity.

5.1 Photochemical Grid Modeling

Comprehensive regional air quality and AQRV regional modeling of emission sources within the BiFO 

and surrounding areas requires PGM. This type of modeling can predict ozone and regional haze impacts, 

for which major pollutants and precursors can be transported many hundreds of miles. 

5.1.1 Data Acquisition

PGM requires three main types of concurrent data: meteorological data, ambient monitoring data, and 

comprehensive emission data. BLM’s analysis determined that the latter two types of data need to be 

augmented and updated prior to performing PGM. 

5.1.1.1 Additional Monitoring

Ambient monitoring data throughout the regional PGM domain (which would extend throughout most of 

Montana and into adjacent states) are needed in order to validate model performance, which is assessed 

by modeling a previous year and comparing the model’s predicted concentrations to actual monitored 

concentrations.

In cooperation with the MDEQ, the BLM funded two new monitoring stations in north-central Montana 

and would provide staffing and additional funding to operate the monitors. One monitor is located near 

Malta in Phillips County and the other is located in Lewistown (Fergus County). Both monitors became 

operational in July 2012 and measure ambient concentrations of nitric oxide (NO), NO2, nitrogen oxides 

(NOx, an ozone precursor), ozone, PM10, and PM2.5. These data would be particularly helpful in assessing 

the photochemical grid model’s ability to accurately predict concentrations of these pollutants and its 

ability to accurately predict regional haze and visibility impacts.

5.1.1.2 Updating Emission Inventories

Comprehensive emission inventories are also critically important in predicting cumulative air quality and 

AQRV impacts. Current oil and gas regional emission inventories for Montana and the Dakotas are 

known to lack important emission sources, particularly sources of volatile organic compounds (VOCs), 

which contribute to ozone formation. The existing oil and gas inventories for the Williston and Central 

Montana Basins represent the year 2002 and were developed as part of the Western Regional Air 

Partnership (WRAP) Phase II inventory. Since then, 2006 Phase III emission inventories have been 

developed for oil and gas basins within Colorado, Utah, Wyoming, and New Mexico, but have not yet 

been completed for Montana, North Dakota, and South Dakota. The Phase III inventories have more 

comprehensive emission inventories of VOC sources at oil and gas facilities.

The BLM Montana and Dakotas State Office is providing financial assistance to the WRAP so that Phase 

III oil and gas emission inventories can be completed in 2013 for the Williston Basin and the Central 
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Montana Basin. These inventories would represent calendar year 2011 emissions. In addition to covering 

the planning area, the inventories would include comprehensive recent emission estimates for oil and gas 

activity in North Dakota and South Dakota.

5.1.2 PGM Schedule

In order to use a full 12 months of ambient monitoring data from the new Malta and Lewistown monitors, 

the baseline year for PGM is expected to be 2013 or may be a 12-month period beginning in late 2012 and 

ending in 2013. PGM planning began in 2012 and development of the PGM modeling protocol was

completed in 2013. Modeling activities will begin in 2014 and should be completed in mid-2015. 

Review and assessment of PGM results would be completed in fall 2015. Table 2 provides the 

planned data acquisition and PGM schedule.

Table 2. Data Acquisition and PGM Schedule

Task / Subtask Completion Date

Pre-Modeling Emission Inventory and Protocol Development

Develop Weather Research Forecasting (WRF) and PGM Protocol 4/15/2013

”WRAP” Williston and Great Plains Basin Inventory * 3/31/2014

Base Year Modeling and Evaluation *

WRF Modeling 5/8/2014

Draft WRF Model Evaluation 6/5/2014

AQTW, MDEQ, and IWG WRF Evaluation Review 7/10/2014

Emission Modeling (Base and Future Year) & Report 9/9/2014 (base year)

12/11/2014 (future year)

AQTW, MDEQ, and IWG Emission Modeling Review 10/2/2014 (base year)

1/7/2015 (future year)

Base Year Photochemical Grid Modeling 8/28/2014

Draft Base Year PGM Evaluation 11/17/2014

AQTW, MDEQ, and IWG PGM Evaluation Review 12/1/2014

Finalize WRF and PGM Evaluations 12/15/2014

Emission Modeling Reports 1/21/2015

Future Year Modeling and Evaluation *

Future Year Photochemical Grid Modeling 3/8/2015

Analyze Air Quality and AQRV Impacts 3/29/2015

Draft ARTSD 4/19/2015

AQTW, MDEQ, and IWG ARTSD Review 6/19/2015

Finalize ARTSD 7/1/2015

* Duration and dates are subject to revision; they are estimated to provide the general timing of future modeling activities.

AQTW = Air Quality Technical Workgroup

ARTSD = Air Resource Technical Support Document

IWG = Interagency Working Group 

MDEQ = Montana Department of Environmental Quality

PGM = Photochemical grid modeling

RFP = Request for Proposal

WRF = Weather Research and Forecasting Model

WRAP = Western Regional Air Partnership
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The Weather Research and Forecasting (WRF) model would be used to model meteorological conditions. 

The Comprehensive Air Quality Model with Extensions (CAMx) would be used for photochemical grid 

modeling. In addition, multiple models would be used to develop and process emission inventories for 

input into the photochemical grid model. When modeling is completed, an Air Resource Technical 

Support Document (ARTSD) would be developed.

Initial PGM would include future year modeling for a year between 2017 and 2030. The specific year 

would be determined by the BLM based on the ability to predict future regional oil and gas emissions in 

the Williston and Central Montana Basins. After initial PGM is completed, the BLM would begin an 

assessment process to determine when or if additional PGM updates are needed. Factors to be considered 

in determining when additional PGM would be needed include: 1) the adequacy of the adaptive 

management strategy to maintain good air quality, and 2) the level of BLM-authorized oil and gas activity 

and emissions compared to modeled levels. 

5.1.3 MDEQ and AQTW and IWG Review and Input to PGM

Throughout the PGM data collection and modeling process, the BLM would work collaboratively with 

the MDEQ and the, with the IWG, and with other agencies or Tribes that request to be involved in the 

PGM effort. These collaborators provided technical review and comment on the draft modeling protocol, 

and will provide input on the WRF and PGM performance evaluations, and on the draft ARTSD. 

Substantial time has been included in the schedule shown in Table 2 to allow adequate review and 

comment periods during the PGM process.

5.1.4 Availability of PGM Results 

Future PGM results would be presented in the final ARTSD and in a summary of the results. The 

ARTSD and summary document would be posted on the BiFO BLM website. In addition, the modeling 

protocol document would be provided via the website when the photochemical modeling ARTSD is made 

available. Outreach information regarding the availability of the results would be made through the 

AQTW, IWG, and other agencies involved in the PGM process, as well as other interested parties. 

5.2 Post- PGM Modeling

To the extent that future emission increases are within the levels modeled with PGM or other modeling 

and are proximate to modeled emission locations, far-field air quality and AQRV impact analysis may 

incorporate by reference PGM and other modeling results. The BLM and the AQTW would determine 

whether previous modeling is sufficient to satisfy MOU requirements. This air quality management 

approach is consistent with the MOU (USDA 2011) and allows for efficient air quality and AQRV impact 

analysis.

If additional modeling is performed after PGM is complete, an assessment of air quality and AQRV 

impacts would be made and, if necessary, additional mitigation measures may be identified.

 
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6.0 MITIGATION

Air quality and AQRV impact mitigation would involve two types of mitigation: 1) initial mitigation 

measures that become effective when the ROD is signed, and 2) enhanced mitigation measures that may 

be identified based on future ambient monitoring data or modeling results.

6.1 Initial Mitigation Actions

The following air quality mitigation measures would be applied upon issuance of the ROD through 

leasing documents and project-specific NEPA documents. To the extent practical, emission reductions 

associated with these mitigation measures have been included in the emission inventory. 

1. Design and construct roads and well pads to reduce the amount of fugitive dust generated by 

traffic or other activities. During construction activities, apply water, apply dust-suppression 

chemicals, apply gravel, or use other control methods to achieve 50 percent fugitive dust control 

efficiency, except when ground is wet or frozen.

2. Use water or other BLM-approved dust suppression during drilling, completion, and well 

workover operations for dust abatement on access roads, as needed, to achieve a 50 percent 

fugitive dust control efficiency, except when ground is wet or frozen.

3. Use water or other BLM-approved dust suppression in high traffic areas during production 

operations for dust abatement, as needed, to achieve 50 percent fugitive dust control efficiency, 

except when ground is wet or frozen. Operators would work with local government agencies to 

improve dust suppression on roads.

4. For oil and gas Project Plans of Development (PODs), oil and gas operators would establish 

speed limits for project-required unpaved roads in and adjacent to the project area; oil and gas 

operator employees would comply with these speed limits.

5. For oil and gas Project PODs, oil and gas operators would be encouraged to reduce surface 

disturbance, vehicle traffic, and fugitive dust emissions by consolidating facilities (e.g., using 

multi-well pads, storage vessels) when feasible.

6. Diesel drill rig and completion engines greater than 200 hp would meet Tier 4 emission standards 

for non-road diesel engines. Alternatively, oil and gas operators may use drill rig and completion 

engines that exceed Tier 4 emission standards if modeling or monitoring at the project level or 

programmatic level demonstrates compliance with the NAAQS and protection of AQRVs.

7. For hydraulically fractured gas wells that do not qualify as “low pressure wells”, “wildcat,” or 

“delineation” wells, oil and gas operators would comply with reduced emissions completion 

(REC) requirements specified in Subpart OOOO, Standards of Performance for Crude Oil and 

Natural Gas Production, Transmission and Distribution (40 CFR §60.5375) within six months of 

ROD issuance.

8. Non-road diesel engines would be required to use ultra-low sulfur diesel fuel (15 ppmw) as 

required by 40 CFR §80.610(e)(3)(iii).

9. Natural-gas-fired or electrical compressors or generators would be required at compressor 

stations in the Powder River Basin.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix T T - 17

10. CBNG operators proposing a POD within 5 miles of the Northern Cheyenne IR or the Crow IR 

would be required to provide the information necessary for BLM to conduct an analysis of air 

quality impacts. The BLM would use the information to determine the impact on air quality in 

the Northern Cheyenne IR and the Crow IR, disclose the analysis results and subsequent 

mitigation in the appropriate NEPA document, and consult with the Tribes when the analysis 

shows that air quality or AQRV impacts are anticipated from a specific development proposal. 

11. CBNG operators within 5 miles of the Northern Cheyenne IR and the Crow IR may be required 

to restrict the timing or location of CBNG development if monitoring or modeling by the MDEQ 

finds their CBNG development is causing or threatening to cause noncompliance with applicable 

local, state, tribal, and federal air quality laws, regulations, and standards, as well as state 

implementation plans developed by the MDEQ. 

6.2 Monitoring-Based Mitigation

Enhanced mitigation would be evaluated and implemented if ambient monitoring data at monitor(s) 

located in oil and gas activity areas within the planning area indicate that pollutant concentrations are 

approaching or threatening the NAQQS or MAAQS. Prior to completion of initial PGM, monitoringbased thresholds would be based on evaluation of exceedances of the NAAQS, as described in Section 

6.2.1. After completion of initial PGM, monitoring-based thresholds would be based on BLM-calculated 

design values, as described in Section 6.2.3. 

6.2.1 Monitoring-Based Thresholds Before PGM Completion

Based on requests from EPA during the MOU review process, the BLM would review NAAQS 

exceedances and determine if enhanced mitigation would be warranted during the interim period between 

ROD issuance and PGM completion. The BLM would require enhanced mitigation for BLM-authorized 

oil and gas activities if there is a monitored exceedance of the NAAQS at the St. Luke’s monitor, unless 

the BLM determines that enhanced mitigation is not warranted after completing specified steps as 

outlined below and in Section 6.2.2.

1. The BLM would notify the EPA and the MDEQ within 30 days after St. Luke’s monitoring data 

showing an exceedance has been posted on EPA’s Air Quality System (AQS). The notification 

would state that the BLM is reviewing the exceedance according to this procedure.

2. After consulting with the MDEQ, the BLM would determine whether an exceptional event1 may have 

caused the exceedance. 

 If the MDEQ informs the BLM that an exceptional event likely caused the exceedance, the BLM 

would provide a letter to that effect to the EPA. No further action would be necessary. 

 If an exceptional event did not cause the exceedance or if MDEQ would not submit an 

exceptional event waiver to EPA, the BLM would perform Step 3. 

3. The BLM would conduct a screening level analysis2to determine the likely source and location of the 

exceedance and whether mitigation is needed.3

 

1

The BLM would not formally decide that an exceptional event occurred as this decision would be made 

by MDEQ. Until a final determination of an exceptional event is presented to EPA by MDEQ, and the EPA 

has concurred, the BLM would assume that an exceptional event occurred based on a stated intention by 

the MDEQ to submit an exceptional event waiver.
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Appendix T T - 18

 If the screening analysis indicates that the exceedance was not caused by BLM-authorized oil and 

gas source(s) within the planning area or indicates that the BLM-authorized oil and gas source(s) 

within the planning did not contribute to the exceedance, the BLM would convey this finding in 

writing to the MDEQ and EPA for review and comment. No further action would be necessary.

 If the screening analysis indicates that the exceedance was caused or contributed to by BLMauthorized oil and gas sources inside the planning area, the BLM would perform Step 4.

4. The BLM would consult with the MDEQ and EPA to determine whether there is a need for: 1) a 

refined attribution analysis (e.g., attribution test using CAMx ozone source attribution technology or 

anthropogenic precursor’s culpability assessment) or 2) mitigation on BLM-authorized oil and gas 

emission sources within the planning area. If the refined analysis:

 Is warranted, BLM would perform the refined analysis within 6 months of completing Step 3 in 

consultation with MDEQ and EPA.

 Indicates that the exceedance was not caused or contributed to by BLM-authorized oil and gas 

sources inside the planning area, the BLM would provide that recommendation to the MDEQ and 

EPA for review and comment. No further action would be necessary.

 Indicates that the exceedance was caused by BLM-authorized oil and gas sources within the 

planning area, the BLM would evaluate enhanced mitigation measures, as described in Section

6.2.2. 

6.2.2 Determination of Enhanced Mitigation Measures Before PGM 

Completion

If a NAAQS exceedance occurs prior to completion of PGM and the refined analysis in Step 4 above 

determined that the exceedance was caused by BLM-authorized oil and gas sources within the planning 

area, enhanced mitigation measures would be evaluated and selected by the BLM, in cooperation with the 

MDEQ, IWG, and AQTW, when appropriate. Preference would be given to mitigation methods that the 

MDEQ intends to impose as new regulations or air quality permitting provisions. Selected mitigation 

measures would be implemented within one year after the BLM decision to apply additional mitigation.

Potential enhanced mitigation measures include the measures listed below based on current information 

concerning potential emission reduction technologies. Additional measures or equivalent methods or 

emission restrictions may be identified in the future. 

 Drilling and/or blowdown activity restrictions based on meteorological conditions 

 Construction activity restrictions based on meteorological conditions

 Centralization of gathering facilities

 Electric drill rigs

 

2

Publically available web based applications suggested by EPA to identify sources of air pollution and potential impacts include 

the following sites: trajectory analysis tools like HySplit (http://ready.arl.noaa.gov/), air quality data at the EPA’s AQS site 

(http://airnow.gov ), state regulatory agency sites and airnowtech.org, an interactive snow site 

(http://www.nohrsc.nws.gov/interactive/html/map.html), daily ozone modeling (http://airquality.weather.gov/), daily ozone and 

PM2.5 modeling site (http://www.getbluesky.org/), and daily satellite imagery site (http://ge.ssec.wisc.edu/modis-today/). 

2

If data necessary to conduct a screening level analysis is not available, the BLM would consult with the MDEQ and the EPA 

regarding source attribution and the need for mitigation. 

 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix T T - 19

 Field electrification for compressors and/or pumpjack engines

 Plunger lift systems with smart automation

 Oil tank load out vapor recovery

 VOC controls on tanks with a potential to emit less than 5 tons per year

 Selective catalytic reduction on non-drill rig stationary engines

 Reduced emission completions beyond those required by EPA regulations, if determined to be 

technically and economically feasible

 Well pad density limitations

 Reducing the total number of drill rigs operating simultaneously

 Seasonally reducing or ceasing drilling during specified periods

 Using only lower-emitting drill and completion rig engines during specified time periods

 Using natural gas-fired drill and completion rig engines

 Replacing internal combustion engines with gas turbines for natural gas compression 

 Employing a monthly forward looking infrared (FLIR) leak detection program to reduce VOCs

 Tank load out vapor recovery

 Enhanced VOC emission controls with 95% control efficiency on additional production 

equipment having a potential to emit of greater than 5 tons/year 

 Enhanced direct inspection and maintenance program
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix T T - 20

6.2.3 Monitoring-Based Thresholds After PGM Completion

By May 31 of each year following completion of PGM, the BLM would calculate design values 

for each pollutant monitored at a federal reference monitor within the planning area and 

identified as a representative monitor in Section 6.2.1. The design value would be calculated 

based on calendar year monitoring data available at the time. For pollutants requiring three years 

of monitoring data for design value calculation, data from the appropriate prior period would be 

used. For example, based on PGM completion in mid-2015, the first annual design value 

calculation would be performed by May 31, 2016 and would include monitoring data for 

calendar years 2013, 2014, and 2015 for three-year design values and on monitoring data for 

calendar year 2015 for single-year design values. BLM design value calculations would exclude 

data associated with MDEQ-identified exceptional events and would be performed in accordance 

with EPA regulations and guidance.

Calculation methods would, to the extent possible, follow EPA procedures provided in the 

following appendices within Title 40 of the Code of Federal Regulations (CFR), Part 50 in effect 

as of December 1, 2012. These procedures may be updated by future EPA regulations and this 

section of the ARMP would be revised to reflect changing regulations.

 NO2 (Appendix S)

 O3 (appendix P)

 PM10 (Appendix K)

 PM2.5 (Appendix N)

 SO2 (Appendix T)

BLM design value calculations would exclude data associated with exceptional events identified 

by MDEQ.

6.2.4 Determination of Enhanced Mitigation Measures After PGM Completion

If the air quality assessment described in Section 6.2.3 indicates that a BLM-calculated design value is 

greater than 85 percent of a NAAQS, enhanced mitigation measures addressing that pollutant or pollutant 

precursor would be evaluated and selected by the BLM, in cooperation with the MDEQ, IWG, and EPA, 

when appropriate. Potential enhanced mitigation measures include the measures listed above in Section

6.1, as well as additional measures that may be identified in the future. 
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6.3 Modeling-Based Mitigation

6.3.1 Modeling-Based Thresholds

Future modeling would assess air quality and AQRV impacts from future BLM-authorized oil and gas 

activity and would include regional PGM and project-specific modeling. Modeling-based thresholds for 

evaluating enhanced mitigation would include potential future impacts on NAAQS or MAAQS or 

impacts above specific levels of concern for AQRVs in Class I or sensitive Class II areas (as identified on 

a case-by-case basis by MDEQ or a federal land management or tribal agency).

6.3.2 Modeling-Based Enhanced Mitigation Measures

If BLM-authorized oil and gas activity is predicted to cause or contribute to impacts above the thresholds 

described above, the BLM would facilitate an interagency process to ensure that a comprehensive strategy 

is developed to manage air quality impacts from future oil and gas development within the region. The 

local, state, federal, and Tribal agencies involved in the regulation of air quality and the authorization of 

oil and gas development would evaluate modeling results from future modeling studies and identify 

potential air quality concerns and necessary reductions in air emissions. If the modeling predicts 

significant impacts, these agencies would use their respective authorities to implement enhanced emission 

control strategies, operating limitations, equipment standards, and/or pacing of development as necessary 

to ensure continued compliance with applicable ambient air quality standards, including the enhanced 

mitigation measures listed in Section 6.2.2, other future mitigation measures identified through BLM’s 

adaptive management strategy, or reasonable mitigation measures suggested by the MDEQ, IWG, or 

AQTW. If necessary, implementation of mitigation measures would occur within one year of obtaining 

final modeling results for mitigation measures that conform to currently implemented land use planning 

decisions and constraints.
Resource Management Plan and Environmental Impact Statement

February 2013

Appendix T T - 22

7.0 BIBLIOGRAPHY

BLM 2007. Supplemental Air Quality Analysis: Draft Supplement to the Montana Statewide Oil and 

Gas Environmental Impact Statement and Amendment of the Powder River and Billings 

Resource Management Plans (November 2007).

BLM 2008a. Final Supplement to the Montana Statewide Oil and Gas Environmental Impact Statement 

and Proposed Amendment of the Powder River and Billings Resource Management Plans 

(October 2008).

BLM 2008b. Record of Decision for the Final Supplement to the Montana Statewide Oil and Gas 

Environmental Impact Statement and Proposed Amendment of the Powder River and Billings 

Resource Management Plans (December 2008).

EPA 2012a. AirData website. U.S. Environmental Protection Agency. Accessed July 17, 2012. 

http://www.epa.gov/airquality/airdata/. 

EPA 2012b. Approval and Promulgation of Implementation Plans; State of Montana; State 

Implementation Plan and Regional Haze Federal Implementation Plan. Docket No. EPA-R08-

OAR-2011-0851. August 15.

MDEQ 2011. Email and spreadsheet from Vickie Walsh (MDEQ) to Susan Bassett (BLM). September 

21, 2011.

MDEQ 2013. State of Montana Ambient Monitoring Network Plan. Montana Department of 

Environmental Quality. May 2012.

http://deq.mt.gov/AirQuality/AQInfo/PDF/MT_2013_NETWORK_PLAN.pdf

USDA 2011. Memorandum of Understanding Among the U.S. Department of Agriculture [USDA], U.S. 

Department of the Interior, and U.S. Environmental Protection Agency, Regarding Air Quality 

Analyses and Mitigation for Federal Oil and Gas Decisions Through the National Environmental 

Policy Act Process. June 23, 2011.

http://www.epa.gov/oecaerth/resources/policies/nepa/air-quality-analyses-mou-2011.pdf

 
Appendix U U - i

Appendix U: 

Water Rights
Appendix U U - ii

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Appendix U U - 1

U. Water Rights

BLM manages the land for multiple uses and, when required, applies to the State of Montana for 

water rights to support these uses. The BLM holds water rights for such beneficial uses as 

livestock water, fisheries and waterfowl and wildlife. Most BLM water sources have more than 

one water right attached to them to protect the varying uses listed above.

Water Rights

County

BLM 

Adjudication 

Claims BLM Permits

Total Water 

Rights

BigHorn 92 22 7518

Carbon 231 36 6224

Golden Valley 0 0 2231

Musselshell 228 29 3714

Stillwater 4 5 5849

Sweet Grass 14 1 7042

Wheatland 0 0 3694

Yellowstone 153 29 9048

Totals 722 122 45320
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Appendix V V - i

Appendix V: 

Recreational Setting Characteristics
Appendix V V - ii

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Appendix V V - 1

V. Recreational Setting Characteristics

Primitive Classification: 

 Physical:

► More than 1⁄2 mile from either mechanized or motorized routes.

► Undisturbed natural landscape.

► No structures. Foot/horse and water trails only. 

 Social: 

► Fewer than 3 encounters/day at camp sites and fewer than 6 encounters/day on 

travel routes. 

► Fewer than or equal to 3 people per group. 

► No alteration of the natural terrain. Footprints only observed. Sounds of 

people rare.

 Operational: 

► Foot, horse, and non-motorized float boat travel.

► No maps or brochures available on-site. Staff is rarely present to provide onsite assistance.

► No on-site posting/signing of visitor regulations, interpretive information or 

ethics. Few use restrictions

Back Country Classification 

 Physical:

► Within 1⁄2 mile of four-wheel drive vehicle, ATV and motorcycles routes.

► Character of the natural landscape retained. A few modifications contrast with 

character of the landscape (e.g. fences, primitive roads).

► Maintained and marked trails, simple trailhead developments and basic toilets.

 Social: 

► 3-6 encounters/day off travel routes (e.g., campsites) and 7-15 encounters/day 

on travel routes 

► 4-6 people per group. 

► Areas of alteration uncommon. Little surface vegetation wear observed. 

Sounds of people infrequent. 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix V V - 2

 Operational:

► Mountain bikes and perhaps other mechanized use, but all is non-motorized.

► Basic maps, staff infrequently present (e.g. seasonally, high use periods) to 

provide on-site assistance.

► Basic user regulations at key access points. Minimum use restrictions.

Middle Country Classification:

 Physical:

► Within 1⁄2 mile of four-wheel drive vehicle, ATV and motorcycles routes.

► Character of the natural landscape retained. A few modifications contrast with 

character of the landscape (e.g. fences, primitive roads).

► Maintained and marked trails, simple trailhead developments and basic toilets. 

 Social: 

► 7-14 encounters/day off travel routes (e.g., staging areas) and 15-29 

encounters/ day on travel routes 

► 7-12 people per group. 

► Small areas of alteration. Surface vegetation showing wear with some bare 

soils. Sounds of people occasionally heard.

 Operational

► Four-wheel drives, all-terrain vehicles, dirt bikes, or snowmobiles in addition 

to non-motorized, mechanized use.

► Area brochures and maps, staff is occasionally (e.g. most weekends) present 

to provide on-site assistance.

► Some regulatory and ethics signing. Moderate use restrictions. (e.g. camping, 

human waste).

Front Country Classification

 Physical:

► Within 1⁄2 mile of low-clearance or passenger vehicle routes (includes unpaved 

County roads and private land routes).

► Character of the natural landscape partially modified but none overpower 

natural landscape (e.g. roads, structures, utilities).

► Rustic facilities such as campsites, restrooms, trailheads, and interpretive 

displays.
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Appendix V V - 3

 Social: 

► 15-29 encounters/day off travel routes (e.g., campgrounds) and 30 or more 

encounters/day on travel routes.

► 13-25 people per group.

► Small areas of alteration prevalent. Surface vegetation gone with compacted

soils observed. Sounds of people regularly heard

 Operational:

► Two-wheel drive vehicles predominant, but also four wheel drives and nonmotorized, mechanized use.

► Information materials describe recreation areas & activities, staff periodically 

present (e.g. weekdays & weekends).

► Rules, regulations and ethics clearly posted. Use restrictions, limitations 

and/or closures.

Rural Classification 

 Physical: 

► Within 1⁄2 mile of paved/primary roads and highways.

► Character of the natural landscape considerably modified (agriculture, 

residential or industrial).

► Modern facilities such as campgrounds, group shelters, boat launches, and 

occasional exhibits.

 Social: 

► People seem to be generally everywhere.

► 26-50 people per group.

► A few large areas of alteration. Surface vegetation absent with hardened soils. 

Sounds of people frequently heard.

 Operational:

► Ordinary highway auto and truck traffic is characteristic.

► Information described to the left, plus experience and benefit descriptions, 

staff regularly present (e.g. almost daily).

► Regulations strict and ethics prominent. Use may be limited by permit, 

reservation, etc.

Urban Classification

 Physical: 

► Within 1⁄2 mile of streets and roads within municipalities and along highways.

► Urbanized developments dominate landscape.

► Elaborate full-service facilities such as laundry, restaurants, and groceries.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix V V - 4

 Social: 

► Busy place with other people constantly in view.

► Greater than 50 people per group.

► Large areas of alteration prevalent. Some recreation. Constantly hear people.

 Operational:

► Wide variety of street vehicles and highway traffic is ever-present.

► Information described to the left, plus regularly scheduled on-site outdoor 

demonstrations and clinics.

► Enforcement in addition to rules to reduce conflicts, hazards, and resource 

damage. 
Appendix W W - i

Appendix W: 

Pompeys Pillar Designations
Appendix W W - ii

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Appendix W W - 1

Establishment of Pompeys Pillar National Monument

January 17, 2001
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Appendix W W - 2
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Appendix W W - 3
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix W W - 4

Federal Register Notice of Establishment of 

Pompeys Pillar National Monument

January 22, 2001
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Appendix W W - 5
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Appendix W W - 6
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Appendix W W - 7
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Appendix W W - 8

Pompeys Pillar National Register of Historic Places

September 20, 1983
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Appendix W W - 9
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Appendix W W - 10
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Appendix W W - 11
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Appendix W W - 12
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Appendix W W - 13
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Appendix W W - 14
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Appendix W W - 15
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Appendix W W - 16
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Appendix W W - 17
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Appendix W W - 18

Pompeys Pillar National Historic Landmark Designation

February 25, 1965
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Appendix W W - 19
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix W W - 20

Notes:

The 1965 "National Survey of Historic Sites and Buildings" survey form was the documentation 

for the designation of Pompeys Pillar as a National Historic Landmark (NHL). These short 

forms, which were generally 1-2 pages in length, served as the NHL documentation forms in 

these early days of the NHL Program. Years later, after the National Park Service developed 

actual National Register nomination forms, then those forms were used to create updated 

documentation forms for NHLs. The 1983 National Register nomination form is the most 

updated NHL nomination form for Pompeys Pillar. 

National Historic Landmark status is different than National Monument status. It wasn't until 

2001 that Pompeys Pillar was declared a National Monument by President Bill Clinton. The 

authority for that designation was through the Antiquities Act (Section 2), which authorizes the 

President to make national monuments out of sites that are "historic landmarks, historic and 

prehistoric structures, and other objects of historic or scientific interest" on land that is already 

managed by the federal government. 
Appendix X: 

Implementation and Monitoring
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Appendix X X - 1 

X. Implementation and Monitoring

Plan implementation is a continuous process occurring over the life of the resource management 

plan that will consider changing circumstances and new information through monitoring. The 

goal is to maintain a dynamic resource management plan that is evaluated and amended if 

necessary on an issue-by-issue basis. 

The implementation and monitoring process for the Billings Field Office and Pompeys Pillar 

National Monument (NM) involves four major steps: planning, implementation, monitoring, 

evaluation, and adjustments, as necessary. 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 based on results, if necessary. 

Planning 

The Proposed Resource Management Plan (RMP) and Final Environmental Impact Statement 

(EIS) is approved once the Record of Decision (ROD) is signed. An Approved Plan will also be 

available that will include all the approved decisions from the RMP. 

The BLM regulation in 43 CFR 1610.5-4 provides that land use plan decisions and supporting 

components can be maintained to reflect minor changes in data. Maintenance is limited to 

further refining, documenting, or clarifying a previously approved decision incorporated in the 

Planning 

Implementation 

Monitoring 

Evaluation 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 2

plan. Maintenance must not expand the scope of resource uses or restrictions or change the 

terms, conditions, and decisions of the Approved Plan.

Land use plan decisions are changed through either a plan amendment or a plan revision. The 

process for conducting plan amendments is essentially the same as the land use planning process 

used in developing RMPs. The primary difference is that circumstances may allow for 

completing a plan amendment through the environmental assessment (EA) process, rather than 

through an EIS. Plan amendments (43 CFR 1610.5-5) change one or more of the terms, 

conditions, or decisions of an approved land use plan. Plan amendments are most often 

prompted by the need to consider a proposal or action that does not conform to the plan; 

implement new or revised policy that changes land use plan decisions; respond to new, 

intensified, or changed uses on BLM land; and consider significant new information from 

resource assessments, monitoring, or scientific studies that change land use plan decisions.

Implementation

Implementation of the resource management plan (RMP) begins once the Record of Decision 

and Approved Plan for the Proposed RMP/Final EIS is signed. 

Decisions made through the RMP planning process are implemented over a period of time. 

Some of the decisions are immediate and go into effect with the Record of Decision. These 

include decisions such as the road designations and lands available for disposal through 

exchange. Some decisions would be implemented after a site-specific environmental review is 

completed. Examples include range improvements, recreation sites, or approval of an 

application for permit to drill a natural gas well. Other decisions include guidance that would be 

applied during site-specific analysis or activity planning.

Any future proposals or management actions will be reviewed against the Approved Plan to 

determine if the proposal would be in conformance with the RMP. While the Final EIS for the 

Billings and Pompeys Pillar NM RMP provides the compliance with NEPA for the broad-scale 

decisions to be made in the Record of Decision, it does not replace the requirement to comply 

with NEPA for implementation actions. 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. 

Activity level planning will address any proposed new activities and long-term permitted 

activities that need to be brought into compliance with plan decisions, subject to valid existing 

rights. Monitoring of these activities will then determine the effectiveness of applying the land 

use plan direction. Where land use plan actions or best management practices are not effective, 

modifications could occur without amendment or revision of the plan as long as assumptions and 

impacts disclosed in the analysis remain valid and broad-scale goals and objectives are not 

changed. This approach uses on-the-ground monitoring, review of scientific information, and 

consideration of practical experience and common sense to adjust management and modify 

implementation of the plan to reach the desired outcome.
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Appendix X X - 3

As part of this process, the BLM will review management actions and the plan periodically to 

determine whether the objectives set forth in this document are being met. Where they are not 

being met, the BLM will consider adjustments of appropriate scope. Where the BLM considers 

taking or approving actions which will alter or not conform to overall direction of the plan, the 

BLM will prepare a plan amendment and environmental analysis of appropriate scope.

In addition, during the life of the Approved Plan, the BLM expects that new information 

gathered from field inventories and assessments, research, other agency studies, and other 

sources will update baseline data or support new management techniques, best management 

practices, and scientific principles. To the extent that such new information or actions address 

issues covered in the plan, the BLM will integrate the data through plan maintenance. 

Monitoring

Monitoring is the repeated measurement of activities and conditions over time. Monitoring data 

gathered over time is examined and used to draw conclusions on whether management actions 

are meeting stated objectives, and if not, why. Conclusions are then used to make 

recommendations on whether to continue current management or what changes need to be made 

in management practices to meet objectives.

Monitoring determines whether planned activities have been implemented in the manner 

prescribed by the plan. This monitoring documents BLM’s progress toward full implementation 

of the land use plan decision. There are no specific thresholds or indicators required for this type 

of monitoring.

Monitoring also is used to determine if the implementation of activities has achieved the desired 

goals and objectives. This requires knowledge of the objectives established in the RMP as well 

as indicators that can be measured. Indicators are established by technical specialists in order to 

address specific questions, and thus avoid collection of unnecessary data. Success is measured 

against the benchmark of achieving desired future conditions established by the plan.

Monitoring is also used to ascertain whether a cause-and-effect relationship exists among 

management activities or resources being managed. It confirms whether the predicted results 

occurred and if assumptions and models used to develop the plan are correct. This type of 

monitoring is often done by contract with another agency, academic institution, or other entity, 

and is usually expensive and time consuming since results are not known for many years.

Regulations at 43 CFR 1610.4-9 require that the proposed plan establish intervals and standards, 

as appropriate, for monitoring and evaluation of the plan, based on the sensitivity of the resource 

decisions involved. Progress in meeting the plan objectives and adherence to the management 

framework established by the plan is reviewed periodically. CEQ regulations implementing 

NEPA state that agencies may provide for monitoring to assure that their decisions are carried 

out and should do so in important cases (40 CFR 1505.2(c)). To meet these requirements, the 

BLM will prepare periodic reports on the implementation of the RMP.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 4

Evaluation

Evaluation is a process in which the plan and monitoring data are reviewed to see if management 

goals and objectives are being met and if management direction is sound. 

Land use plan evaluations will be used by BLM to determine if the decisions in the RMP, 

supported by the accompanying NEPA analysis, are still valid. Evaluation of the RMP will 

generally be conducted every five years, unless unexpected actions, new information, or 

significant changes in other plans, legislation, or litigation triggers an evaluation. Land use plan 

evaluations determine if decisions are being implemented, whether mitigation measures are 

satisfactory, whether there are significant changes in the related plans of other entities, whether 

there is new data of significance to the plan, and if decisions should be changed through 

amendment or revision. 

Based on a Record of Decision and Approved Plan released in the spring of 2014, the following 

evaluation schedule would be followed for the Billings and Pompeys Pillar National Monument

RMP/EIS: 

Fall 2019

Fall 2024

Fall 2029

Fall 2034

Evaluations will follow the protocols established by the BLM Land Use Planning Handbook 

H-1601-1 in effect at the time the evaluation is initiated.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 5

INTRODUCTION

For each resource, there are a series of items that will be monitored. Each item is evaluated by location, technique 

for data gathering, unit of measure, frequency, remedial action trigger, and management option (Table 1). The

monitoring and evaluation plan states the event that will be evaluated and lists the key resources that will be 

managed in the planning area. If an adverse impact can be corrected by a management action within the scope of

this plan, the change will be implemented. If the adverse impact can be corrected only by a management action that

is outside the scope of this plan, the management change will be a formal amendment.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 6

MONITO

RING

APPENDIX

TABLE 1. MONITORING TABLE

Element Item Location Technique Unit of Measure Frequency and

Duration

Remedial

Action

Trigger

Management

Options

AIR RESOURCES AND CLIMATE

Air Resources

and Climate

Gaseous and

particulate

regulated air

pollutants and air

quality related

values(AQRVs),

such as acid

deposition, lake

acidification, and

visibility

Area-wide

Air quality

photochemical

grid modeling

Micrograms/cubic

meter (μg/m

3) and

parts per million

(ppm)

concentrations(as

μg/m

3

)

Modeling will

be performed

when adequate

data are

available to

validate model

performance

(see the Air

Resources and

Climate

Appendix)

Predicted

exceedances

of National

Ambient Air

Quality

Standards

(NAAQS) or

Montana

Ambient Air

Quality

Standards

(MAAQS) or

unacceptable

impacts to

AQRVs

Implement

additional

emission

controls or

operating

limits

Gaseous and

particulate

regulated air

pollutants

Area-wide

Continued

automated

sampling and

analysis

μg/m

3

and ppm

concentrations(as

μg/m

3

)

Continuous

Measured

exceedances of

NAAQS or

MAAQS

Implement

additional

emission

controls or

operating

limits

Climate

indicators

including

temperature,

precipitation,

precipitation

timing and

intensity,

snowfall, snow

pack, albedo,

greenhouse gas

Area-wide

Analysis of

existing climatic

data and climate

change data

available from

the National

Oceanic and

Atmospheric

Administration,

the Western

Degrees

Fahrenheit (°F),

degrees Celsius

(°C), inches, feet,

unitless(albedo),

ppm, parts per

billion

Annual

None (actions

triggered based

on resourcespecific

concerns)

Provide annual

updates

summarizing

recent climate

trends to

Bureau of Land

Management

(BLM)

resource

management
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 7

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

(GHG)

concentrations

Regional

Climate Center,

United States

Environmental

Protection

Agency

(USEPA), and

other reliable

sources of

information

personnel

SOILS

Soils Soil erosion,

uplands

Area-wide

where

management

activities are

occurring or

expected to

occur

Visual

observation,

photo point,

rangeland

health

assessment,

surface

aggregate

stability test,

silt fence, and

surveyed

erosion pins

Soil loss in tons per

acre

Site will be

visually

examined

quarterly.

Where erosion

is considered

excessive,

measurements

of site

characteristics

will be taken to

determine rate

of soil loss.

Visual 

evidence of

pedestal, wind

scour, rill

greater than 3

inches, active

headcutting

gully, or sheet

erosion. Soil or

site stability

indicators are

not similar to

reference

rangeland

health

conditions.

Change in

surface

aggregate

stability to a

lower class.

Loss of soil

exceeding 10

Report

exceedance to

the BLM,

Montana

Department of

Environmental

Quality

(MDEQ), or

USEPA.

Enforcement

action would

be taken.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 8

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure Frequency and

Duration

Remedial

Action

Trigger

Management

Options

tons per acre

per year

Soils

(cont’d)

Soil erosion,

streambanks,

riparian areas,

and floodplains

Area-wide

along rivers and

tributaries

where

management

activities are

occurring or

expected to

occur

Visual

observation,

photo point,

rangeland

health or proper

functioning

condition

assessments,

silt fence, and

surveyed

erosion pins

Area affected in

square feet or

acres

Site would be

visually

examined

quarterly.

Where

streambank

erosion is

considered

excessive,

measurements

of site

characteristics

will be taken to

determine soil

loss.

Visual

evidence of

active

headcutting,

channelization

beyond natural

conditions, or

bank slump.

Proper

functioning

condition

(PFC) rated

functional-atrisk with a

downward

trend or

nonfunctional.

A 10%

increase in

streambank

loss.

Report

exceedance to

the BLM,

MDEQ, or

USEPA.

Enforcement

action would

be taken.

Soilsalinization

and sodification

Area-wide

where

management

activities were

occurring or

expected to

occur

Visual

observation,

measurement of

soil

characteristics

such as

(electrical

conductivity

(EC), sodium

adsorption ratio

(SAR),

Area affected in

square feet or

acres

Site would be

visually

examined

quarterly.

Where impacts

to soil or

vegetation were 

observed,

measurements

of site

A 20%

increase in

levels in EC,

SAR, or

exchange

sodium

percentage

(EC greater

than 8, SAR

greater than 8,

exchangeable

Report

exceedance to

the BLM,

MDEQ, or

USEPA.

Enforcement

action would

be taken.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 9

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure Frequency and

Duration

Remedial

Action

Trigger

Management

Options

exchange

sodium

percentage, and

pH

characteristics

would be taken

to determine

salinity and

sodicity levels.

sodium

percentage

greater than

10, or pH

greater than

8.5)

Soils

(cont’d)

Compaction

Area-wide

where

management

activities were

occurring or

expected to

occur

Visual

inspection,

penetrometer, or

ratio of

penetration

resistance or

bulk density to

that of the

reference area

Lbs. per square

inch, mass per

volume

Site would be

visually

examined 1 to

2 times yearly;

where

compaction is

considered

excessive,

measurements

would be taken.

When an area

has a 10%

increase in

density or

ratio of

penetration

resistance or

bulk density

to that of the

reference area

greater than 1

and the

compacted

area exceeds

10% of surface

disturbance

Decompact or

close access to

compacted site

until area

recovers from

compaction

Rutting

Area-wide

where

management

activities were

occurring or

expected to

occur

Visual

observation and

measured depth

of rut

Inches

Site would be

visually

examined 1 to

2 times yearly.

Where rutting is

considered

excessive,

measurements

would be

taken.

Ruts exceed 4

inches in depth

Close access to

rutted site until

soil conditions

are not

susceptible to

rutting and are

repaired.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 10

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

Soils

(cont’d)

Subsidence of fill

material

Areas where

management

activities

required fill

material

Visual

observation and

measured depth

of subsidence

Feet

Site would be

visually

examined 1 to

2 times yearly.

Where

slumping or

piping is

considered

excessive,

measurements

would be taken.

10% increase

in slumping or

piping depth

Close access to

site until area is

reclaimed

WATER

Water

Surface water

quality and

quantity

In watersheds

expected to be

affected,

potentially

affected, or

down gradient

from CBNG

surface

discharge points

or regionally at

the monitoring

stations

identified by the

interagency

working group

(refer to Final

Supplement to

the Montana

Statewide Oil

and Gas

Environmental

Impact

As determined

by the

interagency

working group

(refer to the

FSEIS) or

water quality

parameters,

temperature,

and discharge

or stage

measurements

As determined by

the interagency

working group

(refer to the

FSEIS) or feet,

cubic feet per

second (cfs), and

standard

quantitative

measurements of

water quality (e.g.,

milligrams per liter

[mg/L], pH,

μS/cm, and

°C)

As determined

by the

interagency

working group

or based on

activity plan

schedule (refer

to the FSEIS)

Exceedance of

any parameter

above the State

of Montana

surface water

quality

standards or

identified

BLM

thresholds

(refer to the

FSEIS)

Report 

exceedancesto

the MDEQ,

which would

determine cause

and take

appropriate

actions if

monitoring

indicatesthat

BLM thresholds

were met or

exceeded, 

Untreated 

discharge of

CBNG water

from federal

wells would no

longer be

allowed 

upstream from

that station.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 11

MONITO

RING

APPENDIX

MON-7

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

Statement and 

Proposed 

Amendment of the

Powder River and

Billings Resource

Management

Plans [FSEIS]).

Note that the

10% of 7Q10 

criteria for

untreated

CBNG water

would apply

unless stations

upstream and

downstream

from proposed

outfalls are

monitored

(refer to the

FSEIS).

Previous 

approvals may be

modified.

Water

(cont’d)

Groundwater

drawdown

Regionally at

locations

determined by

the interagency

working group

(refer to the

FSEIS)

Monitoring

wells would be

finished in

bedrock units;

especially coal

seams expected

to be developed

for CBNG.

Depth to water

reported in

hundredths of feet

Depth to water

measurements

would be made

approximately

monthly to

establish an

initial baseline.

Measurements

would be

A 20-foot

decrease in

static water

level from

seasonally

adjusted mean

static water

level

(determined

from baseline

data) (refer to

If falling water

levels were

determined to

be caused by

CBNG

activity,

operators must

offer water well

mitigation

agreements to

all landowners
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 12

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

made

approximately

quarterly

thereafter

unless a greater

frequency was

determined to

be necessary.

Monitoring

would continue

until at least

80% recovery

of static water

level was

achieved.

the FSEIS) with water

sources in the

defined

drawdown area

(20 feet or

greater

drawdown) of

their

development.

Hydrologic

barriers, such as

injection wells,

may be an

option in some

cases to prevent

drainage of

American

Indian gas and

water resources.

Water

(cont’d)

Groundwater

quality and

quantity

Alluvial

groundwater

would be

monitored in

stream valleys

topographically

down gradient

from CBNG

surface

discharge points.

Since discharge

to ephemeral

streams would

not be allowed,

Monitoring

wells would be

finished in the

alluvium. Depth

to water

measurements

and water

quality

parameters,

including (but

not limited to)

pH, EC, water

temperature,

common ions

(Na, Mg, Ca,

Standard

quantitative

measurements of

water quality and

static water level

(mg/L, °C,

μS/cm, and

hundredths of

feet)

Depth to water

measurements

would be made

approximately

monthly to

establish an

initial baseline.

Depth to water

would then be

collected

approximately

quarterly

thereafter.

A change in

groundwater

chemistry that

affects its class

of use or rise in

static

groundwater

levels of 5 feet

or more that

may cause

impacts at the

ground surface

(refer to the

FSEIS)

If impacts

were

determined to

result from

CBNG

development,

direct discharge

of CBNG water

into waterways

in the watershed

may be

discontinued

until modified
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 13

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

these wells

would be along

larger streams

(refer to the

FSEIS).

K, HCO3, CI,

SO4) would be

obtained.

Water quality

samples would

be taken

approximately

annually unless

more frequent

monitoring is

needed.

Monitoring

would continue

until at least

80% recovery

of static water

level was

achieved.

water

management

plans were

submitted and

approved (refer

to the FSEIS).

Water

(cont’d)

Groundwater

quality and

quantity

Operators

would install

monitoring

wells adjacent

to

impoundments

(refer to the

FSEIS).

A monitoring

well would be

installed within

the first

permeable unit

and within the

first

groundwater

encountered (up

to 50 feet total

depth) to

determine

effectiveness of

infiltration; if

evaporation

basins were

leaking, a water

quality sample

of the

Depth to water

(feet to water

reported in

hundredths of

feet). Water

quality samples

would be collected

if rises in

groundwater were

observed or if

water were

observed in a

previously dry

zone.

Wells would

be gauged

monthly for the

first year and

quarterly

thereafter

unless a rise

was observed.

If a rise were

observed,

monitoring

would be

monthly. Water

quality samples

would be

collected

whenever the

water level is

above

A rise of 1 foot

or more in

static water

levels above

seasonally

adjusted mean

water levels

(determined

from the first

year of data) or

a change in the

class of use in

the

groundwater

(refer to the

FSEIS).

Any change in

class of use

would be

reported to the

MDEQ.

Operators may

be required to

install

additional

monitoring

wells further

downgradient,

or discharge

into

impoundments

may be required

to cease until a

revised water
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 14

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

first

groundwater (if

encountered)

would be

collected to

determine class

of use.

baseline.

Monitoring

would continue

at least until the

end of CBNG

water discharge

into the

impoundment.

management

plan is

submitted and

approved (refer

to the FSEIS)

Water

(cont’d) Springs

A network of

springs

determined to

be fed by the

regional flow

system would

be identified

along coal

outcrops in the

CBNG

development

area (refer to

the FSEIS)

Spring

discharge and

water quality

parameters,

including (but

not limited to)

pH, EC, water

temperature,

and common

ions (Na, Mg,

Ca, K, HCO3,

CI, SO4),

would be

determined

from existing

springs.

Discharge cubic

feet per second

(cfs), pH, EC

(μS/cm), and water

temperature (°C)

would be

determined in the

field. Standard

quantitative

measurements of

water quality also

would be used

(mg/L).

Field

measurement of

discharge, pH,

EC, and water

temperature

would be

determined

approximately

quarterly. An

initial water

quality sample

would be

collected;

additional

samples would

be analyzed if

substantial

changes in the

field parameters

were observed.

A 50%

decrease in

spring

discharge

below

seasonally

adjusted mean

(determined in

the first 3

years) or a

significant

change in water

quality that

affects its

beneficial use

(refer to the

FSEIS).

If decreased

spring

discharges or

water quality

were

determined to

result from

CBNG

activity,

operators must

offer spring

mitigation

agreements to

landowners

who use the

spring. If the

affected spring

were identified

as important

wildlife habitat,

adaptive

management

practices would

be used at the
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 15

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

landscape level

to improve

spring

ecosystems.

Hydrologic

barriers, such as

injection wells,

may be an

option in some

cases to prevent

drainage of

American

Indian gas and

water resources

(refer to the

FSEIS).

Water

(cont’d)

Streambank or

channel

alteration

Any federal

area-wide action

in which

potential

impacts from

management

activities are

occurring or

expected to

occur

Monumented

crosssections,

longitudinal

profile, visual

inspection,

photo point,

PFC, surveyed

erosion pins,

and any suitable

methods as

described in

Grazing

Management

Processes and

Strategiesfor

Riparianwetland Areas

Area affected in

square feet or

acres

Based on

activity plan

schedule and a

minimum of

once every 10

years

Trend away

from

objective, a

10%

increase in

streambank or

channel

alteration,

exceedance of

any parameter

above the State

of Montana

surface water

quality

standards for

sediment, total

Activities

would be

required to be

altered or

discontinued in

order to provide

environmental

factors for

increasing

functionality or

conditions of the

streams.

Exceedance

would be

reported to

BLM, MDEQ,

or USEPA and
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 16

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

(Wyman et al.

2006), Bureau

of Land

Management

Prairie Stream

Surveys: Study

Plan (BLM

2010k), and

Stream

Channel

Reference

Sites: An

Illustrated

Guide to Field

Technique

(Harrelson,

Rawlins, and

Potyondy

1994).

suspended

solids, or

turbidity

without a

variance.

enforcement

action would

be taken.

Water

(cont’d)

Surface water

quality and

quantity

Any federal

area-wide action

in which

potential

impacts from

management

activities are

occurring or

expected to

occur

Water quality

parameters,

temperature,

discharge, or

stage

measurements

Feet, cfs, or

standard

quantitative

measurements of

water quality (e.g.,

mg/L, pH,

μS/cm, °C)

Based on

activity plan

schedule

Exceedance of

any parameter

above the State

of Montana

surface water

quality

standards

Activities would

be required to be

altered or

discontinued.

Exceedance

would be 

reported to

BLM, MDEQ,

or USEPA and

enforcement

action would be

taken.

Water, Indian

trust

Groundwater

Adjacent to the

Northern

Cheyenne and

Sampling of

dedicated

monitoring

Standard

quantitative

measurements of

Field

measurements

six times

Where sitespecific studies

show a

The BLM

would require

the operators
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 17

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

Crow Indian

Reservations

wells in the

zones of

extraction and

zones above and

below the

expected

activity; wells

are to be placed

in the affected

areas to areas

unaffected by

management

activities

water quality and

measurement of

depth in feet

annually prior

to production

activities and

continued

throughout the

activity period

and for the

duration of

95% of the

recovery of predevelopment

conditions

potential to

affect

Reservation

groundwater,

the tribe would

be consulted as

to appropriate

protection

measures and

where

continuous

monitoring

showed a

drawdown of

groundwater

attributed to

CBNG

production.

to modify

federal CBNG

production.

Mitigation

options would

include

reducing

production

rates, shutting

in the well or

wells,

establishing a

hydrologic

barrier, or

providing

compensation

to the affected

tribe.

Water, Indian

trust

Groundwater

Adjacent to the

Northern

Cheyenne and

Crow

Reservations

Monitoring

wells would be

established near

the mouth of

streams

containing

alluvium

Measurements of

depth in feet

Water level

measurements

would be taken

monthly prior

to production

activity and

during

development

and water

quality

measurements

would be taken

4 times per year

A 20% rise in

the water table

above its

seasonally

adjusted

elevation, or a

2-unit increase

in the SAR

value

Discontinue

CBNG

evaporative

ponds in that

watershed or

require ponds

to be lined
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 18

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

VEGETATION

Trees and

shrubs

Functional

habitat within

desired

conditions

Site-specific

and landscapelevel

Visual

observation,

photos,

utilization,

browseevaluation,

trend

Cover, diversity, and

composition.

Varies and

designed to

address

objectives

Failure to

meet

Rangeland

Health

Standards.

Trend moving

away from

management

objectives.

Change in

livestock

season-of-use,

timing,

intensity,

frequency, and

duration

Herbaceous

Functional

habitat within

desired

conditions.

Site-specific

and landscapelevel

Utilization,

visual

observation,

photos, and

trend

Cover, diversity, and

composition.

Varies and

designed to

address

objectives

Failure to

meet

Rangeland

Health

Standards or

trend moving

away from

management

objectives

Change in

livestock

season-of-use,

timing,

intensity,

frequency, and

duration

Riparian and

Wetland

Functional rating

and trend

Priority

allotments with

allotment

management

plans and areas

rated as nonfunctional or

functional-at

risk with

downward trend

Lotic and lentic

standard PFC

checklist and

multiple

indicators

monitoring

techniques(see

Riparian Area

Management, A

User Guide to

Assessing

Proper

Functioning

Condition and

the Supporting

Science for

Miles or acres

based on

functional rating

and trend

Once every 5

to 10 years

based on

priority of

non-functional

and

functional-at

risk with

downward

trend areas

Trend away

from objective

or when no

improvement

occurs in areas

rated as nonfunctional and

functional-at

risk with

downward

trend

Management

changes would

address causes

of degradation.

If impacts to

management

changes did not

maintain or

improve

riparian and

wetland

functionality,

additional

monitoring or

project revision

would
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 19

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

Lotic Areas,

TR 1737-15

[Prichard 1998]

and Riparian

Area

Management A

User Guide to

Assessing

Proper

Functioning

Condition and

the Supporting

Science for

Lentic Areas,

TR 1737-16

[Prichard et al.

1999])

be required.

Oil and gas

operators would

be required to

alter activities in

order to provide

environmental

factors for

maintaining or

improving

functionality of

riparian and

wetland areas.

Noxious and 

Invasive Species Infestations

Inventoried

infestation

Photo points,

geographic

information

systems(GIS)

data, mapping,

and National

Invasive

Species

Information

Management

System

Infestation size,

presence or

absence

Annually or

every 3 to 5

years and

prioritized by

species

location and

treatment

method.

Expansion of

weeds, Early

Detection

Rapid

Response, new

infestationsin

areas of high

public use,

and public

accessible

areas

Change in

control method

or combine

multiple control

methods and

strategies

FISH AND WILDLIFE

Fisheries and

aquatic

wildlife in

prairie

streams

Habitat conditions

and index of

biological integrity

All locations 

within Miles City

Field Office 

(MCFO)

Bureau of Land

Management

Prairie Stream

Surveys: Study

Plan (BLM

300 meter stream

study reaches

Every 5 years

(all sites or

streams)

As needed: as

Decrease in 

index of 

biological

integrity score,

habitat

Management 

changes would 

address causes of

degradation. If

impacts to
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 20

MONITO

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APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

prairie stream

survey protocol

and

locations as

needed due to

degraded

habitat,

allotment

inspections,

pre- and postdevelopment,

or as other

needs arise

2010k) and

index of

biological

integrity

approach

following

Development

and evaluation

of a fish

assemblage

index of biotic

integrity for

Northwestern

Great Plains

streams

(Bramblett,

Johnson, Zale,

and Heggem

2005) and Fish

and Habitat

Sampling

Protocol for

Prairie Streams

(Bramblett

2003)

determined by

a decrease in

riparian 

conditions

(e.g. declining

PFC rating),

water quality or

water resource

parameters

indicate a

decline in

habitat

conditions, or

land-use or

development

plansindicate a

potential for

deleterious

impacts to

habitat

parameters,

decreased

riparian

function, or

allotment

failing to meet

Standards for

Rangeland

Health

management

changes did not

maintain or

improve prairie

streamaquatic

wildlife habitat,

additional

monitoring or

project revision

would be

required. Oil

and gas

operators would

be required to

alter activities in

order to provide

environmental

factors for

maintaining or

improving

prairie stream

aquatic wildlife

habitat.

Fisheries and

aquatic

wildlife in

sport-fish

reservoirs

Habitat

conditions and

surveys by

Montana Fish,

Wildlife, and

Parks(MFWP)

Designated

sport-fish

reservoirs

Gill netting and

trapping

conducted by

MFWP

Acres of reservoir

1 to 5 years or

determined by

MFWP

Decrease in

population

sizes due to

factorsrelated

to resource use

Management

changes would

address causes

of degradation.

If impacts of

management

changes did not

maintain or

improve sport-
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 21

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

fish reservoir

habitat,

additional

monitoring or

project revision

would be

required. Oil

and gas

operators would

be required to

alter activities

to provide

environmental

factors for

maintaining or

improving

sport-fish

reservoir

habitat.

Upland game

birds and

migratory bird

species

Use and trend

Sharp-tailed and

sage- grouse

leks or winter

grounds and

migratory bird

species habitats

Field inspect

leks/breeding

bird surveys

and strategies

outlined in the

Wildlife

Appendix

Number of

males/numbers

and species of

migratory birds

Monitoring will

be tied to

yearly (varies

per species, 1-

5 years for

migratory bird

species)

planning with

MFWP or

based upon

project specific

need or

existing

requirements

Varies and is

projectspecific (i.e.,

downward

trend in lek

attendance)

Extension of

timing or project 

location or relocation,

stipulations or

COAs, and offsite mitigation
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 22

MONITO

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APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

Threatened and

Endangered

species and

other special

status wildlife

species habitat

Habitat use and

trends

Black-tailed

prairie dog

colonies,

interior least

terns, and

specialstatus

speciesraptor

nests

Field surveys

that include

aerial, boat, or

ground survey

methodologies

Acres and number

of prairie dog

colonies, least tern

numbers and

nesting sites, and

raptor nest site

surveys

Monitoring

will be tied to

yearly planning

with MFWP or

based upon

projectspecific need or

existing

requirements

Varies and is

project- specific

Extension of

timing or

project location

re- location;

stipulations or

COAs; off-site

mitigation

Upland game

bird: sage and

sharp-tailed

grouse

Habitat condition

or baseline data

collection

Sage-grouse

nesting, broodrearing, winter

grounds, and

sharp-tailed

grouse habitats

Methodologies

such as line

point intercept

and other

methodologies

as outlined in

the Management

Plan and

Conservation

Strategiesfor

Sage Grouse in

Montana-Final

(Montana Sage

Grouse Work

Group 2005)

Existing habitat

conditions, height

of residual

vegetation, cover,

species diversity,

and potential

habitat trends

Monitoring

will be tied to

grazing permit

renewals,

existing

conditions, and

allotments that

contain a high

percentage of

BLMadministered

lands and other

actions that

cause direct or

indirect habitat

loss

Varies and is

project- specific

Mitigate

potential effects

of habitat

conditions or

loss or require

changes to

livestock

season-of-use

Wildland Fire Management and Ecology

Wildland Fire

Management

and Ecology

Fire Regime and

Condition Class

(FR/CC)

Area-wide

FR/CC

Standard

Landscape

Worksheet

Composition of

departure and

condition classes

compared to

reference

conditions

Field

measurements

evaluated on a

10-year cycle

A change in

the direction of

trend away

from

management

Implement

additional

vegetation or

habitat

treatments
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 23

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

CULTURAL RESOURCES

Cultural 

Resources

Random sample

of 10 additional

sites

Area-wide Site inspection Site, surrounding

area

Annually

Any noticeable

trend

indicating

increased

disturbance,

natural or

human-caused

For any

noticeable

trend 

indicating

increased

disturbance

(natural or 

humancaused), halt

activity affecting

sites, increase

frequency and

number of sites

monitored (if

sites are being

impacted),

increase

monitoring of

nearby sites,

and evaluate

damage to sites
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 24

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

Cultural

Resources

(cont’d)

Site degradation

caused by human

activity

Significant

cultural sites

and area-wide

Inspection of

area disturbed

Site, surrounding

area

Annually

Any noticeable

trend indicating

increased

disturbance

(natural or

humancaused), such

as excavations

Closure of 

areas

surrounding site

to prevent

further 

disturbance to

significant

cultural

resources(may

require an RMP

amendment); for

any noticeable 

trend indicating

increased

disturbance

(natural or

human-caused),

halt activity

affecting sites,

increase

frequency and

number of sites

monitored (if

sites are being

impacted),

increase

monitoring of

nearby sites, and

evaluate

damage to sites
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 25

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

Cultural

Resources

(cont’d)

Environmental

degradation,such

as erosion or

trampling

Significant

cultural sites

and area-wide

Inspection of

displaced or

altered area

Site, surrounding

area Annually

Accelerated

loss or

damage to

significant

cultural

material

Closure of

areas

surrounding site

to prevent

further

disturbance to

significant

cultural

resources(may

require an RMP

amendment; for

any noticeable

trend indicating

increased

disturbance

(natural or

human- caused),

halt activity

affecting sites,

increase

frequency and

number of sites

monitored (if

sites are being

impacted),

increase

monitoring of

nearby sites, and

evaluate damage

to sites
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 26

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

PALEONTOLOGICAL RESOURCES

Paleontological

Resources

Significant

paleontological

localities

Area-wide Inspection of

disturbed area

Degradation

caused by human

or natural activities

that lead to loss of

significant fossil

resources

Annually

Loss or

damage to

significant

fossil

resources

Closure of

areas

surrounding site

to prevent

further

disturbance to

significant fossil

resources (may

require an RMP

amendment)

Random

sample of 5

additional sites

Area-wide Inspection of

disturbed area

Degradation

caused by human

or natural activities

that lead to loss of

significant fossil

resources

Annually

Loss or

damage to

significant

fossil

resources

Closure of

areas

surrounding site

to prevent

further

disturbance to

significant fossil

resources (may

require an RMP

amendment)

Locality

degradation

caused by human

activity

Significant

paleontological

localities

Inspection of

area disturbed

Percentage of

locality

Annually

Any

noticeable

trend

indicating

increased

disturbance

such as

excavations

Closure of

areas

surrounding

site to prevent

further

disturbance to

significant

fossil resources

(may require

an RMP

amendment)
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 27

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

Paleontological

Resources

(cont’d)

Environmental

degradation,such

as erosion or

trampling

Significant

paleontological

localities

Inspection of

displaced or

altered area

Number of fossils Annually

Accelerated

loss or

damage to

significant

fossils

Closure of

areas

surrounding site

to prevent

further

disturbance to

significant fossil

resources (may

require an RMP

amendment)

VISUAL RESOURCE MANAGEMENT (VRM)

VRM I (see Wilderness in this table)

VRM II VRM II See Map # Field visit Photo points Once every 1

to 5 years

Unanticipated

or

unacceptable

effects or

conflicts

occurring

Require

mitigation;

signing;

increase

enforcement

visits; and

replan for area

(may require an

RMP

amendment)

VRM III/IV

Large scalesurface

disturbing

project

Planning area

Field visit or

key

observation

points

Photos As the need

arises

Large-scale

surfacedisturbing

project on

landscape

Require

mitigation

LANDS WITH WILDERNESS CHARACTERISTICS
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 28

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

CAVE AND KARSTS
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 29

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

FORESTRY AND WOODLAND PRODUCTS

Forestry and 

Woodland 

Products

(cont’d)

Reforestation BiFO

Site inspection

and stocking

surveys

Trees per acre and

visual evaluation

of tree vigor

Initial survey

10 years after

harvest or

wildfire;

subsequent

survey after 15

years to

determine if

artificial

regeneration is

necessary

Less than 150

trees per acre;

trees greater

than 4.6

inches

diameter at

breast height

Planting of

nursery stock

or broadcast

seeding

Silvicultural

treatments BiFO Site inspection

Trees per acre;

basal area per

acre; volume per

acre (thousand

board feet per

acre); and size

classes; visual

evaluation of

forest health

Pre- and posttreatment

Obtain current

stand data

information

and evaluate

effects of

treatments

Stocking

surveys, stand

exams, forest

inventory,

permanent

plots, and photo

points

Forest health BiFO

National

Agricultural

Imagery

Program

photography,

aerial detection

surveys, site

visits

Visual evaluation Annually

Evaluate insect

and disease

damage and

tree mortality

levels

Silvicultural 

treatments,

sanitation

harvest,

chemical

application 

(e.g.,

verbenone,

carbaryl)

Roads BiFO Site Inspection Visual Evaluation

Pre- and posttreatment

Damage to

road surface

(e.g., rutting,

erosion,

sediment

Culvert

replacement or

installation,

rolling dips,

proper
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 30

MONITO

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APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

delivery, or

culvert

washouts)

drainage and

road placement,

reconstruction,

cut and fill

slope

stabilization,

surface blading,

grass seeding,

armoring, road

closures, timing

restrictions, and

other activities

(see Montana

BMPs in the

Forestry and

Woodland

Products

Appendix)

MINERALS

Coal

Exploration

license

Area-wide Site inspection Exploration

license

The

regulations at

43 Code of

Federal

Regulations

(CFR)

3480.06(d)(4)

require

inspections of

exploration and

production as

frequently as

necessary,

Noncompliance

with the terms

and conditions

of the

exploration

license, or

operating

regulations;

poor

reclamation; or

Require

compliance

with terms and

conditions of

the license,

require

appropriate

reclamation,

and eliminate

environmental

degradation
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 31

MONITO

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APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

Coal

(cont.)

but at least

quarterly.

Exploration

license areas

must be

inspected for

compliance

with sitespecific

stipulations,

terms and

conditions of

the license, and

reclamation

success prior to

bond release.

Because

exploration

licenses expire

after 2 years

license areas

are typically

inspected after

expiration of

the license but

prior to bond

release (or

sooner if

requested by

the proponent).

environmental

degradation

Oil, Gas, and

Geothermal

Geophysical

notice of intent

(NOI)

Area-wide Line or area

inspection

Operations 

conducted in

compliance with

Minimum of

once during

operations

Violation of

regulations,

change from

Issue certified

letter with

corrective
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 32

MONITO

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APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

NOI approved NOI action and

timeframe;

bond release

cannot occur

until violations

are corrected

Oil, Gas, and

Geothermal

(cont’d)

Application for

permit to drill

operations

(surface and

technical

inspections)

Area-wide Site inspection

Operations

conducted in

compliance with

applicationsfor

permit to drill

Surface

Inspections:

construction,

drilling, and

production –

Minimum of

once and as

necessary

Interim and

final

reclamation –

minimum of

once and until

reclamation is

complete

Technical

inspection:

drilling and

production –

Violations of

regulations,

change from

approved

applications

for permit to

drill

Issue a written

order or an

incident of noncompliance

with timeframe

to correct

violations or

shut in

operations
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 33

MONITO

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APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

minimum of

once and as

necessary

Oil, Gas, and

Geothermal

(cont’d)

Sundry notice Area-wide Site inspection

Operations

conducted in

compliance with

approved sundry

notice

As necessary

Violations of

regulations,

change from

approved

sundry notice

Issue a written

order or an

incident of

noncompliance

with timeframe

to correct or

shut in

operations

Oil and gas

drainage Area-wide

Drainage

evaluation

Radius of

drainage

As necessary

The BLM

determines that

federal oil or

gas is being

drained

(physically

removed) by an

off-lease well.

Notify lessee of

drainage

situation.

Require lease

protection,

compensatory

royalty, or

relinquishment

Produced water

disposal

Area-wide Site inspection

Operations

conducted in

compliance with

permit

Minimum of

once annually

or as necessary

Violation of

regulations or

change from

approved

permit

Issue a written

order or an

incident of

noncompliance

with timeframe

to correct or

shut in

operations

Spill Area-wide Site inspection Spill area cleaned up

and reclaimed

Minimum of

once after event

and as

necessary

Violation of

regulations or

change from

approved

permit

Issue a written

order or an

incident of

noncompliance
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 34

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

with timeframe

for correction

Locatable

Minerals NOIs Area-wide Site inspection NOI

At least four

times each year,

the responsible

field office

would inspect

an operation if

the operator

uses cyanide or

other leachates

or where there

is significant

potential for

acidic or

deleterious

drainage(43

CFR

3809.600(b).

active notices

and plans that

do not involve

leachates

should be

inspected at

least two times

per year. These 

inspection 

frequencies are 

minimums; 

field offices are 

encouraged to 

conduct 

inspections on 

a more frequent 

basis where it 

Noncompliance

with the terms

and conditions

of the NOI or

Plan of

Operations,

surface

management

regulations,

poor

reclamation, or

environmental

degradation

Require

compliance

with the terms

and conditions

of the NOI or

Plan of

Operations,

surface

management

regulations, and

require that

reclamation was

appropriately

completed and

environmental

degradation did

not occur.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 35

MONITO

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APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

is deemed

necessary.

MBiFO 

currently has no

plans or

notices that use

leachates.

Mineral

Materials

Permits and

contracts Area-wide Site visit Permits andcontracts

Inspections are

required at least

once per year

for sales less

than 5,000

cubic yards and

twice per year

for sales larger

than 5,000

cubic yards.

Noncompliance

with the terms

and conditions

of the permit or

contract,

regulations,

poor

reclamation, or

environmental

degradation

Require

compliance

with the terms

and conditions

of the permit or

contract,

regulations, and

require that

reclamation was

appropriately

completed and

environmental

degradation did 

not occur.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix X X - 36

MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

RECREATION

Recreation

General

recreation use

Area-wide with

emphasis on

dispersed use

of undeveloped

recreational

sites(extensive

recreation

management

areas)

Area inspection

to look for

vandalism and

resource abuse

and to install

photo points

Site condition

Twice a year

(e.g.,

once in June

and

once in

October) and

photograph

annually

User conflicts,

resource

degradation, or

safety hazards

Signing,

fencing or

other

mitigation

measures

Concentrated

recreation use

and demand

Special

recreation

management

areas

and sites with

recreation

facilities

Visitor

registration,

traffic counters,

estimates, and

photo

points

Visitor days and

site

condition

Visitor

registration

boxes and

counters

checked once

monthly (at the

minimum) and

weekly

or biweekly

during heavy

use periods;

photograph

annually

Increased

visitor use per

year or

sustained use

that requires

additional or

improved

facilities

Monitor more

frequently and

signing,

fencing, or

other mitigation

measures

Area-wide

commercial and

competitive

activities

(special

recreation

permits)

Administrative

review and

site

inspection or

reviews for

permittees with

permit

stipulations

Permit

stipulations,

resource

condition, and

success of

reclamation

On site during

competitive

events,

periodic site

inspection for

commercial

operations,

Violation of

permit

stipulations,

irreparable

resource

damage, and

compromised

visitor safety

Monitor more

frequently and

signing,

fencing, or

other mitigation

measures
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MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

and

administrative

review

annually

and

recreation

experience

RENEWABLE ENERGY

Renewable

Energy

Rights-of-way

(ROWs)

Area-wide Site inspection ROW

Minimum of

once during or

for construction

within 5 years

of issuance,

then in the 20

th

year after

issuance and

every 10 years

thereafter;

before release

or collection of

a bond; before

renewal

termination or

relinquishment

acceptance; or

as required by

specific terms

and conditions

in the ROW

grant or the

plan of

development

(POD) or

regulations

Nonuse of the

ROW or

violation of

ROW grant

stipulations,

the terms of the

POD, or

regulations

Require

compliance

with ROW grant

stipulations,

POD terms, or

regulations with

possible

suspension or

termination for

noncompliance or

nonuse
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MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

TRAVEL MANAGEMENT AND OHV 

Travel

Management

and OHV 

(cont’d)

Track progress

on

implementation or

planning signing,

and mapping

Planning-areawide

Field trips and

localized public

meetings

Verify minimized

resource damage,

user conflicts, and

new user-created

roads

Annual

Effects not

anticipated in

EIS or

unacceptable

effects

Require further

mitigation or

reclamation;

consider

replanning area

(may require

an RMP

amendment)

REALTY, CADASTRAL SURVEY, AND LANDS 

Realty, 

Cadastral 

Survey, and 

Lands

ROWs Area-wide Site inspection ROW

Minimum of

once during or

for construction

within 2 years

of issuance for

Mineral

Leasing Act

reviews and

within 5 years

of issuance for

Federal Land

and Policy

Management

Act reviews,

then in the 20

th

year after

issuance and

every 10 years

thereafter;

before release

or collection

of a bond;

before renewal

termination or

Nonuse of the

ROW or

violation of

ROW grant

stipulations,

the terms of the

POD, or

regulations

Require

compliance

with ROW grant

stipulations,

POD terms, or

regulations with

possible

suspension or

termination for

noncompliance or

nonuse
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MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

relinquishment

acceptance; or

as required by

specific terms

and conditions

in the ROW

grant or the

POD or

regulations

Realty, 

Cadastral 

Survey, and 

Lands (cont’d)

2920 Land Use

Permits and

Leases

Area-wide Site inspection Lease or Permit

Minimum of

once during or

for construction

within 2 years

of issuance;

before release

or collection of

a bond; before

renewal

termination or

relinquishment

acceptance; or

as required by

specific terms

and conditions

in the lease or

permit or the

POD or

regulations

Nonuse of the

lease or permit

or violation of

lease or permit

stipulations,

the terms of the

POD, or

regulations

Require

compliance

with lease or

permit

stipulations,

POD terms, or

regulations with

possible

suspension or

termination for

noncompliance or

nonuse

Other Land Use

Authorizations

Area-wide Site inspection Use

Authorization

Minimum of

once during or

for

construction;

before release

or collection of

a bond;

Nonuse of the

authorization

or violation of

authorization

stipulations,

the terms of the

POD, or

Require

compliance

with

authorization

stipulations,

POD terms, or

regulations;
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MONITO

RING

APPENDIX

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

before renewal

termination or

relinquishment

acceptance; or

as required by

specific terms

and conditions

in the

authorization or

the POD or

regulations

regulations with possible

suspension or

termination for

noncompliance or

nonuse

Realty, Cadastral 

Survey, and 

Lands (cont’d)

Commercial film 

permits
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Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

SPECIAL DESIGNATION AREAS

ACECs

Cultural ACECs Area-wide Site inspection

Sites receiving most 

public visitation,

surrounding area

Annually

Any

noticeable

trend

indicating

increased

disturbance,

natural or

human-caused

Increase

frequency of

monitoring to

ensure ACEC

values are not

being impaired

Paleontological

ACECs

Bridger Fossil 

Area Site inspection Site, surroundingarea

Annually

Any

noticeable

trend

indicating

increased

disturbance,

natural or

human-caused

Increase

frequency of

monitoring to

ensure ACEC

values are not

being impaired

Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

ACECs

(cont’d)

Geologic and Scenic 

ACECs Area-wide Site inspection Site, surroundingarea

Annually

Any

noticeable trend

indicating

increased

disturbance,

natural or

human-caused

Increase

frequency of

monitoring to

ensure ACEC

values are not

being impaired

Research Natural 

Areas & SS plants Area-wide Site inspection Site, surrounding area

Annually 

Any

noticeable trend

indicating

increased

disturbance,

natural or

human-caused

Increase

frequency of

monitoring to

ensure ACEC

values are not

being impaired
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Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

National Historic 

Trails

Lewis & Clark 

NHT and Nez 

Perce NHT

Area wide

Area inspection

to look for

vandalism,

resource abuse,

and to install

photo points

Site condition Annually

User conflicts,

resource

degradation, or

safety hazards

Signing; site

mitigation;

more restrictive

management

(may require a

resource

management

plan [RMP]

amendment)

Pryor Mountain 

Wild Horse 

Range

PMWHR PMWHR / 

Territory

 Wild horse 

inventory

 Flight,

vehicle, and

foot review

 Range 

monitoring

 Number of 

animals

 Rangeland 

Health

Annually

Wild horse 

population and 

use patterns

 Fertility 

control

 Removal

 Water and 

habitat 

projects for 

distribution

Wilderness

Study Areas

WSAs WSAs Flight, vehicle,

and foot review

Surface

disturbance

Once per

month if the

area is

accessible

unless an

alternate

schedule is

approved by

the State

Director

Unauthorized

actions

Require

reclamation or

possible civil or

criminal action

and public

notification
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Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options

Wild and Scenic 

Rivers WSR Area-wide Vehicle and foot

review

Site, surrounding 

area

Annually

SPECIAL DESIGNATION AREAS
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Element Item Location Technique Unit of Measure

Frequency and

Duration

Remedial

Action

Trigger

Management

Options
Appendix Y: 

Emission Inventories for Alternatives
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Y. Emission Inventories for Alternatives
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Appendix Z: 

Discussion of Proper Functioning Condition
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Z. PFC – PROPER FUNCTIONING CONDITION

Z.1 WHAT IT IS - WHAT IT ISN’T

PFC is: A methodology for assessing the physical functioning of riparian and wetland 

areas. The term PFC is used to describe both the assessment process, and a 

defined, on-the-ground condition of a riparian-wetland area. In either case, PFC 

defines a minimum or starting point.

The PFC assessment provides a consistent approach for assessing the physical

functioning of riparian-wetland areas through consideration of hydrology, 

vegetation, and soil/landform attributes. The PFC assessment synthesizes 

information that is foundational to determining the overall health of a riparianwetland area.

The on-the-ground condition termed PFC refers to how well the physical

processes are functioning. PFC is a state of resiliency that will allow a riparian

wetland system to hold together during a 25 to 30 year flow event, sustaining that

system's ability to produce values related to both physical and biological 

attributes.

PFC isn’t: The sole methodology for assessing the health of the aquatic or terrestrial

components of a riparian-wetland area.

PFC isn’t: A replacement for inventory or monitoring protocols designed to yield

information on the "biology" of the plants and animals dependent on the riparianwetland area.

PFC can: Provide information on whether a riparian-wetland area is physically functioning 

in a manner which will allow the maintenance or recovery of desired values, e.g., 

fish habitat, neotropical birds, or forage, over time.

PFC isn’t: Desired (future) condition. It is a prerequisite to achieving desired condition.

PFC can’t: Provide more than strong clues as to the actual condition of habitat for plants and 

animals. Generally a riparian-wetland area in a physically nonfunctioning

condition will not provide quality habitat conditions. A riparian wetland area that 

has recovered to a proper functioning condition would either be providing quality 

habitat conditions, or would be moving in that direction if recovery is allowed to 

continue. A riparian-wetland area that is functioning-at-risk would likely lose any 

habitat that exists in a 25 to 30 year flow event.

Therefore: To obtain a complete picture of riparian-wetland area health, including the

biological side, one must have information on both physical status, provided

through the PFC assessment, and biological habitat quality. Neither will provide a 
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Appendix Z Z - 2

complete picture when analyzed in isolation. In most cases proper functioning 

condition will be a prerequisite to achieving and maintaining habitat quality.

PFC is: A useful tool for prioritizing restoration activities. By concentrating on the “at 

risk” systems, restoration activities can save many riparian-wetland areas from

degrading to a non functioning condition. Once a system is non functional the

effort, cost, and time required for recovery is dramatically increased. Restoration 

of non functional systems should be reserved for those situations where the 

riparian wetland has reached a point where recovery is possible, when efforts are 

not at the expense of "at risk" systems, or when unique opportunities exist. At the 

same time, systems that are properly functioning are not the highest priorities for 

restoration. Management of these systems should be continued to maintain PFC 

and further recovery towards desired condition.

PFC is: A useful tool for determining appropriate timing and design of riparian-wetland

restoration projects (including structural and management changes). It can 

identify situations where instream structures are either entirely inappropriate or 

premature.

PFC is: A useful tool that can be used in watershed analysis. While the methodology and

resultant data is "reach based", the ratings can be aggregated and analyzed at the

watershed scale. PFC, along with other watershed and habitat condition

information helps provide a good picture of watershed health and the possible

causal factors affecting watershed health. Use of PFC will help to identify

watershed scale problems and suggest management remedies and priorities.

PFC isn’t: Watershed analysis in and of itself, or a replacement for watershed analysis.

PFC is: A useful tool for designing implementation and effectiveness monitoring plans. 

By concentrating implementation monitoring efforts on the “no” answers, greater

efficiency of resources (people, dollars, time) can be achieved. The limited

resources of the local manager in monitoring riparian-wetland parameters can be

prioritized to those factors that are currently “out of range” or at risk of going out 

of range. The role of research may extend to validation monitoring of many of the

parameters.

PFC wasn’t: Designed to be a long term monitoring tool but it may be an appropriate part of a 

well designed monitoring program.

PFC isn’t: Designed to provide monitoring answers about attainment of desired conditions. 

However, it can be used to provide a thought process on whether a management 

strategy is likely to allow attainment of desired conditions.

PFC can: Reduce the frequency and sometimes the extent of more data and labor intensive

inventories. PFC can reduce process by concentrating efforts on the most

significant problem areas first and thereby increasing efficiency.
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Appendix Z Z - 3

PFC can’t: Eliminate the need for more intensive inventory and monitoring protocols. These 

will often be needed to validate that riparian-wetland area recovery is indeed 

moving toward or has achieved desired conditions, e.g., good quality habitat; or 

simply establish what the existing habitat quality is.

PFC is: A qualitative assessment based on quantitative science. The PFC assessment is

intended for individuals with local, on-the-ground experience in the kind of

quantitative sampling techniques that support the checklist. These quantitative

techniques are encouraged in conjunction with the PFC assessment for individual

calibration, where answers are uncertain, or where experience is limited. PFC is

also an appropriate starting point for determining and prioritizing the type and

location of quantitative inventory or monitoring necessary.

PFC isn’t: A replacement for quantitative inventory or monitoring protocols. PFC is meant to 

complement more detailed methods by providing a way to synthesize data and 

communicate results.

Z.2 PFC Checklist

The following section contains the PFC checklist as used by BLM staff and others in the field.

Immediately following are the general instructions, and then the two pages of the checklist itself.
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Appendix Z Z - 4

Z.3 General Instructions

1) The concept "Relative to Capability" applies wherever it may be inferred.

2) This checklist constitutes the Minimum National Standards required to determine Proper

Functioning Condition of lotic riparian-wetland areas.

3) As a minimum, an ID Team will use this checklist to determine the degree of function of a

riparian-wetland area.

4) Mark one box for each element. Elements are numbered for the purpose of cataloging

comments. The numbers do not declare importance.

5) For any item marked "No," the severity of the condition must be explained in the

"Remarks" section and must be a subject for discussion with the ID Team in determining

riparian-wetland functionality. Using the "Remarks" section to also explain items marked

"Yes" is encouraged but not required.

6) Based on the ID Team’s discussion, "functional rating" will be resolved and the checklist’s 

summary section will be completed.

7) Establish photo points where possible to document the site.

Standard Checklist

Name of Riparian-Wetland Area: _________________________________________________

Date: ________ Area/Segment ID: ________________________ Miles: _______________________

ID Team Observers: _________________________________________________________________

HYDROLOGIC (circle one)

Yes /No/ N/A 1) Floodplain inundated in "relatively frequent" events (1-3 years)

Yes/ No /N/A 2) Active/stable beaver dams

Yes/ No /N/A 3) Sinuosity, width/depth ratio, and gradient are in balance with the landscape setting 

(i.e., landform, geology, and bioclimatic region)

Yes/ No/ N/A 4) Riparian zone is widening or has achieved potential extent

Yes /No /N/A 5) Upland watershed not contributing to riparian degradation

VEGETATIVE (circle one)

Yes /No/ N/A 6) Diverse age-class distribution (recruitment for maintenance/recovery)

Yes/ No/ N/A 7) Diverse composition of vegetation (for maintenance/recovery)

Yes /No/ N/A 8) Species present indicate maintenance of riparian soil moisture characteristics

Yes /No/ N/A 9) Streambank vegetation is comprised of those plants or plant communities that have 

root masses capable of withstanding high streamflow events

Yes/ No/ N/A 10) Riparian plants exhibit high vigor

Yes /No /N/A 11) Adequate vegetative cover present to protect banks and dissipate energy during high 

flows

Yes/ No/ N/A 12) Plant communities in the riparian area are an adequate source of coarse and/or large 

woody debris

SOILS-EROSION DEPOSITION (circle one)

Yes/ No /N/A 13) Floodplain and channel characteristics (i.e., rocks, overflow channels, coarse and/or 

large woody debris) adequate to dissipate energy
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Yes /No /N/A 14) Point bars are revegetating

Yes /No/ N/A 15) Lateral stream movement is associated with natural sinuosity

Yes/ No /N/A 16) System is vertically stable

Yes /No /N/A 17) Stream is in balance with the water and sediment being supplied by the watershed 

(i.e., no excessive erosion or deposition)

Remarks:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

Summary Determination Functional Rating:

Proper Functioning Condition ______________________

Functional – At Risk ______________________

Nonfunctional ______________________

Unknown ______________________

Trend for Functional – At Risk:

Upward ______________________

Downward ______________________

Not Apparent ______________________

Are factors contributing to unacceptable conditions outside BLM’s control or

management?

Yes ______________________

No ______________________

If yes, what are those factors?

____ Flow regulations

____ Mining activities

____ Upstream channel conditions

____ Channelization

____ Road encroachment

____ Oil Field water discharge

____ Augmented flows

____ Other (specify) __________________________________________________
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Appendix AA AA - i

Appendix AA: 

Greater Sage-Grouse and Sagebrush Habitats: 

Monitoring, Monitoring Framework, Disturbance Caps, 

Effects Analysis Process, Mitigation, 

Mitigation Measures, Conservation Action Resources, 

Required Design Features, and Applying Lek Buffers
Appendix AA AA - ii

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Appendix AA AA - iii

Table of Contents

Appendix AA: Greater Sage-Grouse and Sagebrush Habitats:

Monitoring, Monitoring Framework, Disturbance Caps, Effects Analysis Process, Mitigation,

Mitigation Measures, Conservation Action Resources, Required Design Features, and Applying 

Lek Buffers

A. Monitoring of Sage‐grouse and Sagebrush Habitats.....................................................................5

A.1 Background...................................................................................................................................5

A.2 Sage‐Grouse Habitat Assessment Framework..............................................................................6

A.3 BLM Assessment, Inventory, and Monitoring Strategy ...............................................................6

A.4 Adaptive Management..................................................................................................................7

A.5 Implementation .............................................................................................................................7

B. The Greater Sage-Grouse Monitoring Framework .....................................................................10

B.1 INTRODUCTION ......................................................................................................................10

B.2 BROAD and MID-SCALES.......................................................................................................13

B.2.1 Implementation (Decision) Monitoring ..........................................................................14

B.2.2 Habitat Monitoring..........................................................................................................14

B.2.3 Population (Demographics) Monitoring .........................................................................35

B.2.4 Effectiveness Monitoring................................................................................................35

B.3 FINE and SITE SCALES............................................................................................................40

B.4 CONCLUSION...........................................................................................................................42

B.5 THE GREATER SAGE-GROUSE DISTURBANCE AND MONITORING SUB-TEAM 

MEMBERS .............................................................................................................................................42

C. Greater Sage-Grouse (GRSG) Disturbance Caps .......................................................................51

C.1 Disturbance Cap:.........................................................................................................................51

C.2 Density Cap:................................................................................................................................52

D. Greater Sage-Grouse Effects Analysis Process.....................................................................57

D.1 Effects Analysis Process.............................................................................................................57

D.1.1 Step 1 – Determine Proposal Adequacy..........................................................................58

D.1.2 Step 2 – Evaluate Proposal Consistency with LUP ........................................................58

D.1.3 Step 3 – Determine Proposal Consistency with Density and Disturbance Limitations ..58

D.1.4 Step 4 – Determine Projected Sage-Grouse Population and Habitat Impacts.................58

D.1.5 Step 5 –Apply Avoidance and Minimization Measures to Comply with Sage-Grouse 

Goals and Objectives...........................................................................................................................59

D.1.6 Step 6 – Apply Compensatory Mitigation or Reject / Defer Proposal............................59
Appendix AA AA - iv

E. MITIGATION.............................................................................................................................61

E.1 General........................................................................................................................................61

E.2 Developing a WAFWA Management Zone Regional Mitigation Strategy ................................61

F. MITIGATION MEASURES...............................................................................................................65

F.1 Introduction.................................................................................................................................65

F.2 GENERAL MITIGATION MEASURES and CONSERVATION ACTION RESOURCES....66

F.2.1 Best Management Practices............................................................................................66

F.3 Greater Sage-Grouse Required Design Features.........................................................................74

F.3.1 Required Design Features for Fluid Mineral Development............................................76

F.3.2 Required Design Features for Fire & Fuels ....................................................................79

F.3.3 Required Design Features for Solid Minerals.................................................................81

G. Greater Sage-Grouse: Applying Lek Buffers.............................................................................84

G.1 Buffer Distances and Evaluation of Impacts to Leks..................................................................84

G.2 For Actions in General Habitat Management Area (GHMA).....................................................84

G.3 For Actions in Priority Habitat Management Area (PHMA)......................................................85
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A. Monitoring of Sage‐grouse and Sagebrush 

Habitats

A.1 Background

On March 5, 2010 the 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 FR 13910 14014). 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. For example, one 

question asked about the number of acres of land within sage-grouse habitat that 

was meeting rangeland health standards. Field offices in more than three States 

conducted the rangeland health assessments, and reported landscape conditions at 

different scales (Sell 2009, pers. comm.). In addition, the BLM data call reported 

information at a different scale than was used for their landscape mapping 

(District or project level versus national scale) (Buckner 2009b, pers. comm.).” 

Given the degree of uncertainty associated with managing natural resources, adaptive 

management approaches that include rigorous monitoring protocols to support them are essential 

if conservation goals are to be realized (Walters 1986, Burgman et al. 2005, Stankey et al. 2005, 

Turner 2005, Lyons et al. 2008). Recent efforts to develop range‐wide policy and conservation 

measures for sage‐grouse have emphasized the importance of improving monitoring efforts on

both sage‐grouse distribution and population trends, as well as the habitat they depend on 

(Wambolt et al. 2002, Connelly et al. 2003, Stiver et al. 2006, Reese and Boyer 2007, Connelly 

et al. 2011). Connelly et al. (2003) and Stiver et al. (2010) identified the need to assess and 

monitor sage-grouse habitats based on habitat characterization that should follow habitat 

selection processes identified by Johnson (1980). These processes identify four selection orders: 

(1) rangewide, (2) physical and geographic range of populations, (3) physical and geographic 

range within home ranges, and (4) physical and geographic areas within seasonal ranges to meet 

the life requisites of sage-grouse. These four habitat selection orders each have unique habitat 

indicators that should be assessed and monitored to properly evaluate sage-grouse habitats and 

relate those habitat indicators back to sage-grouse populations.

Monitoring tied to Resource Management Plan (RMP) decisions has two parts: (1) 

implementation monitoring (implementation of decisions, waivers, modifications, etc.), and (2) 

effectiveness monitoring. Through effectiveness monitoring, BLM can answer questions about 

how our decisions and actions impact habitat. Understanding the effectiveness and validating 

results of RMPs and management decisions is an important part of BLM measuring its 

performance under the Government Performance Results Act. For example, riparian condition is 

a primary measure for RMP effectiveness (see WO IM 2010-101). Monitoring that is applicable 

for evaluating management effectiveness can also be used to address a number of other critical 

habitat variables (e.g., location, condition, habitat conversion, size of patches, number of patches, 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 6

species composition, connectivity and linkage, etc.). Ideally, monitoring attributes of sage‐

grouse habitat and sage‐grouse populations will allow linking real or potential habitat changes 

(from both natural events and management actions) to vital rates of sage‐grouse populations 

(Stiver et al. 2006, Naugle and Walker 2007). These conclusions will enable managers to 

identify indicators associated with population change across large landscapes and to ameliorate 

negative effects with appropriate conservation actions (Burgman et al. 2005, Turner 2005).

A.2 Sage‐Grouse Habitat Assessment Framework

In August 2010, the Sage‐Grouse Habitat Assessment Framework (HAF): Multi‐scale Habitat 

Assessment Tool was completed (Stiver et al. 2010). The HAF provides policy makers, resource 

managers, and natural resource specialists a comprehensive framework for sage grouse specific 

habitat assessments within sagebrush ecosystems. Assessment and monitoring of sage-grouse 

habitat is scale dependent. The HAF provides consistent indicators, metric descriptions, and 

habitat suitability characteristics for each of these scales specific to sage-grouse. It also provides 

consistent terminology so that biologists, other resource specialists, and managers from a wide 

range of agencies can address sage-grouse habitats. Monitoring inappropriate indicators for 

various scales can result in monitoring results that cannot correctly evaluate sage-grouse habitats 

and can misinform management of the effectiveness of land use plan decisions and activity level 

management actions. 

A.3 BLM Assessment, Inventory, and Monitoring Strategy

The BLM Assessment, Inventory, and Monitoring (AIM) Strategy (Toevs et al. 2011) was 

completed in 2011 (BLM IB 2012-080) and describes a vision for integrated, cross-program 

assessment, inventory, and monitoring of resources at multiple scales of management. Following 

the AIM Strategy, the BLM is modernizing its resource monitoring approach to more efficiently 

and effectively meet local, regional, and national resource information needs. The AIM Strategy 

provides a process for the BLM to collect quantitative information on the condition, trend, 

amount, location, and spatial pattern of natural resources on the public lands. Each AIMMonitoring survey, at any scale of inquiry (from the plot level to westwide deployments), uses a 

set of core indicators, standardized field methods, remote sensing, and a statistically valid study 

design to provide nationally consistent and scientifically defensible information to determine 

condition (e.g., rangeland health) and trend on public lands.

The National-scale deployment of AIM (i.e. Landscape Monitoring Framework [LMF]) 

commenced in 2011 with the collection of 1,000 plots of field-collected monitoring data across 

the Western U.S. The LMF will add approximately 1,000 new plots per year on non-forested 

public rangeland West-wide, plus an additional 1,000 plots per year in greater sage-grouse 

priority habitats. These national core data sets will be integrated with locally collected, project 

level, core data and remote sensing data to determine the condition and trend of sage-grouse 

habitats and the effectiveness of BLM management actions. This will be used to address threats 

and stressors, restore priority habitats, and maintain spatial connectivity at multiple scales of 

inquiry (from plots to landscapes and regions). Further, these multi-scale data will provide 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 7

information to determine long-term achievement of planning goals and objectives, analyze 

cumulative effects, and serve as the basis for adaptive management actions. A critical element of 

greater sage-grouse monitoring will be the production of an annual public report summarizing 

the broad scale condition and trend of priority habitats. Analysis of condition and trend reports 

will adaptively feed back into the monitoring process and will be refined as necessary. 

Additional site- or population-scale monitoring or habitat assessments, specific to greater sagegrouse needs, may be implemented when necessary through the Sage‐Grouse HAF to answer 

specific local management questions or refine adaptive management needs that are not addressed 

by the AIM-Monitoring core indicators.

A.4 Adaptive Management

When a hard trigger is hit in a Biologically Significant Unit (BSU) within a Priority Area for 

Conservation (PAC) that has multiple BSUs, including those that cross state lines, the Western 

Association of Fish and Wildlife Agencies (WAFWA) Management Zone Greater Sage-Grouse 

Conservation Team will 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 plane response. 

A.5 Implementation

The standardization of monitoring methods and implementation of a defensible monitoring 

approach (within and across jurisdictions) is vital if BLM and other conservation partners are to 

use the resulting information to guide implementation of conservation activities. Monitoring 

strategies for sage‐grouse habitat and populations must be collaborative, as habitat occurs across 

jurisdictional boundaries (52% BLM, 31% private, 8% USFS, 5% state, 4% tribal and other 

Federal; 75 FR 13910), and because state fish and wildlife agencies have primary responsibility 

for population level management of wildlife, including population monitoring. Population 

efforts therefore will continue to be conducted in partnership with state fish and wildlife 

agencies. The BLM will coordinate our multiple internal, habitat-based protocols among 

jurisdictions, as feasible, to provide large scale data sets to understand trends in sagebrush 

ecosystems.

Implementation policy directing use of the HAF, and the HAF in conjunction with AIMMonitoring in addition to other guidance in the BLM National Greater Sage-Grouse Land Use 

Planning Strategy will be necessary to provide a framework for consistent approaches to sagegrouse habitat condition and trend monitoring across planning units and jurisdictions. This 

implementation policy will be developed by BLM in cooperation with our conservation partners. 
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Appendix AA AA - 8

Literature Cited

Burgman, M.A., D.B. Lindenmayer, and J. Elith. 2005. Managing landscapes for conservation 

under uncertainty. Ecology 86:2007‐2017.

Connelly, J.W., K.P. Reese, and M.A. Schroeder. 2003. Monitoring sage‐grouse habitats and 

populations. University of Idaho, College of Natural Resources Experiment Station 

Bulletin 80 Moscow, Idaho, USA.

Connelly, J.W., S.T. Knick, C.E. Braun, W.L. Baker, E.A. Beever, T. Christiansen, K.E. 

Doherty, E.O. Garton, S.E. Hanser, D.H. Johnson, M. Leu, R.F. Miller, D.E. Naugle, S.J. 

Oyler‐McCance, D.A. Pyke, K.P. Reese, M.A. Schroeder, S.J. Stiver, B.L. Walker, and 

M.J. Wisdom. 2011. Conservation of Greater Sage‐Grouse: a synthesis of current trends 

and future management. Pp. 549–563 in S. T. Knick and J. W. Connelly (editors). Greater 

Sage‐Grouse: ecology and conservation of a landscape species and habitats. Studies in 

Avian Biology (vol. 38), University of California Press, Berkeley, CA.

Johnson, D. H. 1980. The comparison of usage and availability measurements for evaluating 

resource preference. Ecology 61:65-71.

Lyons, J.E., M.C. Runge, H.P. Laskowski, and W.L. Kendall. 2008. Monitoring in the context of 

structured decision‐making and adaptive management.

Naugle, D.E. and B.L. Walker. 2007. A collaborative vision for integrated monitoring of greater 

sage‐grouse populations. Pp. 57‐62 in K.P. Reese and R.T. Bowyer (editors). Monitoring 

populations of sage‐grouse: proceedings of a symposium at Idaho State University. 

University of Idaho College of Natural Resources Station Bulletin 88. University of 

Idaho, Moscow, ID.

Reese, K.P., and R.T. Bowyer (editors). 2007. Monitoring populations of sage‐grouse. College of 

Natural Resources Experiment Station Bulletin 88. University of Idaho, Moscow, ID.

Stankey, G.H., R.N. Clark, and B.T. Bormann. 2005. Adaptive management of natural resources: 

theory, concepts, and management institutions. Gen. Tech. Rep. PNW‐GTR‐654. 

Portland, OR: U.S. Department of Agriculture, Forest Service, Northwest Research 

Station.

Stiver, S.J., A.D. Apa, J.R. Bohne, S.D. Bunnell, P.A. Deibert, S.C. Gardner, M.A. Hilliard, 

C.W. McCarthy, and M.A. Schroeder. 2006. Greater sage‐grouse comprehensive 

strategy. Western Association of Fish and Wildlife Agencies. Unpublished Report. 

Cheyenne, Wyoming, USA.

Stiver, S.J., E.T. Rinkes, and D.E. Naugle. 2010. Sage‐Grouse Habitat Assessment Framework. , 

Bureau of Land Management Unpublished Report. U.S. Department of Interior, Bureau 

of Land Management, Idaho State Office, Boise, ID.
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Proposed Resource Management Plan and Final Environmental Impact Statement

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Toevs, G.R., J.J. Taylor, C.S. Spurrier, W.C. MacKinnon, and M.R. Bobo. 2011. Assessment, 

Inventory, and Monitoring Strategy: For integrated renewable resource management. 

U.S. Department of Interior, Bureau of Land Management, National Operations Center, 

Denver, CO.

Turner, M.G. 2005. Landscape ecology in North America: Past, present, and future. Ecology 

86:1967‐1974.

Walters, C.J. 1986. Adaptive Management of Renewable Resources. MacMillan, New York, 

New York. 374pp.

Wambolt, C.L., A.J. Harp, B.L. Welch, N. Shaw, J.W. Connelly, K.P. Reese, C.E. Braun, D.A. 

Klebenow, E.D.McArthur, J.G. Thompson, L.A.Torell, and J.A. Tanaka. 2002. Conservation 

of Greater Sage‐Grouse on Public Lands in the Western U.S.: Implications of Recovery and 

Management Policies. PACWPL Policy Paper SG‐02‐02, Caldwell, ID: Policy Analysis 

Center for Western Public Lands. 41p.
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B. The Greater Sage-Grouse Monitoring Framework

Developed by the Interagency GRSG Disturbance and Monitoring Subteam May 30, 2014

B.1 INTRODUCTION

The purpose of this U.S. Bureau of Land Management (BLM) and U.S. Forest Service (USFS) 

Greater Sage-Grouse Monitoring Framework (hereafter, monitoring framework) is to describe 

the methods to monitor habitats and evaluate the implementation and effectiveness of the BLM’s 

national planning strategy (attachment to BLM Instruction Memorandum 2012-044), the BLM 

resource management plans (RMPs), and the USFS’s land management plans (LMPs) to 

conserve the species and its habitat. The regulations for the BLM (43 CFR 1610.4-9) and the 

USFS (36 CFR part 209, published July 1, 2010) require that land use plans establish intervals 

and standards, as appropriate, for monitoring and evaluations based on the sensitivity of the 

resource to the decisions involved. Therefore, the BLM and the USFS will use the methods 

described herein to collect monitoring data and to evaluate implementation and effectiveness of 

the Greater Sage-Grouse (GRSG) (hereafter, sage-grouse) planning strategy and the conservation 

measures contained in their respective land use plans (LUPs). A monitoring plan specific to the 

Environmental Impact Statement, land use plan, or field office will be developed after the 

Record of Decision is signed. For a summary of the frequency of reporting, see Attachment A, 

An Overview of Monitoring Commitments. Adaptive management will be informed by data 

collected at any and all scales.

To ensure that the BLM and the USFS are able to make consistent assessments about sagegrouse habitats across the range of the species, this framework lays out the methodology—at 

multiple scales—for monitoring of implementation and disturbance and for evaluating the 

effectiveness of BLM and USFS actions to conserve the species and its habitat. Monitoring 

efforts will include data for measurable quantitative indicators of sagebrush availability, 

anthropogenic disturbance levels, and sagebrush conditions. Implementation monitoring results 

will allow the BLM and the USFS to evaluate the extent that decisions from their LUPs to 

conserve sage-grouse and their habitat have been implemented. State fish and wildlife agencies 

will collect population monitoring information, which will be incorporated into effectiveness 

monitoring as it is made available.

This multiscale monitoring approach is necessary, as sage-grouse are a landscape species and 

conservation is scale-dependent to the extent that conservation actions are implemented within 

seasonal habitats to benefit populations. The four orders of habitat selection (Johnson 1980) used 

in this monitoring framework are described by Connelly et al. (2003) and were applied 

specifically to the scales of sage-grouse habitat selection by Stiver et al. (in press) as first order 

(broad scale), second order (mid scale), third order (fine scale), and fourth order (site scale). 

Habitat selection and habitat use by sage-grouse occur at multiple scales and are driven by 

multiple environmental and behavioral factors. Managing and monitoring sage-grouse habitats 

are complicated by the differences in habitat selection across the range and habitat use by 

individual birds within a given season. Therefore, the tendency to look at a single indicator of 

habitat suitability or only one scale limits managers’ ability to identify the threats to sage-grouse 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 11

and to respond at the appropriate scale. For descriptions of these habitat suitability indicators for 

each scale, see “Sage-Grouse Habitat Assessment Framework: Multiscale Habitat Assessment 

Tool” (HAF; Stiver et al. 2015 in press).

Monitoring methods and indicators in this monitoring framework are derived from the current 

peer-reviewed science. Rangewide, best available datasets for broad- and mid-scale monitoring 

will be acquired. If these existing datasets are not readily available or are inadequate, but they are 

necessary to inform the indicators of sagebrush availability, anthropogenic disturbance levels, 

and sagebrush conditions, the BLM and the USFS will strive to develop datasets or obtain 

information to fill these data gaps. Datasets that are not readily available to inform the fine- and 

site-scale indicators will be developed. These data will be used to generate monitoring reports at 

the appropriate and applicable geographic scales, boundaries, and analysis units: across the range 

of sage-grouse as defined by Schroeder et al. (2004), and clipped by Western Association of Fish 

and Wildlife Agencies (WAFWA) Management Zone (MZ) (Stiver et al. 2006) boundaries and 

other areas as appropriate for size (e.g., populations based on Connelly et al. 2004). (Figure B-1, 

Map of Greater Sage-Grouse range, populations, subpopulations, and Priority Areas for 

Conservation as of 2013.) This broad- and mid-scale monitoring data and analysis will provide 

context for RMP/LMP areas; states; GRSG Priority Habitat, General Habitat, and other sagegrouse designated management areas; and Priority Areas for Conservation (PACs), as defined in 

“Greater Sage-grouse (Centrocercus urophasianus) Conservation Objectives: Final Report” 

(Conservation Objectives Team [COT] 2013). Hereafter, all of these areas will be referred to as 

“sage-grouse areas.”
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Figure B-1: Map of Greater Sage-Grouse range, populations, subpopulations, and Priority 

Areas for Conservation as of 2013.
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Proposed Resource Management Plan and Final Environmental Impact Statement

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This monitoring framework is divided into two sections. The broad- and mid-scale methods, 

described in B.2, provide a consistent approach across the range of the species to monitor 

implementation decisions and actions, mid-scale habitat attributes (e.g., sagebrush availability 

and habitat degradation), and population changes to determine the effectiveness of the planning 

strategy and management decisions. (Table B-1, Indicators for monitoring implementation of the 

national planning strategy, RMP/LMP decisions, sage-grouse habitat, and sage-grouse 

populations at the broad and mid scales.) For sage-grouse habitat at the fine and site scales, 

described in B.3, this monitoring framework describes a consistent approach (e.g., indicators and 

methods) for monitoring sage-grouse seasonal habitats. Funding, support, and dedicated 

personnel for broad- and mid-scale monitoring will be renewed annually through the normal 

budget process. For an overview of BLM and USFS multiscale monitoring commitments, see 

Attachment A.

Table B-1: Indicators for monitoring implementation of the national planning strategy, 

RMP/LMP decisions, sage-grouse habitat, and sage-grouse populations at the broad and 

mid scales.

Implementation Habitat Population 

(State Wildlife 

Agencies)

Geographic 

Scales

Availability Degradation Demographics

Broad Scale: 

From the 

range of sagegrouse to 

WAFWA 

Management 

Zones

BLM/USFS 

National Planning 

Strategy goal and 

objectives

Distribution and 

amount of 

sagebrush within 

the range

Distribution and 

amount of 

energy, mining 

and 

infrastructure 

facilities

WAFWA 

Management 

Zone 

population 

trend

Mid-scale: 

From 

WAFWA 

Management 

Zone to 

populations; 

PACs

RMP/LMP 

decisions

Mid-scale habitat 

indicators (HAF; 

Table 2 herein, 

e.g., percent of 

sagebrush per 

unit area)

Distribution and 

amount of 

energy, mining, 

and 

infrastructure 

facilities (Table 2 

herein)

Individual 

population 

trend

B.2 BROAD and MID-SCALES

First-order habitat selection, the broad scale, describes the physical or geographical range of a 

species. The first-order habitat of the sage-grouse is defined by populations of sage-grouse 

associated with sagebrush landscapes, based on Schroeder et al. 2004, and Connelly et al. 2004,

and on population or habitat surveys since 2004. An intermediate scale between the broad and 
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Appendix AA AA - 14

mid scales was delineated by WAFWA from floristic provinces within which similar 

environmental factors influence vegetation communities. This scale is referred to as the 

WAFWA Sage-Grouse Management Zones (MZs). Although no indicators are specific to this 

scale, these MZs are biologically meaningful as reporting units.

Second-order habitat selection, the mid-scale, includes sage-grouse populations and PACs. The 

second order includes at least 40 discrete populations and subpopulations (Connelly et al. 2004). 

Populations range in area from 150 to 60,000 mi2 and are nested within MZs. PACs range from 

20 to 20,400 mi2 and are nested within population areas.

Other mid-scale landscape indicators, such as patch size and number, patch connectivity, linkage 

areas, and landscape matrix and edge effects (Stiver et al. in press) will also be assessed. The 

methods used to calculate these metrics will be derived from existing literature (Knick et al. 

2011, Leu and Hanser 2011, Knick and Hanser 2011).

B.2.1 Implementation (Decision) Monitoring

Implementation monitoring is the process of tracking and documenting the implementation (or 

the progress toward implementation) of RMP/LMP decisions. The BLM and the USFS will 

monitor implementation of project-level and/or site-specific actions and authorizations, with 

their associated conditions of approval/stipulations for sage-grouse, spatially (as appropriate) 

within Priority Habitat, General Habitat, and other sage-grouse designated management areas, at 

a minimum, for the planning area. These actions and authorizations, as well as progress toward 

completing and implementing activity-level plans, will be monitored consistently across all 

planning units and will be reported to BLM and USFS headquarters annually, with a summary 

report every 5 years, for the planning area. A national-level GRSG Land Use Plan Decision 

Monitoring and Reporting Tool is being developed to describe how the BLM and the USFS will 

consistently and systematically monitor and report implementation-level activity plans and 

implementation actions for all plans within the range of sage-grouse. A description of this tool 

for collection and reporting of tabular and spatially explicit data will be included in the Record of 

Decision or approved plan. The BLM and the USFS will provide data that can be integrated with 

other conservation efforts conducted by state and federal partners.

B.2.2 Habitat Monitoring

The U.S. Fish and Wildlife Service (USFWS), in its 2010 listing decision for the sage-grouse, 

identified 18 threats contributing to the destruction, modification, or curtailment of sage-grouse 

habitat or range (75 FR 13910 2010). The BLM and the USFS will, therefore, monitor the 

relative extent of these threats that remove sagebrush, both spatially and temporally, on all lands 

within an analysis area, and will report on amount, pattern, and condition at the appropriate and 

applicable geographic scales and boundaries. These 18 threats have been aggregated into three 

broad- and mid-scale measures to account for whether the threat predominantly removes 

sagebrush or degrades habitat. (Table B-2, Relationship between the 18 threats and the three 

habitat disturbance measures for monitoring.) The three measures are:
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Measure 1: Sagebrush Availability (percent of sagebrush per unit area) 

Measure 2: Habitat Degradation (percent of human activity per unit area) 

Measure 3: Energy and Mining Density (facilities and locations per unit area)

These three habitat disturbance measures will evaluate disturbance on all lands, regardless of 

land ownership. The direct area of influence will be assessed with the goal of accounting for 

actual removal of sagebrush on which sage-grouse depend (Connelly et al. 2000) and for habitat 

degradation as a surrogate for human activity. Measure 1 (sagebrush availability) examines 

where disturbances have removed plant communities that support sagebrush (or have broadly 

removed sagebrush from the landscape). Measure 1, therefore, monitors the change in sagebrush 

availability—or, specifically, where and how much of the sagebrush community is available 

within the range of sage-grouse. The sagebrush community is defined as the ecological systems 

that have the capability of supporting sagebrush vegetation and seasonal sage-grouse habitats 

within the range of sage-grouse (B.2.2.1, Sagebrush Availability). Measure 2 (B.2.2.2, Habitat 

Degradation Monitoring) and Measure 3 (B.2.2.3., Energy and Mining Density) focus on where 

habitat degradation is occurring by using the footprint/area of direct disturbance and the number 

of facilities at the mid scale to identify the relative amount of degradation per geographic area of 

interest and in areas that have the capability of supporting sagebrush and seasonal sage-grouse 

use. Measure 2 (habitat degradation) not only quantifies footprint/area of direct disturbance but 

also establishes a surrogate for those threats most likely to have ongoing activity. Because 

energy development and mining activities are typically the most intensive activities in sagebrush 

habitat, Measure 3 (the density of active energy development, production, and mining sites) will 

help identify areas of particular concern for such factors as noise, dust, traffic, etc. that degrade 

sage-grouse habitat..
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Appendix AA AA - 16

Table B-2: Relationship between the 18 threats and the three habitat disturbance 

measures for monitoring.

Note: Data availability may preclude specific analysis of individual layers. See the detailed 

methodology for more information.

The methods to monitor disturbance found herein differ slightly from methods used in Manier et 

al. 2013, which provided a baseline environmental report (BER) of datasets of disturbance across 

jurisdictions. One difference is that, for some threats, the BER data were for federal lands only. 

In addition, threats were assessed individually, using different assumptions from those in this 

monitoring framework about how to quantify the location and magnitude of threats. The 

methodology herein builds on the BER methodology and identifies datasets and procedures to 

use the best available data across the range of the sage-grouse and to formulate a consistent 

USFWS Listing Decision Threat Sagebrush 

Availability

Habitat 

Degradation

Energy and 

Mining 

Density

Agriculture X

Urbanization X

Wildfire X

Conifer encroachment X

Treatments X

Invasive Species X

Energy (oil and gas wells and development 

facilities) X X

Energy (coal mines) X X

Energy (wind towers) X X

Energy (solar fields) X X

Energy (geothermal) X X

Mining (active locatable, leasable, and salable 

developments) X X

Infrastructure (roads) X

Infrastructure (railroads) X

Infrastructure (power lines) X

Infrastructure (communication towers) X

Infrastructure (other vertical structures) X

Other developed rights of ways X
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 17

approach to quantify impact of the threats through time. This methodology also describes an 

approach to combine the threats and calculate each of the three habitat disturbance measures.

B.2.2.1 Sagebrush Availability (Measure 1)

Sage-grouse populations have been found to be more resilient where a percentage of the 

landscape is maintained in sagebrush (Knick and Connelly 2011), which will be determined by 

sagebrush availability. Measure 1 has been divided into two submeasures to describe sagebrush 

availability on the landscape:

Measure 1a: the current amount of sagebrush on the geographic area of interest, and 

Measure 1b: the amount of sagebrush on the geographic area of interest compared with

the amount of sagebrush the landscape of interest could ecologically support.

Measure 1a (the current amount of sagebrush on the landscape) will be calculated using this 

formula: [the existing updated sagebrush layer] divided by [the geographic area of interest]. The 

appropriate geographic areas of interest for sagebrush availability include the species’ range, 

WAFWA MZs, populations, and PACs. In some cases these sage-grouse areas will need to be 

aggregated to provide an estimate of sagebrush availability with an acceptable level of accuracy.

Measure 1b (the amount of sagebrush for context within the geographic area of interest) will be 

calculated using this formula: [existing sagebrush divided by [pre-EuroAmerican settlement 

geographic extent of lands that could have supported sagebrush]. This measure will provide 

information to set the context for a given geographic area of interest during evaluations of 

monitoring data. The information could also be used to inform management options for 

restoration or mitigation and to inform effectiveness monitoring.

The sagebrush base layer for Measure 1 will be based on geospatial vegetation data adjusted for 

the threats listed in Table B-2. The following subsections of this monitoring framework describe 

the methodology for determining both the current availability of sagebrush on the landscape and 

the context of the amount of sagebrush on the landscape at the broad and mid scales.

B.2.2.1.1 Establishing the Sagebrush Base Layer

The current geographic extent of sagebrush vegetation within the rangewide distribution of sagegrouse populations will be ascertained using the most recent version of the Existing Vegetation 

Type (EVT) layer in LANDFIRE (2013). LANDFIRE EVT was selected to serve as the 

sagebrush base layer for five reasons: 1) it is the only nationally consistent vegetation layer that 

has been updated multiple times since 2001; 2) the ecological systems classification within 

LANDFIRE EVT includes multiple sagebrush type classes that, when aggregated, provide a 

more accurate (compared with individual classes) and seamless sagebrush base layer across 

jurisdictional boundaries; 3) LANDFIRE performed a rigorous accuracy assessment from which 

to derive the rangewide uncertainty of the sagebrush base layer; 4) LANDFIRE is consistently 

used in several recent analyses of sagebrush habitats (Knick et al. 2011, Leu and Hanser 2011, 

Knick and Hanser 2011); and 5) LANDFIRE EVT can be compared against the geographic 

extent of lands that are believed to have had the capability of supporting sagebrush vegetation 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 18

pre-EuroAmerican settlement [LANDFIRE Biophysical Setting (BpS)]. This fifth reason 

provides a reference point for understanding how much sagebrush currently remains in a defined 

geographic area of interest compared with how much sagebrush existed historically (Measure 

1b). Therefore, the BLM and the USFS have determined that LANDFIRE provides the best 

available data at broad and mid scales to serve as a sagebrush base layer for monitoring changes 

in the geographic extent of sagebrush. The BLM and the USFS, in addition to aggregating the 

sagebrush types into the sagebrush base layer, will aggregate the accuracy assessment reports 

from LANDFIRE to document the cumulative accuracy for the sagebrush base layer. The 

BLM—through its Assessment, Inventory, and Monitoring (AIM) program and, specifically, the 

BLM’s landscape monitoring framework (Taylor et al. 2014)—will provide field data to the 

LANDFIRE program to support continuous quality improvements of the LANDFIRE EVT layer. 

The sagebrush layer based on LANDFIRE EVT will allow for the mid-scale estimation of the 

existing percent of sagebrush across a variety of reporting units. This sagebrush base layer will 

be adjusted by changes in land cover and successful restoration for future calculations of 

sagebrush availability (Measures 1a and 1b).

This layer will also be used to determine the trend in other landscape indicators, such as patch 

size and number, patch connectivity, linkage areas, and landscape matrix and edge effects (Stiver 

et al. in press). In the future, changes in sagebrush availability, generated annually, will be 

included in the sagebrush base layer. The landscape metrics will be recalculated to examine 

changes in pattern and abundance of sagebrush at the various geographic boundaries. This 

information will be included in effectiveness monitoring (B.2.4, Effectiveness Monitoring).

Within the USFS and the BLM, forest-wide and field office–wide existing vegetation 

classification mapping and inventories are available that provide a much finer level of data than 

what is provided through LANDFIRE. Where available, these finer-scale products will be useful 

for additional and complementary mid-scale indicators and local-scale analyses (B.3, Fine and 

Site Scales). The fact that these products are not available everywhere limits their utility for 

monitoring at the broad and mid scale, where consistency of data products is necessary across 

broader geographies. 

Data Sources for Establishing and Monitoring Sagebrush Availability

There were three criteria for selecting the datasets for establishing and monitoring the change in 

sagebrush availability (Measure 1):

 Nationally consistent dataset available across the range

 Known level of confidence or accuracy in the dataset

 Continual maintenance of dataset and known update interval

Datasets meeting these criteria are listed in Table B-3, Datasets for establishing and monitoring 

changes in sagebrush availability.

LANDFIRE Existing Vegetation Type (EVT) Version 1.2

LANDFIRE EVT represents existing vegetation types on the landscape derived from remote 

sensing data. Initial mapping was conducted using imagery collected in approximately 2001. 
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Appendix AA AA - 19

Since the initial mapping there have been two update efforts: version 1.1 represents changes 

before 2008, and version 1.2 reflects changes on the landscape before 2010. Version 1.2 will be 

used as the starting point to develop the sagebrush base layer.

Sage-grouse subject matter experts determined which of the ecological systems from the 

LANDFIRE EVT to use in the sagebrush base layer by identifying the ecological systems that 

have the capability of supporting sagebrush vegetation and that could provide suitable seasonal 

habitat for the sage-grouse. (Table B-4, Ecological systems in BpS and EVT capable of 

supporting sagebrush vegetation and capable of providing suitable seasonal habitat for Greater 

Sage-Grouse.) Two additional vegetation types that are not ecological systems were added to the 

EVT: Artemisia tridentata ssp. vaseyana Shrubland Alliance and Quercus gambelii Shrubland 

Alliance. These alliances have species composition directly related to the Rocky Mountain 

Lower Montane-Foothill Shrubland ecological system and the Rocky Mountain Gambel OakMixed Montane Shrubland ecological system, both of which are ecological systems in 

LANDFIRE BpS. In LANDFIRE EVT, however, in some map zones, the Rocky Mountain 

Lower Montane-Foothill Shrubland ecological system and the Rocky Mountain Gambel OakMixed Montane Shrubland ecological system were named Artemisia tridentata ssp. vaseyana

Shrubland Alliance and Quercus gambelii Shrubland Alliance, respectively.
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Table B-3: Datasets for establishing and monitoring changes in sagebrush availability.

Dataset Source

Update 

Interval

Most Recent 

Version Year Use

BioPhysical Setting 

v1.1

LANDFIRE Static 2008 Denominator for 

sagebrush 

availability

Existing Vegetation 

Type v1.2

LANDFIRE Static 2010 Numerator for 

sagebrush 

availability

Cropland Data Layer National 

Agricultural 

Statistics Service

Annual 2012 Agricultural 

updates; removes 

existing sagebrush 

from numerator of 

sagebrush 

availability

National Land Cover 

Dataset Percent 

Imperviousness

Multi-Resolution 

Land 

Characteristics 

Consortium 

(MRLC)

5-Year 2011 (next 

available in 2016)

Urban area 

updates; removes 

existing sagebrush 

from numerator of 

sagebrush 

availability

Fire Perimeters GeoMac Annual 2013 < 1,000-acre fire 

updates; removes 

existing sagebrush 

from numerator of 

sagebrush 

availability

Burn Severity Monitoring 

Trends in Burn 

Severity

Annual 2012 (2-year delay 

in data 

availability)

> 1,000-acre fire 

updates; removes 

existing sagebrush 

from numerator of 

sagebrush 

availability except 

for unburned 

sagebrush islands

Table B-4: Ecological systems in BpS and EVT capable of supporting sagebrush vegetation 

and capable of providing suitable seasonal habitat for Greater Sage-Grouse.

Ecological System Sagebrush Vegetation that the Ecological System has

the Capability of Producing
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Appendix AA AA - 21

Colorado Plateau Mixed Low Sagebrush

Shrubland

Artemisia arbuscula ssp. longiloba

Artemisia bigelovii 

Artemisia nova 

Artemisia frigida

Artemisia tridentata ssp. wyomingensis

Columbia Plateau Low Sagebrush Steppe Artemisia arbuscula

Artemisia arbuscula ssp. longiloba 

Artemisia nova

Columbia Plateau Scabland Shrubland Artemisia rigida

Columbia Plateau Steppe and Grassland Artemisia spp.

Great Basin Xeric Mixed Sagebrush

Shrubland

Artemisia arbuscula ssp. longicaulis

Artemisia arbuscula ssp. longiloba 

Artemisia nova

Artemisia tridentata ssp. wyomingensis

Inter-Mountain Basins Big Sagebrush

Shrubland

Artemisia tridentata ssp. tridentata

Artemisia tridentata ssp. xericensis 

Artemisia tridentata ssp. vaseyana 

Artemisia tridentata ssp. wyomingensis

Inter-Mountain Basins Big Sagebrush

Steppe

Artemisia cana ssp. cana

Artemisia tridentata ssp. tridentata 

Artemisia tridentata ssp. xericensis

Artemisia tridentata ssp. wyomingensis

Artemisia tripartita ssp. tripartita 

Artemisia frigida

Inter-Mountain Basins Curl-Leaf Mountain

Mahogany Woodland and Shrubland

Artemisia tridentata ssp. vaseyana

Artemisia arbuscula 

Artemisia tridentata

Inter-Mountain Basins Mixed Salt Desert

Scrub

Artemisia tridentata ssp. wyomingensis

Artemisia spinescens

Inter-Mountain Basins Montane Sagebrush

Steppe

Artemisia tridentata ssp. vaseyana

Artemisia tridentata ssp. wyomingensis 

Artemisia nova

Artemisia arbuscula

Artemisia tridentata ssp. spiciformis

Inter-Mountain Basins Semi-Desert ShrubSteppeArtemisia tridentata

Artemisia bigelovii

Artemisia tridentata ssp. wyomingensis

Northwestern Great Plains Mixed Grass

Prairie

Artemisia cana ssp. cana

Artemisia tridentata ssp. vaseyana 

Artemisia frigida

Northwestern Great Plains Shrubland Artemisia cana ssp. cana

Artemisia tridentata ssp. tridentata 

Artemisia tridentata ssp. wyomingensis

Rocky Mountain Gambel Oak-Mixed

Montane Shrubland

Artemisia tridentata

Rocky Mountain Lower Montane-Foothill

Shrubland

Artemisia nova

Artemisia tridentata 

Artemisia frigida

Western Great Plains Floodplain Systems Artemisia cana ssp. cana

Western Great Plains Sand Prairie Artemisia cana ssp. cana
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Appendix AA AA - 22

Wyoming Basins Dwarf Sagebrush

Shrubland and Steppe

Artemisia arbuscula ssp. longiloba

Artemisia nova

Artemisia tridentata ssp. wyomingensis 

Artemisia tripartita ssp. rupicola

Artemisia tridentata ssp. vaseyana

Shrubland Alliance (EVT only)

Artemisia tridentata ssp. vaseyana

Quercus gambelii Shrubland Alliance (EVT

only)

Artemisia tridentata

Accuracy and Appropriate Use of LANDFIRE Datasets

Because of concerns over the thematic accuracy of individual classes mapped by LANDFIRE, all 

ecological systems listed in Table B-4 will be merged into one value that represents the 

sagebrush base layer. With all ecological systems aggregated, the combined accuracy of the 

sagebrush base layer (EVT) will be much greater than if all categories were treated separately.

LANDFIRE performed the original accuracy assessment of its EVT product on a map zone 

basis. There are 20 LANDFIRE map zones that cover the historical range of sage-grouse as 

defined by Schroeder (2004). (See Attachment B, User and Producer Accuracies for Aggregated 

Ecological Systems within LANDFIRE Map Zones.) The aggregated sagebrush base layer for 

monitoring had user accuracies ranging from 57.1% to 85.7% and producer accuracies ranging 

from 56.7% to 100%.

LANDFIRE EVT data are not designed to be used at a local level. In reports of the percent 

sagebrush statistic for the various reporting units (Measure 1a), the uncertainty of the percent 

sagebrush will increase as the size of the reporting unit gets smaller. LANDFIRE data should 

never be used at the 30m pixel level (900m2 resolution of raster data) for any reporting. The 

smallest geographic extent for using the data to determine percent sagebrush is at the PAC level;

for the smallest PACs, the initial percent sagebrush estimate will have greater uncertainties 

compared with the much larger PACs.

Agricultural Adjustments for the Sagebrush Base Layer

The dataset for the geographic extent of agricultural lands will come from the National 

Agricultural Statistics Service (NASS) Cropland Data Layer (CDL) 

(http://www.nass.usda.gov/research/Cropland/Release/index.htm). CDL data are generated 

annually, with estimated producer accuracies for “large area row crops ranging from the mid 

80% to mid-90%,” depending on the state 

(http://www.nass.usda.gov/research/Cropland/sarsfaqs2.htm#Section3_18.0). Specific 

information on accuracy may be found on the NASS metadata website 

(http://www.nass.usda.gov/research/Cropland/metadata/meta.htm). CDL provided the only 

dataset that matches the three criteria (nationally consistent, known level of accuracy, and 

periodically updated) for use in this monitoring framework and represents the best available 

agricultural lands mapping product.
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Appendix AA AA - 23

The CDL data contain both agricultural classes and nonagricultural classes. For this effort, and in 

the baseline environmental report (Manier et al. 2013), nonagricultural classes were removed 

from the original dataset. The excluded classes are:

Barren (65 & 131), Deciduous Forest (141), Developed/High Intensity (124), 

Developed/Low Intensity (122), Developed/Med Intensity (123), Developed/Open Space 

(121), Evergreen Forest (142), Grassland Herbaceous (171), Herbaceous Wetlands (195), 

Mixed Forest (143), Open Water (83 & 111), Other Hay/Non Alfalfa (37), Pasture/Hay 

(181), Pasture/Grass (62), Perennial Ice/Snow (112), Shrubland (64 & 152), Woody 

Wetlands (190).

The rule set for adjusting the sagebrush base layer for agricultural lands (and for updating the 

base layer for agricultural lands in the future) is that once an area is classified as agriculture in 

any year of the CDL, those pixels will remain out of the sagebrush base layer even if a new 

version of the CDL classifies that pixel as one of the nonagricultural classes listed above. The 

assumption is that even though individual pixels may be classified as a nonagricultural class in 

any given year, the pixel has not necessarily been restored to a natural sagebrush community that 

would be included in Table B-4. A further assumption is that once an area has moved into 

agricultural use, it is unlikely that the area would be restored to sagebrush. Should that occur, 

however, the method and criteria for adding pixels back into the sagebrush base layer would 

follow those found in the sagebrush restoration monitoring section of this monitoring framework 

B.2.2.1.2, Monitoring Sagebrush Availability).

Urban Adjustments for the Sagebrush Base Layer

The National Land Cover Database (NLCD) (Fry et al. 2011) includes a percent imperviousness 

dataset that was selected as the best available dataset to be used for urban adjustments and 

monitoring. These data are generated on a 5-year cycle and are specifically designed to support 

monitoring efforts. Other datasets were evaluated and lacked the spatial specificity that was 

captured in the NLCD product. Any new impervious pixel in NLCD will be removed from the 

sagebrush base layer through the monitoring process. Although the impervious surface layer 

includes a number of impervious pixels outside of urban areas, this is acceptable for the 

adjustment and monitoring for two reasons. First, an evaluation of national urban area datasets 

did not reveal a layer that could be confidently used in conjunction with the NLCD product to 

screen impervious pixels outside of urban zones. This is because unincorporated urban areas 

were not being included, thus leaving large chunks of urban pixels unaccounted for in this rule 

set. Second, experimentation with setting a threshold on the percent imperviousness layer that 

would isolate rural features proved to be unsuccessful. No combination of values could be 

identified that would result in the consistent ability to limit impervious pixels outside urban 

areas. Therefore, to ensure consistency in the monitoring estimates, all impervious pixels will be 

used.

Fire Adjustments for the Sagebrush Base Layer

Two datasets were selected for performing fire adjustments and updates: GeoMac fire 

perimeters and Monitoring Trends in Burn Severity (MTBS). An existing data standard in the 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 24

BLM requires that all fires of more than 10 acres are to be reported to GeoMac; therefore, there 

will be many small fires of less than 10 acres that will not be accounted for in the adjustment and 

monitoring attributable to fire. Using fire perimeters from GeoMac, all sagebrush pixels falling

within the perimeter of fires less than 1,000 acres will be used to adjust and monitor the 

sagebrush base layer.

For fires greater than 1,000 acres, MTBS was selected as a means to account for unburned 

sagebrush islands during the update process of the sagebrush base layer. The MTBS program 

(http://www.mtbs.gov) is an ongoing, multiyear project to map fire severity and fire perimeters 

consistently across the United States. One of the burn severity classes within MTBS is an 

unburned to low-severity class. This burn severity class will be used to represent unburned 

islands of sagebrush within the fire perimeter for the sagebrush base layer. Areas within the other 

severity classes within the fire perimeter will be removed from the base sagebrush layer during 

the update process. Not all wildfires, however, have the same impacts on the recovery of 

sagebrush habitat, depending largely on soil moisture and temperature regimes. For example, 

cooler, moister sagebrush habitat has a higher potential for recovery or, if needed, restoration 

than does the warmer, dryer sagebrush habitat. These cooler, moister areas will likely be detected 

as sagebrush in future updates to LANDFIRE.

Conifer Encroachment Adjustment for the Sagebrush Base Layer

Conifer encroachment into sagebrush vegetation reduces the spatial extent of sage-grouse habitat 

(Davies et al. 2011, Baruch-Mordo et al. 2013). Conifer species that show propensity for 

encroaching into sagebrush vegetation resulting in sage-grouse habitat loss include various 

juniper species, such as Utah juniper (Juniperus osteosperma), western juniper (Juniperus 

occidentalis), Rocky Mountain juniper (Juniperus scopulorum), pinyon species, including 

singleleaf pinyon (Pinus monophylla) and pinyon pine (Pinus edulis), ponderosa pine (Pinus 

ponderosa), lodgepole pine (Pinus contorta), and Douglas fir (Pseudotsuga menziesii) (Gruell et 

al. 1986, Grove et al. 2005, Davies et al. 2011).

A rule set for conifer encroachment was developed to adjust the sagebrush base layer. To capture 

the geographic extent of sagebrush that is likely to experience conifer encroachment, ecological 

systems within LANDFIRE EVT version 1.2 (NatureServe 2011) were identified if they had the 

capability of supporting both the conifer species (listed above) and sagebrush vegetation. Those 

ecological systems were deemed to be the plant communities with conifers most likely to 

encroach into sagebrush vegetation. (Table B-5, Ecological systems with conifers most likely to 

encroach into sagebrush vegetation.) Sagebrush vegetation was defined as including sagebrush 

species or subspecies that provide habitat for the Greater Sage-Grouse and that are included in 

the HAF. (See Attachment C, Sagebrush Species and Subspecies Included in the Selection 

Criteria for Building the EVT and BpS Layers.) An adjacency analysis was conducted to identify 

all sagebrush pixels that were directly adjacent to these conifer ecological systems, and these 

pixels were removed from the sagebrush base layer.

Table B-5: Ecological Systems with Conifers Most Likely to Encroach into Sagebrush 

Vegetation 

EVT Ecological Systems Coniferous Species and Sagebrush Vegetation 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 25

that the Ecological System has the Capability to 

Produce

Colorado Plateau Pinyon-Juniper Woodland Pinus edulis

Juniperus osteosperma

Artemisia tridentata

Artemisia arbuscula

Artemisia nova

Artemisia tridentata ssp. tridentata

Artemisia tridentata ssp. wyomingensis

Artemisia tridentata ssp. vaseyana

Artemisia bigelovii

Artemisia pygmaea

Columbia Plateau Western Juniper Woodland and 

Savanna

Juniperus occidentalis

Pinus ponderosa

Artemisia tridentata

Artemisia arbuscula

Artemisia rigida

Artemisia tridentata ssp. vaseyana

East Cascades Oak-Ponderosa Pine Forest and 

Woodland

Pinus ponderosa

Pseudotsuga menziesii

Artemisia tridentata

Artemisia nova

Great Basin Pinyon-Juniper Woodland Pinus monophylla

Juniperus osteosperma

Artemisia arbuscula

Artemisia nova

Artemisia tridentata

Artemisia tridentata ssp. vaseyana

Northern Rocky Mountain Ponderosa Pine 

Woodland and Savanna

Pinus ponderosa

Artemisia tridentata

Artemisia arbuscula

Artemisia tridentata ssp. vaseyana

Rocky Mountain Foothill Limber Pine-Juniper 

Woodland

Juniperus osteosperma

Juniperus scopulorum

Artemisia nova

Artemisia tridentata

Rocky Mountain Poor-Site Lodgepole Pine Forest Pinus contorta

Pseudotsuga menziesii

Pinus ponderosa

Artemisia tridentata

Southern Rocky Mountain Pinyon-Juniper 

Woodland

Pinus edulis

Juniperus monosperma

Artemisia bigelovii

Artemisia tridentata

Artemisia tridentata ssp. wyomingensis

Artemisia tridentata ssp.vaseyana

Southern Rocky Mountain Ponderosa Pine 

Woodland

Pinus ponderosa

Pseudotsuga menziesii

Pinus edulis

Pinus contorta
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 26

Juniperus spp.

Artemisia nova

Artemisia tridentata

Artemisia arbuscula

Artemisia tridentata ssp. vaseyana

Invasive Annual Grasses Adjustments for the Sagebrush Base Layer

There are no invasive species datasets from 2010 to the present (beyond the LANDFIRE data) 

that meet the three criteria (nationally consistent, known level of accuracy, and periodically 

updated) for use in the determination of the sagebrush base layer. For a description of how 

invasive species land cover will be incorporated in the sagebrush base layer in the future, see 

B.2.2.1.2., Monitoring Sagebrush Availability.

Sagebrush Restoration Adjustments for the Sagebrush Base Layer

There are no datasets from 2010 to the present that could provide additions to the sagebrush base 

layer from restoration treatments that meet the three criteria (nationally consistent, known level 

of accuracy, and periodically updated); therefore, no adjustments were made to the sagebrush 

base layer calculated from the LANDFIRE EVT (version 1.2) attributable to restoration activities 

since 2010. Successful restoration treatments before 2010 are assumed to have been captured in 

the LANDFIRE refresh.

B.2.2.1.2 Monitoring Sagebrush Availability

Sagebrush Availability Updates

Sagebrush availability will be updated annually by incorporating changes to the sagebrush base 

layer attributable to agriculture, urbanization, and wildfire. The monitoring schedule for the 

existing sagebrush base layer updates is as follows:

Base 2010 Existing Sagebrush Layer = [Sagebrush EVT] minus [2006 Imperviousness 

Layer] minus [2009 and 2010 CDL] minus [2009/10 GeoMac Fires that are less than 

1,000 acres] minus [2009/10 MTBS Fires that are greater than 1,000 acres, excluding 

unburned sagebrush islands within the perimeter] minus [Conifer Encroachment Layer] 

2012 Existing Sagebrush Update = [2010 Existing Sagebrush Base Layer] minus [2011 

Imperviousness Layer] minus [2011 and 2012 CDL] minus [2011/12 GeoMac Fires < 

1,000 acres] minus [2011/12 MTBS Fires that are greater than 1,000 acres, excluding 

unburned sagebrush islands within the perimeter]

Monitoring Existing Sagebrush post 2012 = [Previous Existing Sagebrush Update 

Layer] minus [Imperviousness Layer (if new data are available)] minus [Next 2 years of 

CDL] minus [Next 2 years of GeoMac Fires < 1,000 acres] minus [Next 2 years of 

MTBS Fires that are greater than 1,000 acres, excluding unburned sagebrush islands 

within the perimeter] plus [restoration/monitoring data provided by the field]

Monitoring Sagebrush Restoration

Restoration after fire, after agricultural conversion, after seedings of introduced grasses, or after 

treatments of pinyon pine and/or juniper are examples of updates to the sagebrush base layer that 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 27

can add sagebrush vegetation back into sagebrush availability in the landscape. When restoration 

has been determined to be successful through rangewide, consistent, interagency fine- and sitescale monitoring, the polygonal data will be used to add sagebrush pixels back into the broadand mid-scale sagebrush base layer. 

Measure1b: Context for Monitoring the Amount of Sagebrush in a Geographic Area of Interest

Measure 1b describes the amount of sagebrush on the landscape of interest compared with the 

amount of sagebrush the landscape of interest could ecologically support. Areas with the 

potential to support sagebrush were derived from the BpS data layer that describes sagebrush 

pre-EuroAmerican settlement (v1.2 of LANDFIRE).

The identification and spatial locations of natural plant communities (vegetation) that are 

believed to have existed on the landscape (BpS) were constructed based on an approximation of 

the historical (pre-EuroAmerican settlement) disturbance regime and how the historical 

disturbance regime operated on the current biophysical environment. BpS is composed of map 

units that are based on NatureServe (2011) terrestrial ecological systems classification.

The ecological systems within BpS used for this monitoring framework are those ecological 

systems that are capable of supporting sagebrush vegetation and of providing seasonal habitat for 

sage-grouse (Table B-4). Ecological systems selected included sagebrush species or subspecies 

that are included in the HAF and listed in Attachment C.

The BpS layer does not have an associated accuracy assessment, given the lack of any reference 

data. Visual inspection of the BpS data, however, reveals inconsistencies in the labeling of pixels 

among LANDFIRE map zones. The reason for these inconsistencies is that the rule sets used to 

map a given ecological system will vary among map zones based on different physical, 

biological, disturbance, and atmospheric regimes of the region. These variances can result in 

artificial edges in the map. Metrics will be calculated, however, at broad spatial scales using BpS 

potential vegetation type, not small groupings or individual pixels. Therefore, the magnitude of 

these observable errors in the BpS layer will be minor compared with the size of the reporting 

units. Since BpS will be used to identify broad landscape patterns of dominant vegetation, these 

inconsistencies will have only a minor impact on the percent sagebrush availability calculation. 

As with the LANDFIRE EVT, LANDFIRE BpS data are not designed to be used at a local level. 

LANDFIRE data should never be used at the 30m pixel level for reporting.

In conclusion, sagebrush availability data will be used to inform effectiveness monitoring and 

initiate adaptive management actions as necessary. The 2010 estimate of sagebrush availability 

will serve as the base year, and an updated estimate for 2012 will be reported in 2014 after all 

datasets become available. The 2012 estimate will capture changes attributable to wildfire, 

agriculture, and urban development. Subsequent updates will always include new fire and 

agricultural data and new urban data when available. Restoration data that meet the criteria for 

adding sagebrush areas back into the sagebrush base layer will be factored in as data allow. 

Given data availability, there will be a 2-year lag (approximately) between when the estimate is 

generated and when the data used for the estimate become available (e.g., the 2014 sagebrush 

availability will be included in the 2016 estimate).

Future Plans
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Geospatial data used to generate the sagebrush base layer will be available through the BLM’s 

EGIS web portal and geospatial gateway or through the authoritative data source. Legacy 

datasets will be preserved so that trends may be calculated. Additionally, accuracy assessment 

data for all source datasets will be provided on the portal either spatially, where applicable, or 

through the metadata. Accuracy assessment information was deemed vital to help users 

understand the limitation of the sagebrush estimates; it will be summarized spatially by map zone 

and will be included in the portal.

LANDFIRE plans to begin a remapping effort in 2015. This remapping has the potential to 

improve the overall quality of data products greatly, primarily through the use of higher-quality 

remote sensing datasets. Additionally, the BLM and the Multi-Resolution Land Characteristics 

Consortium (MRLC) are working to improve the accuracy of vegetation map products for broadand mid-scale analyses through the Grass/Shrub mapping effort. The Grass/Shrub mapping effort 

applies the Wyoming multiscale sagebrush habitat methodology (Homer et al. 2009) to depict 

spatially the fractional percent cover estimates for five components rangewide and West-wide. 

These five components are percent cover of sagebrush vegetation, percent bare ground, percent 

herbaceous vegetation (grass and forbs combined), annual vegetation, and percent shrubs. A 

benefit of the design of these fractional cover maps is that they facilitate monitoring “within” 

class variation (e.g., examination of declining trend in sagebrush cover for individual pixels). 

This “within” class variation can serve as one indicator of sagebrush quality that cannot be 

derived from LANDFIRE’s EVT information. The Grass/Shrub mapping effort is not a substitute 

for fine-scale monitoring but will leverage fine-scale data to support the validation of the 

mapping products. An evaluation will be conducted to determine if either dataset is of great 

enough quality to warrant replacing the existing sagebrush layers. At the earliest, this evaluation 

will occur in 2018 or 2019, depending on data availability.

B.2.2.2 Habitat Degradation Monitoring (Measure 2)

The measure of habitat degradation will be calculated by combining the footprints of threats 

identified in Table B-2. The footprint is defined as the direct area of influence of “active” energy 

and infrastructure; it is used as a surrogate for human activity. Although these analyses will try to 

summarize results at the aforementioned meaningful geographic areas of interest, some may be 

too small to report the metrics appropriately and may be combined (smaller populations, PACs 

within a population, etc.). Data sources for each threat are found in Table B-6, Geospatial data 

sources for habitat degradation. Specific assumptions (inclusion criteria for data, width/area 

assumptions for point and line features, etc.) and methodology for each threat, and the combined 

measure, are detailed below. All datasets will be updated annually to monitor broad- and midscale year-to-year changes and to calculate trends in habitat degradation to inform adaptive 

management. A 5-year summary report will be provided to the USFWS.

B.2.2.2.1 Habitat Degradation Datasets and Assumptions

Energy (oil and gas wells and development facilities) 

This dataset will compile information from three oil and gas databases: the proprietary IHS 

Enerdeq database, the BLM Automated Fluid Minerals Support System (AFMSS) database, and 

the proprietary Platts (a McGraw-Hill Financial Company) GIS Custom Data (hereafter, Platts) 

database of power plants. Point data from wells active within the last 10 years from IHS and 
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producing wells from AFMSS will be considered as a 5-acre (2.0ha) direct area of influence 

centered on the well point, as recommended by the BLM WO-300 (Minerals and Realty 

Management). Plugged and abandoned wells will be removed if the date of well abandonment 

was before the first day of the reporting year (i.e., for the 2015 reporting year, a well must have 

been plugged and abandoned by 12/31/2014 to be removed). Platts oil and gas power plants data 

(subset to operational power plants) will also be included as a 5-acre (2.0ha) direct area of 

influence. 

Additional Measure: Reclaimed Energy-related Degradation This dataset will include 

those wells that have been plugged and abandoned. This measure thereby attempts to 

measure energy-related degradation that has been reclaimed but not necessarily fully 

restored to sage-grouse habitat. This measure will establish a baseline by using wells that 

have been plugged and abandoned within the last 10 years from the IHS and AFMSS 

datasets. Time lags for lek attendance in response to infrastructure have been documented 

to be delayed 2–10 years from energy development activities (Harju et al. 2010). 

Reclamation actions may require 2 or more years from the Final Abandonment Notice. 

Sagebrush seedling establishment may take 6 or more years from the point of seeding, 

depending on such variables as annual precipitation, annual temperature, and soil type 

and depth (Pyke 2011). This 10-year period is conservative and assumes some level of 

habitat improvement 10 years after plugging. Research by Hemstrom et al. (2002), 

however, proposes an even longer period—more than 100 years—for recovery of 

sagebrush habitats, even with active restoration approaches. Direct area of influence will 

be considered 3 acres (1.2ha) (J. Perry, personal communication, February 12, 2014). 

This additional layer/measure could be used at the broad and mid scale to identify areas 

where sagebrush habitat and/or potential sagebrush habitat is likely still degraded. This 

layer/measure could also be used where further investigation at the fine or site scale 

would be warranted to: 1) quantify the level of reclamation already conducted, and 2) 

evaluate the amount of restoration still required for sagebrush habitat recovery. At a 

particular level (e.g., population, PACs), these areas and the reclamation efforts/success 

could be used to inform reclamation standards associated with future developments. Once 

these areas have transitioned from reclamation standards to meeting restoration standards, 

they can be added back into the sagebrush availability layer using the same methodology 

as described for adding restoration treatment areas lost to wildfire and agriculture 

conversion (Monitoring Sagebrush Restoration in B.2.2.1.2, Monitoring Sagebrush 

Availability). This dataset will be updated annually from the IHS dataset.

Energy (coal mines)

Currently, there is no comprehensive dataset available that identifies the footprint of active coal 

mining across all jurisdictions. Therefore, point and polygon datasets will be used each year to 

identify coal mining locations. Data sources will be identified and evaluated annually and will 

include at a minimum: BLM coal lease polygons, U.S. Energy Information Administration mine 

occurrence points, U.S. Office of Surface Mining Reclamation and Enforcement coal mining 

permit polygons (as available), and U.S. Geological Survey (USGS) Mineral Resources Data 

System mine occurrence points. These data will inform where active coal mining may be 

occurring. Additionally, coal power plant data from Platts power plants database (subset to 

operational power plants) will be included. Aerial imagery will then be used to digitize manually 
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the active coal mining and coal power plants surface disturbance in or near these known 

occurrence areas. While the date of aerial imagery varies by scale, the most current data 

available from Esri and/or Google will be used to locate (generally at 1:50,000 and below) and 

digitize (generally at 1:10,000 and below) active coal mine and power plant direct area of 

influence. Coal mine location data source and imagery date will be documented for each 

digitized coal polygon at the time of creation. Subsurface facility locations (polygon or point 

location as available) will also be collected if available, included in density calculations, and 

added to the active surface activity layer as appropriate (if an actual direct area of influence can 

be located). 

Energy (wind towers)

This dataset will be a subset of the Federal Aviation Administration (FAA) Digital Obstacles 

point file. Points where “Type_” = “WINDMILL” will be included. Direct area of influence of 

these point features will be measured by converting to a polygon dataset as a direct area of

influence of 3 acres (1.2ha) centered on each tower point. See the BLM’s “Wind Energy 

Development Programmatic Environmental Impact Statement” (BLM 2005). Additionally, Platts 

power plants database will be used for transformer stations associated with wind energy sites 

(subset to operational power plants), also with a 3-acre (1.2ha) direct area of influence.

Energy (solar energy facilities)

This dataset will include solar plants as compiled with the Platts power plants database (subset to 

operational power plants). This database includes an attribute that indicates the operational 

capacity of each solar power plant. Total capacity at the power plant was based on ratings of the 

in-service unit(s), in megawatts. Direct area of influence polygons will be centered over each 

point feature representing 7.3ac (3.0ha) per megawatt of the stated operational capacity, per the 

report of the National Renewable Energy Laboratory (NREL), “Land-Use Requirements for 

Solar Power Plants in the United States” (Ong et al. 2013).

Energy (geothermal energy facilities)

This dataset will include geothermal wells in existence or under construction as compiled with 

the IHS wells database and power plants as compiled with the Platts database (subset to 

operational power plants). Direct area of influence of these point features will be measured by 

converting to a polygon dataset of 3 acres (1.2ha) centered on each well or power plant point.

Mining (active developments; locatable, leasable, saleable)

This dataset will include active locatable mining locations as compiled with the proprietary 

InfoMine database. Aerial imagery will then be used to digitize manually the active mining 

surface disturbance in or near these known occurrence areas. While the date of aerial imagery 

varies by scale, the most current data available from Esri and/or Google will be used to locate 

(generally at 1:50,000 and below) and digitize (generally at 1:10,000 and below) active mine 

direct area of influence. Mine location data source and imagery date will be documented for each 

digitized polygon at the time of creation. Currently, there are no known compressive databases 

available for leasable or saleable mining sites beyond coal mines. Other data sources will be 

evaluated and used as they are identified or as they become available. Point data may be 

converted to polygons to represent direct area of influence unless actual surface disturbance is 

available.
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Infrastructure (roads)

This dataset will be compiled from the proprietary Esri StreetMap Premium for ArcGIS. Dataset 

features that will be used are: Interstate Highways, Major Roads, and Surface Streets to capture 

most paved and “crowned and ditched” roads while not including “two-track” and 4-wheel-drive 

routes. These minor roads, while not included in the broad- and mid-scale monitoring, may 

support a volume of traffic that can have deleterious effects on sage-grouse leks. It may be

appropriate to consider the frequency and type of use of roads in a NEPA analysis for a proposed 

project. This fine- and site-scale analysis will require more site-specific data than is identified in 

this monitoring framework. The direct area of influence for roads will be represented by 240.2ft, 

84.0ft, and 40.7ft (73.2m, 25.6m, and 12.4m) total widths centered on the line feature for 

Interstate Highways, Major Roads, and Surface Streets, respectively (Knick et al. 2011). The 

most current dataset will be used for each monitoring update. Note: This is a related but 

different dataset than what was used in BER (Manier et al. 2013). Individual BLM/USFS 

planning units may use different road layers for fine- and site-scale monitoring.

Infrastructure (railroads)

This dataset will be a compilation from the Federal Railroad Administration Rail Lines of the 

USA dataset. Non-abandoned rail lines will be used; abandoned rail lines will not be used. The 

direct are of influence for railroads will be represented by a 30.8ft (9.4m) total width (Knick et 

al. 2011) centered on the non-abandoned railroad line feature. 

Infrastructure (power lines)

This line dataset will be derived from the proprietary Platts transmission lines database. Linear 

features in the dataset attributed as “buried” will be removed from the disturbance calculation. 

Only “In Service” lines will be used; “Proposed” lines will not be used. Direct area of influence 

will be determined by the kV designation: 1–199 kV (100ft/30.5m), 200–399 kV (150ft/45.7m), 

400–699 kV (200ft/61.0m), and 700-or greater kV (250ft/76.2m) based on average right-of-way 

and structure widths, according to BLM WO-300 (Minerals and Realty Management). 

Infrastructure (communication towers)

This point dataset will be compiled from the Federal Communications Commission (FCC) 

communication towers point file; all duplicate points will be removed. It will be converted to a 

polygon dataset by using a direct area of influence of 2.5 acres (1.0ha) centered on each 

communication tower point (Knick et al. 2011). 

Infrastructure (other vertical structures)

This point dataset will be compiled from the FAA’s Digital Obstacles point file. Points where 

“Type_” = “WINDMILL” will be removed. Duplicate points from the FCC communication 

towers point file will be removed. Remaining features will be converted to a polygon dataset 

using a direct area of influence of 2.5 acres (1.0ha) centered on each vertical structure point 

(Knick et al. 2011). 

Other developed rights-of-ways

Currently, no additional data sources for other rights-of-way have been identified; roads, power 

lines, railroads, pipelines, and other known linear features are represented in the categories 
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Proposed Resource Management Plan and Final Environmental Impact Statement

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described above. The newly purchased IHS data do contain pipeline information; however, this 

database does not currently distinguish between above-ground and underground pipelines. If 

additional features representing human activities are identified, they will be added to monitoring 

reports using similar assumptions to those used with the threats described above.

B.2.2.2.2 Habitat Degradation Threat Combination and Calculation

The threats targeted for measuring human activity (Table B-2) will be converted to direct area of 

influence polygons as described for each threat above. These threat polygon layers will be 

combined and features dissolved to create one overall polygon layer representing footprints of 

active human activity in the range of sage-grouse. Individual datasets, however, will be 

preserved to indicate which types of threats may be contributing to overall habitat degradation.

This measure has been divided into three submeasures to describe habitat degradation on the 

landscape. Percentages will be calculated as follows:

1) Measure 2a. Footprint by geographic area of interest: Divide area of the active/direct 

footprint by the total area of the geographic area of interest (% disturbance in 

geographic area of interest).

2) Measure 2b. Active/direct footprint by historical sagebrush potential: Divide area of 

the active footprint that coincides with areas with historical sagebrush potential (BpS 

calculation from habitat availability) within a given geographic area of interest by the 

total area with sagebrush potential within the geographic area of interest (% 

disturbance on potential historical sagebrush in geographic area of interest).

3) Measure 2c. Active/direct footprint by current sagebrush: Divide area of the active 

footprint that coincides with areas of existing sagebrush (EVT calculation from 

habitat availability) within a given geographic area of interest by the total area that is 

current sagebrush within the geographic area of interest (% disturbance on current 

sagebrush in geographic area of interest))

B.2.2.3 Energy and Mining Density (Measure 3)

The measure of density of energy and mining will be calculated by combining the locations of 

energy and mining threats identified in Table B-2. This measure will provide an estimate of the 

intensity of human activity or the intensity of habitat degradation. The number of energy 

facilities and mining locations will be summed and divided by the area of meaningful geographic 

areas of interest to calculate density of these activities. Data sources for each threat are found in 

Table B-6. Specific assumptions (inclusion criteria for data, width/area assumptions for point and 

line features, etc.) and methodology for each threat, and the combined measure, are detailed 

below. All datasets will be updated annually to monitor broad- and mid-scale year-to-year 

changes and 5-year (or longer) trends in habitat degradation. 
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Table B-6: Geospatial Data Sources for Habitat Degradation (Measure 2)

Geospatial data sources for habitat degradation (Measure 2)

Degradation Type Subcategory Data Source Direct Area of

Influence

Area

Source

Energy (oil & gas)

Wells IHS; BLM (AFMSS) 5.0ac (2.0ha) BLM WO300

Power Plants Platts (power plants) 5.0ac (2.0ha) BLM WO300

Energy (coal)

Mines

BLM; USFS; Office of Surface

Mining Reclamation and

Enforcement; USGS Mineral

Resources Data System

Polygon area

(digitized)

Esri/

Google

Imagery

Power Plants Platts (power plants)

Polygon area

(digitized)

Esri Imagery

Energy (wind)

Wind Turbines

Federal Aviation

Administration

3.0ac (1.2ha) BLM WO300

Power Plants Platts (power plants) 3.0ac (1.2ha) BLM WO300

Energy (solar) Fields/Power

Plants Platts (power plants)

7.3ac

(3.0ha)/MW NREL

Energy

(geothermal)

Wells IHS 3.0ac (1.2ha) BLM WO300

Power Plants Platts (power plants)

Polygon area

(digitized)

Esri Imagery

Mining

Locatable

Developments InfoMine

Polygon area

(digitized)

Esri Imagery

Infrastructure

(roads)

Surface Streets

(Minor Roads) Esri StreetMap Premium 40.7ft (12.4m) USGS

Major Roads Esri StreetMap Premium 84.0ft (25.6m) USGS

Interstate

Highways

Esri StreetMap Premium

240.2ft

(73.2m)

USGS

Infrastructure

(railroads)

Active Lines

Federal Railroad

Administration

30.8ft (9.4m) USGS

Infrastructure

(power lines)

1-199kV Lines Platts(transmission lines) 100ft (30.5m)

BLM WO300 

200-399 kV Lines Platts(transmission lines) 150ft (45.7m)

BLM WO300

400-699kV Lines Platts(transmission lines) 200ft (61.0m)

BLM WO300

700+kV Lines Platts(transmission lines) 250ft (76.2m)

BLM WO300

Infrastructure

(communication) Towers

FederalCommunications

Commission 2.5ac (1.0ha) BLM WO300
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B.2.2.3.1 Energy and Mining Density Datasets and Assumptions

Energy (oil and gas wells and development facilities) 

(See Section B.2.2.2, Habitat Degradation Monitoring.) 

Energy (coal mines)

(See Section B.2.2.2, Habitat Degradation Monitoring.)

Energy (wind energy facilities)

(See Section B.2.2.2, Habitat Degradation Monitoring.)

Energy (solar energy facilities)

(See Section B.2.2.2, Habitat Degradation Monitoring.)

Energy (geothermal energy facilities)

(See Section B.2.2.2, Habitat Degradation Monitoring.) 

Mining (active developments; locatable, leasable, saleable) 

(See Section B.2.2.2, Habitat Degradation Monitoring.

B.2.2.3.2 Energy and Mining Density Threat Combination and Calculation

Datasets for energy and mining will be collected in two primary forms: point locations (e.g., 

wells) and polygon areas (e.g., surface coal mining). The following rule set will be used to 

calculate density for meaningful geographic areas of interest including standard grids and per 

polygon:

1. Point locations will be preserved; no additional points will be removed beyond the 

methodology described above. Energy facilities in close proximity (an oil well close to a 

wind tower) will be retained.

2. Polygons will not be merged, or features further dissolved. Thus, overlapping facilities 

will be retained, such that each individual threat will be a separate polygon data input for 

the density calculation.

3. The analysis unit (polygon or 640-acre section in a grid) will be the basis for counting the 

number of mining or energy facilities per unit area. Within the analysis unit, all point 

features will be summed, and any individual polygons will be counted as one (e.g., a coal 

mine will be counted as one facility within population). Where polygon features overlap 

multiple units (polygons or pixels), the facility will be counted as one in each unit where 

the polygon occurs (e.g., a polygon crossing multiple 640-acre sections would be counted 

as one in each 640-acre section for a density per 640-acre- section calculation).

4. In methodologies with different-sized units (e.g., MZs, populations, etc.) raw facility 

counts will be converted to densities by dividing the raw facility counts by the total area 

of the unit. Typically this will be measured as facilities per 640 acres.
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5. For uniform grids, raw facility counts will be reported. Typically this number will also be 

converted to facilities per 640 acres.

6. Reporting may include summaries beyond the simple ones above. Zonal statistics may be 

used to smooth smaller grids to help display and convey information about areas within 

meaningful geographic areas of interest that have high levels of energy and/or mining 

activity.

7. Additional statistics for each defined unit may also include adjusting the area to include 

only the area with the historical potential for sagebrush (BpS) or areas currently 

sagebrush (EVT).

Individual datasets and threat combination datasets for habitat degradation will be available 

through the BLM’s EGIS web portal and geospatial gateway. Legacy datasets will be preserved 

so that trends may be calculated. 

B.2.3 Population (Demographics) Monitoring

State wildlife management agencies are responsible for monitoring sage-grouse populations 

within their respective states. WAFWA will coordinate this collection of annual population data 

by state agencies. These data will be made available to the BLM according to the terms of the 

forthcoming Greater Sage-Grouse Population Monitoring Memorandum of Understanding 

(MOU) (2014) between WAFWA and the BLM. The MOU outlines a process, timeline, and 

responsibilities for regular data sharing of sage-grouse population and/or habitat information for 

the purposes of implementing sage-grouse LUPs/amendments and subsequent effectiveness 

monitoring. Population areas were refined from the “Greater Sage-grouse (Centrocercus 

urophasianus) Conservation Objectives: Final Report” (COT 2013) by individual state wildlife 

agencies to create a consistent naming nomenclature for future data analyses. These population 

data will be used for analysis at the applicable scale to supplement habitat effectiveness 

monitoring of management actions and to inform the adaptive management responses.

B.2.4 Effectiveness Monitoring

Effectiveness monitoring will provide the data needed to evaluate BLM and USFS actions 

toward reaching the objective of the national planning strategy (BLM IM 2012-044)—to 

conserve sage-grouse populations and their habitat—and the objectives for the land use planning 

area. Effectiveness monitoring methods described here will encompass multiple larger scales, 

from areas as large as the WAFWA MZ to the scale of this LUP. Effectiveness data used for 

these larger-scale evaluations will include all lands in the area of interest, regardless of surface 

ownership/management, and will help inform where finer-scale evaluations are needed, such as 

population areas smaller than an LUP or PACs within an LUP (described in Section B.3, Fine 

and Site Scales). Data will also include the trend of disturbance within these areas of interest to 

inform the need to initiate adaptive management responses as described in the land use plan.

Effectiveness monitoring reported for these larger areas provides the context to conduct 

effectiveness monitoring at finer scales. This approach also helps focus scarce resources to areas 

experiencing habitat loss, degradation, or population declines, without excluding the possibility 
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of concurrent, finer-scale evaluations as needed where habitat or population anomalies have been 

identified through some other means.

To determine the effectiveness of the sage-grouse national planning strategy, the BLM and the 

USFS will evaluate the answers to the following questions and prepare a broad- and mid-scale 

effectiveness report:

1. Sagebrush Availability and Condition:

a. What is the amount of sagebrush availability and the change in the amount 

and condition of sagebrush?

b. What is the existing amount of sagebrush on the landscape and the change in 

the amount relative to the pre-EuroAmerican historical distribution of 

sagebrush (BpS)?

c. What is the trend and condition of the indicators describing sagebrush 

characteristics important to sage-grouse?

2. Habitat Degradation and Intensity of Activities:

a. What is the amount of habitat degradation and the change in that amount?

b. What is the intensity of activities and the change in the intensity?

c. What is the amount of reclaimed energy-related degradation and the change in 

the amount?

3. What is the population estimation of sage-grouse and the change in the population 

estimation?

4. How are the BLM and the USFS contributing to changes in the amount of sagebrush?

5. How are the BLM and the USFS contributing to disturbance?

The compilation of broad- and mid-scale data (and population trends as available) into an 

effectiveness monitoring report will occur on a 5-year reporting schedule (see Attachment A), 

which may be accelerated to respond to critical emerging issues (in consultation with the 

USFWS and state wildlife agencies). In addition, effectiveness monitoring results will be used to

identify emerging issues and research needs and inform the BLM and the USFS adaptive 

management strategy (see the adaptive management section of this Environmental Impact 

Statement).

To determine the effectiveness of the sage-grouse objectives of the land use plan, the BLM and 

the USFS will evaluate the answers to the following questions and prepare a plan effectiveness 

report: 

1. Is this plan meeting the sage-grouse habitat objectives?

2. Are sage-grouse areas within the LUP meeting, or making progress toward meeting, land 

health standards, including the Special Status Species/wildlife habitat standard?

3. Is the plan meeting the disturbance objective(s) within sage-grouse areas?

4. Are the sage-grouse populations within this plan boundary and within the sage-grouse

areas increasing, stable, or declining?

The effectiveness monitoring report for this LUP will occur on a 5-year reporting schedule (see 

Attachment A) or more often if habitat or population anomalies indicate the need for an 

evaluation to facilitate adaptive management or respond to critical emerging issues. Data will be 

made available through the BLM’s EGIS web portal and the geospatial gateway. 
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Appendix AA AA - 37

Methods

At the broad and mid scales (PACs and above) the BLM and the USFS will summarize the 

vegetation, disturbance, and (when available) population data. Although the analysis will try to 

summarize results for PACs within each sage-grouse population, some populations may be too 

small to report the metrics appropriately and may need to be combined to provide an estimate 

with an acceptable level of accuracy. Otherwise, they will be flagged for more intensive 

monitoring by the appropriate landowner or agency. The BLM and the USFS will then analyze 

monitoring data to detect the trend in the amount of sagebrush; the condition of the vegetation in 

the sage-grouse areas (MacKinnon et al. 2011); the trend in the amount of disturbance; the 

change in disturbed areas owing to successful restoration; and the amount of new disturbance the 

BLM and/or the USFS has permitted. These data could be supplemented with population data 

(when available) to inform an understanding of the correlation between habitat and PACs within 

a population. This overall effectiveness evaluation must consider the lag effect response of 

populations to habitat changes (Garton et al. 2011).

Calculating Question 1, National Planning Strategy Effectiveness: The amount of sagebrush 

available in the large area of interest will use the information from Measure 1a (B.2.2.1, 

Sagebrush Availability) and calculate the change from the 2012 baseline to the end date of the 

reporting period. To calculate the change in the amount of sagebrush on the landscape to 

compare with the historical areas with potential to support sagebrush, the information from 

Measure 1b (B.2.2.1, Sagebrush Availability) will be used. To calculate the trend in the 

condition of sagebrush at the mid scale, three sources of data will be used: the BLM’s 

Grass/Shrub mapping effort (Future Plans in Section B.2.2.1, Sagebrush Availability); the results 

from the calculation of the landscape indicators, such as patch size (described below); and the 

BLM’s Landscape Monitoring Framework (LMF) and sage-grouse intensification effort (also 

described below). The LMF and sage-grouse intensification effort data are collected in a 

statistical sampling framework that allows calculation of indicator values at multiple scales.

Beyond the importance of sagebrush availability to sage-grouse, the mix of sagebrush patches on 

the landscape at the broad and mid scale provides the life requisite of space for sage-grouse 

dispersal needs (see the HAF). The configuration of sagebrush habitat patches and the land cover 

or land use between the habitat patches at the broad and mid scales also defines suitability. There 

are three significant habitat indicators that influence habitat use, dispersal, and movement across 

populations: the size and number of habitat patches, the connectivity of habitat patches (linkage 

areas), and habitat fragmentation (scope of unsuitable and non-habitats between habitat patches). 

The most appropriate commercial software to measure patch dynamics, connectivity, and 

fragmentation at the broad and mid scales will be used, along with the same data layers derived 

for sagebrush availability.

The BLM initiated the LMF in 2011 in cooperation with the Natural Resources Conservation 

Service (NRCS). The objective of the LMF effort is to provide unbiased estimates of vegetation 

and soil condition and trend using a statistically balanced sample design across BLM lands. 

Recognizing that sage-grouse populations are more resilient where the sagebrush plant 

community has certain characteristics unique to a particular life stage of sage-grouse (Knick and 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 38

Connelly 2011, Stiver et al. in press), a group of sage-grouse habitat and sagebrush plant 

community subject matter experts identified those vegetation indicators collected at LMF 

sampling points that inform sage-grouse habitat needs. The experts represented the Agricultural 

Research Service, BLM, NRCS, USFWS, WAFWA, state wildlife agencies, and academia. The 

common indicators identified include: species composition, foliar cover, height of the tallest 

sagebrush and herbaceous plant, intercanopy gap, percent of invasive species, sagebrush shape, 

and bare ground. To increase the precision of estimates of sagebrush conditions within the range 

of sage-grouse, additional plot locations in occupied sage-grouse habitat (Sage-Grouse 

Intensification) were added in 2013. The common indicators are also collected on sampling 

locations in the NRCS National Resources Inventory Rangeland Resource Assessment 

(http://www.nrcs.usda.gov/wps/portal/nrcs/detail/national/technical/nra/nri/?&cid=stelprdb10416

20).

The sage-grouse intensification baseline data will be collected over a 5-year period, and an 

annual sage-grouse intensification report will be prepared describing the status of the indicators. 

Beginning in year 6, the annual status report will be accompanied with a trend report, which will 

be available on an annual basis thereafter, contingent on continuation of the current monitoring 

budget. This information, in combination with the Grass/Shrub mapping information, the midscale habitat suitability indicator measures, and the sagebrush availability information will be 

used to answer Question 1 of the National Planning Strategy Effectiveness Report.

Calculating Question 2, National Planning Strategy Effectiveness: Evaluations of the amount of 

habitat degradation and the intensity of the activities in the area of interest will use the 

information from Measure 2 (Section B.2.2.2, Habitat Degradation Monitoring) and Measure 3 

(Section B.2.2.3, Energy and Mining Density). The field office will collect data on the amount of 

reclaimed energy-related degradation on plugged and abandoned and oil/gas well sites. The data 

are expected to demonstrate that the reclaimed sites have yet to meet the habitat restoration 

objectives for sage-grouse habitat. This information, in combination with the amount of habitat 

degradation, will be used to answer Question 2 of the National Planning Strategy Effectiveness 

Report.

Calculating Question 3, National Planning Strategy Effectiveness: The change in sage-grouse 

estimated populations will be calculated from data provided by the state wildlife agencies, when 

available. This population data (Section B.2.3., Population [Demographics] Monitoring) will be 

used to answer Question 3 of the National Planning Strategy Effectiveness Report.

Calculating Question 4, National Planning Strategy Effectiveness: The estimated contribution by 

the BLM or the USFS to the change in the amount of sagebrush in the area of interest will use 

the information from Measure 1a (Section B.2.2.1, Sagebrush Availability). This measure is 

derived from the national datasets that remove sagebrush (Table B-1). To determine the relative 

contribution of BLM and USFS management, the current Surface Management Agency 

geospatial data layer will be used to differentiate the amount of change for each management 

agency for this measure in the geographic areas of interest. This information will be used to 

answer Question 4 of the National Planning Strategy Effectiveness Report.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 39

Calculating Question 5, National Planning Strategy Effectiveness: The estimated contribution by 

the BLM or the USFS to the change in the amount of disturbance in the area of interest will use 

the information from Measure 2a (Section B.2.2.2, Monitoring Habitat Degradation) and 

Measure 3 (Section B.2.2.3, Energy and Mining Density). These measures are all derived from 

the national disturbance datasets that degrade habitat (Table B-6). To determine the relative 

contribution of BLM and USFS management, the current Surface Management Agency 

geospatial data layer will be used to differentiate the amount of change for each management 

agency for these two measures in the geographic areas of interest. This information will be used 

to answer Question 5 of the National Planning Strategy Effectiveness Report.

Answers to the five questions for determining the effectiveness of the national planning strategy 

will identify areas that appear to be meeting the objectives of the strategy and will facilitate 

identification of population areas for more detailed analysis. Conceptually, if the broad-scale 

monitoring identifies increasing sagebrush availability and improving vegetation conditions, 

decreasing disturbance, and a stable or increasing population for the area of interest, there is 

evidence that the objectives of the national planning strategy to maintain populations and their 

habitats have been met. Conversely, where information indicates that sagebrush is decreasing 

and vegetation conditions are degrading, disturbance in sage-grouse areas is increasing, and/or

populations are declining relative to the baseline, there is evidence that the objectives of the 

national planning strategy are not being achieved. Such a determination would likely result in a 

more detailed analysis and could be the basis for implementing more restrictive adaptive 

management measures.

With respect to the land use plan area, the BLM and the USFS will summarize the vegetation, 

disturbance, and population data to determine if the LUP is meeting the plan objectives. 

Effectiveness information used for these evaluations includes BLM/USFS surface management 

areas and will help inform where finer-scale evaluations are needed, such as seasonal habitats, 

corridors, or linkage areas. Data will also include the trend of disturbance within the sage-grouse 

areas, which will inform the need to initiate adaptive management responses as described in the 

land use plan.

Calculating Question 1, Land Use Plan Effectiveness: The condition of vegetation and the 

allotments meeting land health standards (as articulated in “BLM Handbook 4180-1, Rangeland 

Health Standards”) in sage-grouse areas will be used to determine the LUP’s effectiveness in 

meeting the vegetation objectives for sage-grouse habitat set forth in the plan. The field 

office/ranger district will be responsible for collecting this data. In order for this data to be 

consistent and comparable, common indicators, consistent methods, and an unbiased sampling 

framework will be implemented following the principles in the BLM’s AIM strategy (Taylor et 

al. 2014; Toevs et al. 2011; MacKinnon et al. 2011), in the BLM’s Technical Reference 

“Interpreting Indicators of Rangeland Health” (Pellant et al. 2005), and in the HAF (Stiver et al.

2015. in press) or other approved WAFWA MZ–consistent guidance to measure and monitor 

sage- grouse habitats. This information will be used to answer Question 1 of the Land Use Plan 

Effectiveness Report.

Calculating Question 2, Land Use Plan Effectiveness: Sage-grouse areas within the LUP that are 

achieving land health stands (or, if trend data are available, that are making progress toward 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 40

achieving them)—particularly the Special Status Species/wildlife habitat land health standard—

will be used to determine the LUP’s effectiveness in achieving the habitat objectives set forth in 

the plan. Field offices will follow directions in “BLM Handbook 4180-1, Rangeland Health 

Standards,” to ascertain if sage-grouse areas are achieving or making progress toward achieving 

land health standards. One of the recommended criteria for evaluating this land health standard is 

the HAF indicators.

Calculating Question 3, Land Use Plan Effectiveness: The amount of habitat disturbance in sagegrouse areas identified in this LUP will be used to determine the LUP’s effectiveness in meeting 

the plan’s disturbance objectives. National datasets can be used to calculate the amount of 

disturbance, but field office data will likely increase the accuracy of this estimate. This 

information will be used to answer Question 3 of the Land Use Plan Effectiveness Report.

Calculating Question 4, Land Use Plan Effectiveness: The change in estimated sage-grouse 

populations will be calculated from data provided by the state wildlife agencies, when available, 

and will be used to determine LUP effectiveness. This population data (Section B.2.3, Population 

[Demographics] Monitoring) will be used to answer Question 4 of the Land Use Plan 

Effectiveness Report.

Results of the effectiveness monitoring process for the LUP will be used to inform the need for 

finer-scale investigations, initiate adaptive management actions as described in the land use plan, 

initiate causation determination, and/or determine if changes to management decisions are 

warranted. The measures used at the broad and mid scales will provide a suite of characteristics 

for evaluating the effectiveness of the adaptive management strategy. 

B.3 FINE and SITE SCALES

Fine-scale (third-order) habitat selected by sage-grouse is described as the physical and 

geographic area within home ranges during breeding, summer, and winter periods. At this level, 

habitat suitability monitoring should address factors that affect sage-grouse use of, and 

movements between, seasonal use areas. The habitat monitoring at the fine and site scale (fourth 

order) should focus on indicators to describe seasonal home ranges for sage-grouse associated 

with a lek or lek group within a population or subpopulation area. Fine- and site-scale monitoring 

will inform LUP effectiveness monitoring (see Section B.2.4, Effectiveness Monitoring) and the 

hard and soft triggers identified in the LUP’s adaptive management section.

Site-scale habitat selected by sage-grouse is described as the more detailed vegetation 

characteristics of seasonal habitats. Habitat suitability characteristics include canopy cover and 

height of sagebrush and the associated understory vegetation. They also include vegetation 

associated with riparian areas, wet meadows, and other mesic habitats adjacent to sagebrush that 

may support sage-grouse habitat needs during different stages in their annual cycle.

As described in the Conclusion (B.4), details and application of monitoring at the fine and site 

scales will be described in the implementation-level monitoring plan for the land use plan. The 

need for fine- and site-scale-specific habitat monitoring will vary by area, depending on 

proposed projects, existing conditions, habitat variability, threats, and land health. Examples of 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 41

fine- and site-scale monitoring include: habitat vegetation monitoring to assess current habitat 

conditions; monitoring and evaluation of the success of projects targeting sage-grouse habitat 

enhancement and/or restoration; and habitat disturbance monitoring to provide localized 

disturbance measures to inform proposed project review and potential mitigation for project 

impacts. Monitoring plans should incorporate the principles outlined in the BLM’s AIM strategy 

(Toevs et al. 2011) and in “AIM-Monitoring: A Component of the Assessment, Inventory, and 

Monitoring Strategy” (Taylor et al. 2014). Approved monitoring methods are: 

 “BLM Core Terrestrial Indicators and Methods” (MacKinnon et al. 2011);

 The BLM’s Technical Reference “Interpreting Indicators of Rangeland Health” (Pellant 

et al. 2005); and,

 “Sage-Grouse Habitat Assessment Framework: Multiscale Assessment Tool” (Stiver et 

al. 2015 in press).

Other state-specific disturbance tracking models include: the BLM’s Wyoming Density and 

Disturbance Calculation Tool (http://ddct.wygisc.org/) and the BLM’s White River Data 

Management System in development with the USGS. Population monitoring data (in cooperation 

with state wildlife agencies) should be included during evaluation of the effectiveness of actions 

taken at the fine and site scales.

Fine- and site-scale sage-grouse habitat suitability indicators for seasonal habitats are identified 

in the HAF. The HAF has incorporated the Connelly et al. (2000) sage-grouse guidelines as well 

as many of the core indicators in the AIM strategy (Toevs et al. 2011). There may be a need to 

develop adjustments to height and cover or other site suitability values described in the HAF; 

any such adjustments should be ecologically defensible. To foster consistency, however, 

adjustments to site suitability values at the local scale should be avoided unless there is strong, 

scientific justification for making those adjustments. That justification should be provided. 

WAFWA MZ adjustments must be supported by regional plant productivity and habitat data for 

the floristic province. If adjustments are made to the site-scale indicators, they must be made 

using data from the appropriate seasonal habitat designation (breeding/nesting, brood-rearing, 

winter) collected from sage-grouse studies found in the relevant area and peer-reviewed by the 

appropriate wildlife management agency(ies) and researchers.

When conducting land heath assessments, the BLM should follow, at a minimum, “Interpreting 

Indicators of Rangeland Health” (Pellant et. al. 2005) and the “BLM Core Terrestrial Indicators 

and Methods” (MacKinnon et al. 2011). For assessments being conducted in sage-grouse 

designated management areas, the BLM should collect additional data to inform the HAF 

indicators that have not been collected using the above methods. Implementation of the 

principles outlined in the AIM strategy will allow the data to be used to generate unbiased 

estimates of condition across the area of interest; facilitate consistent data collection and rollup 

analysis among management units; help provide consistent data to inform the classification and 

interpretation of imagery; and provide condition and trend of the indicators describing sagebrush 

characteristics important to sage-grouse habitat (see Section B.2.4, Effectiveness Monitoring).
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 42

B.4 CONCLUSION

This Greater Sage-Grouse Monitoring Framework was developed for all of the Final 

Environmental Impact Statements involved in the sage-grouse planning effort. As such, it 

describes the monitoring activities at the broad and mid scales and provides a guide for the BLM 

and the USFS to collaborate with partners/other agencies to develop the land use plan- specific 

monitoring plan.

B.5 THE GREATER SAGE-GROUSE DISTURBANCE AND 

MONITORING SUB-TEAM MEMBERS

Gordon Toevs (BLM -WO) 

Duane Dippon (BLM-WO) 

Frank Quamen (BLM-NOC) 

David Wood (BLM-NOC) 

Vicki Herren (BLM-NOC) 

Matt Bobo (BLM-NOC)

Michael “Sherm” Karl (BLM-NOC) 

Emily Kachergis (BLM-NOC) 

Doug Havlina (BLM-NIFC)

Mike Pellant (BLM-GBRI) 

John Carlson (BLM-MT) 

Jenny Morton (BLM -WY)

Robin Sell (BLM-CO) 

Paul Makela (BLM-ID) 

Renee Chi (BLM-UT) 

Sandra Brewer (BLM-NV)

Glenn Frederick (BLM-OR) 

Robert Skorkowsky (USFS) 

Dalinda Damm (USFS) 

Rob Mickelsen (USFS)

Tim Love (USFS) 

Pam Bode (USFS)

Lief Wiechman (USFWS) 

Lara Juliusson (USFWS)
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Appendix AA AA - 43

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Attachment A: AN OVERVIEW OF MONITORING COMMITMENTS

Broad and Mid-scales

Fine & Site 

Implementation Vegetation Disturbance Population Effectiveness Scales

How will the 

data be used?

Track and document 

implementation of 

land use plan 

decisions and 

inform adaptive 

management

Track changes in 

land cover 

(sagebrush) and 

inform adaptive 

management

Track changes in

disturbance 

(threats) to sagegrouse habitat

and inform 

adaptive 

management

Track trends in 

sage-grouse 

populations 

(and/or leks; as 

determined by 

state wildlife 

agencies) and 

inform adaptive 

management

Characterize the 

relationship 

among 

disturbance, 

implementation 

actions, and 

sagebrush 

metrics and 

inform adaptive 

management

Measure 

seasonal habitat, 

connectivity at 

the fine scale, 

calculate 

disturbance, and 

inform adaptive 

management

Who is 

collecting the 

data?

BLM FO and USFS 

Forest 

NOC and NIFC National data 

sets (NOC), 

BLM FOs and 

USFS Forests as 

applicable

State wildlife 

agencies through 

WAFWA

Comes from 

other broad- and 

mid-scale 

monitoring types, 

analyzed by the 

NOC

BLM FO and 

SO, USFS 

Forests and RO 

(with partners) 

How often are 

the data 

collected,

reported, and 

made available 

to USFWS?

Collected and 

reported annually; 

summary report 

every 5 years

Updated and 

changes reported 

annually; 

summary report 

every 5 years

Collected and

changes reported 

annually; 

summary report 

every 5 years

State data 

reported annually 

per WAFWA 

MOU; summary 

report every 5 

years

Collected and 

reported every 5 

years (coincident 

with LUP 

evaluations)

Collection and 

trend analysis 

ongoing, 

reported every 5 

years or as 

needed to inform 

adaptive 

management

What is the 

spatial scale?

Summarized by 

LUP with flexibility 

for reporting by 

other units

Summarized by 

PACs (size 

dependent) with 

flexibility for 

reporting by 

other units

Summarized by 

PACs (size 

dependent) with 

flexibility for 

reporting by 

other units

Summarized by 

PACs (size 

dependent) with 

flexibility for 

reporting by 

other units

Summarized by 

MZ and LUP 

with flexibility 

for reporting by 

other units (e.g., 

PAC)

Variable (e.g., 

projects and 

seasonal 

habitats)

What are the 

potential 

personnel and 

budget 

impacts?

Additional capacity 

or re-prioritization 

of ongoing 

monitoring work 

and budget 

realignment

At a minimum, 

current skills 

and capacity 

must be 

maintained; data 

management 

costs are TBD

At a minimum, 

current skills and 

capacity must be 

maintained; data 

management and 

data layer 

purchase cost are 

TBD 

No additional 

personnel or 

budget impacts 

for BLM or 

USFS

Additional 

capacity or reprioritization of 

ongoing 

monitoring work 

and budget 

realignment

Additional 

capacity or reprioritization of 

ongoing 

monitoring work 

and budget 

realignment

Who has 

primary and 

secondary 

responsibilities 

for reporting?

1) BLM FO & 

SO; USFS 

Forest & RO

2) BLM & FS 

Planning

1) NOC

2) WO

1) NOC

2) BLM SO, 

USFS RO & 

appropriate 

programs

1) WAFWA & 

state wildlife 

agencies

2) BLM SO, 

USFS RO, 

NOC

1) Broad and 

mid-scale at 

the NOC, 

LUP at BLM 

SO, USFS 

RO

1) BLM FO & 

USFS 

Forests

2) BLM SO & 

FS RO

What new 

processes/ tools 

will be needed?

National 

implementation data 

sets and analysis 

tools 

Updates to 

national land 

cover data 

Data standards 

and roll-up 

methods for 

these data

Standards in 

population 

monitoring 

(WAFWA)

Reporting 

methodologies

Data standards 

data storage; and 

reporting

FO (field office); NIFC (National Interagency Fire Center); NOC (National Operations Center); RO (regional office); SO (state 

office); TBD (to be determined); WO (Washington Office)
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 48

Attachment B - User and Producer Accuracies for Aggregated Ecological Systems within 

LANDFIRE Map Zones

LANDFIRE Map Zone Name User 

Accuracy

Producer 

Accuracy

% of Map Zone

within Historical 

Schroeder

Wyoming Basin 76.9% 90.9% 98.5%

Snake River Plain 68.8% 85.2% 98.4%

Missouri River Plateau 57.7% 100.0% 91.3%

Grand Coulee Basin of the Columbia Plateau 80.0% 80.0% 89.3%

Wyoming Highlands 75.3% 85.9% 88.1%

Western Great Basin 69.3% 75.4% 72.9%

Blue Mountain Region of the Columbia Plateau 85.7% 88.7% 72.7%

Eastern Great Basin 62.7% 80.0% 62.8%

Northwestern Great Plains 76.5% 92.9% 46.3%

Northern Rocky Mountains 72.5% 89.2% 42.5%

Utah High Plateaus 81.8% 78.3% 41.5%

Colorado Plateau 65.3% 76.2% 28.8%

Middle Rocky Mountains 78.6% 73.3% 26.4%

Cascade Mountain Range 57.1% 88.9% 17.3%

Sierra Nevada Mountain Range 0.0% 0.0% 12.3%

Northwestern Rocky Mountains 66.7% 60.0% 7.3%

Southern Rocky Mountains 58.6% 56.7% 7.0%

Northern Cascades 75.0% 75.0% 2.6%

Mogollon Rim 66.7% 100.0% 1.7%

Death Valley Basin 0.0% 0.0% 1.2%

There are two anomalous map zones with 0% user and producer accuracies, attributable to no 

available reference data for the ecological systems of interest.
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User accuracy is a map-based accuracy that is computed by looking at the reference data for a 

class and determining the percentage of correct predictions for these samples. For example, if I 

select any sagebrush pixel on the classified map, what is the probability that I'll be standing in a 

sagebrush stand when I visit that pixel location in the field? Commission Error equates to 

including a pixel in a class when it should have been excluded (i.e., commission error = 1 –

user’s accuracy).

Producer accuracy is a reference-based accuracy that is computed by looking at the predictions 

produced for a class and determining the percentage of correct predictions. In other words, if I 

know that a particular area is sagebrush (I've been out on the ground to check), what is the 

probability that the digital map will correctly identify that pixel as sagebrush? Omission Error

equates to excluding a pixel that should have been included in the class (i.e., omission error = 1 –

producer’s accuracy).
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Proposed Resource Management Plan and Final Environmental Impact Statement

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Attachment C. Sagebrush Species and Subspecies Included in the Selection Criteria for 

Building the EVT and BpS Layers

 Artemisia arbuscula subspecies longicaulis

 Artemisia arbuscula subspecies longiloba

 Artemisia bigelovii

 Artemisia nova

 Artemisia papposa

 Artemisia pygmaea

 Artemisia rigida

 Artemisia spinescens

 Artemisia tripartita subspecies rupicola

 Artemisia tripartita subspecies tripartita

 Tanacetum nuttallii

 Artemisia cana subspecies bolanderi

 Artemisia cana subspecies cana

 Artemisia cana subspecies viscidula

 Artemisia tridentata subspecies wyomingensis

 Artemisia tridentata subspecies tridentata

 Artemisia tridentata subspecies vaseyana

 Artemisia tridentata subspecies spiciformis

 Artemisia tridentata subspecies xericensis

 Artemisia tridentata variety pauciflora

 Artemisia frigida

 Artemisia pedatifida 
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Proposed Resource Management Plan and Final Environmental Impact Statement

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C. Greater Sage-Grouse (GRSG) Disturbance Caps

In the USFWS’s 2010 listing decision for sage-grouse, the USFWS identified 18 threats 

contributing to the destruction, modification, or curtailment of the sage-grouse’s habitat or range 

(75 FR 13910 2010. The 18 threats have been aggregated into three measures: 

Sagebrush Availability (percent of sagebrush per unit area)

Habitat Degradation (percent of human activity per unit area) 

Density of Energy and Mining (facilities and locations per unit area)

Habitat Degradation and Density of Energy and Mining will be evaluated under the Disturbance 

Cap and Density Cap respectively and are further described in this appendix. The three 

measures, in conjunction with other information, will be considered during the NEPA process for 

projects authorized or undertaken by the BLM. 

C.1 Disturbance Cap:

This land use plan has incorporated a 3% anthropogenic disturbance cap within Greater SageGrouse (GRSG) Priority Habitat Management Areas (PHMAs) and the subsequent land use 

planning actions if the cap is met: 

If the 3% anthropogenic disturbance cap is exceeded on lands (regardless of land 

ownership) within GRSG Priority Habitat Management Areas (PHMA) in any given 

Biologically Significant Unit (BSU), then no further discrete anthropogenic disturbances 

(subject to applicable laws and regulations, such as the 1872 hard rock mining law, valid 

existing rights, etc.) will be permitted by BLM within GRSG PHMAs in any given BSU 

until the disturbance has been reduced to less than the cap.

If the 3% disturbance cap is exceeded on all lands (regardless of land ownership) or if 

anthropogenic disturbance and habitat loss associated with conversion to agricultural 

tillage or fire exceed 5% within a proposed project analysis area in a Priority Habitat 

Management Areas, then no further anthropogenic disturbance will 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.). If the BLM determines that the State of 

Montana’s GRSG Habitat Conservation Program contains comparable components to 

those found in the State of Wyoming’s Density and Disturbance model (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 will be converted to a 5% cap. 

The disturbance cap applies to the PHMA within both the Biologically Significant Units (BSU) 

and at the project authorization scale. For the BSUs, west-wide habitat degradation (disturbance) 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 52

data layers (Table C-1) will be used at a minimum to calculate the amount of disturbance and to 

determine if the disturbance cap has been exceeded as the land use plans (LUP) are being 

implemented. Locally collected disturbance data will be used to determine if the disturbance cap 

has been exceeded for project authorizations, and may also be used to calculate the amount of 

disturbance in the BSUs. 

Although locatable mine sites are included in the degradation calculation, mining activities under 

the 1872 mining law may not be subject to the 3% disturbance cap. Details about locatable 

mining activities will be fully disclosed and analyzed in the NEPA process to assess impacts to 

sage-grouse and their habitat as well as to BLM goals and objectives, and other BLM programs 

and activities.

Formulas for calculations of the amount of disturbance in the PHMA in a BSU and or in a 

proposed project area are as follows:

 For the BSUs: 

% Degradation Disturbance = (combined acres of the 12 degradation threats1) ÷ 

(acres of all lands within the PHMAs in a BSU) x 100. 

 For the Project Analysis Area: 

% Degradation Disturbance = (combined acres of the 12 degradation threats1 

plus the 7 site scale threats2 and acres of habitat loss1) ÷ (acres of all lands within 

the PHMA in the project analysis area) x 100. 

1 see Table C-1. 2 see Table C-2

The denominator in the disturbance calculation formula consists of all acres of lands classified as 

PHMA within the analysis area (BSU or project area). Areas that are not sage-grouse seasonal 

habitats, or are not currently supporting sagebrush cover (e.g., due to wildfire), are not excluded 

from the acres of PHMA in the denominator of the formula. Information regarding sage-grouse 

seasonal habitats, sagebrush availability, and areas with the potential to support sage-grouse 

populations will be considered along with other local conditions that may affect sage-grouse 

during the analysis of the proposed project area. 

C.2 Density Cap:

This land use plan has also incorporated a cap on the density of energy and mining facilities at an 

average of one facility per 640 acres in the PHMA in a project authorization area. If the 

disturbance density in the PHMA in a proposed project area is on average less than 1 facility per 

640 acres, the analysis will proceed through the NEPA process incorporating mitigation 

measures into an alternative. If the disturbance density is greater than an average of 1 facility per 

640 acres, the proposed project will either be deferred until the density of energy and mining 

facilities is less than the cap or co-located it into existing disturbed area (subject to applicable 

laws and regulations, such as the 1872 Mining Law, valid existing rights, etc.). Facilities 

included in the density calculation (Table 3) are:

 Energy (oil and gas wells and development facilities)

 Energy (coal mines)
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Proposed Resource Management Plan and Final Environmental Impact Statement

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 Energy (wind towers)

 Energy (solar fields)

 Energy (geothermal)

 Mining (active locatable, leasable, and saleable developments)

Project Analysis Area Method for Permitting Surface Disturbance Activities:

 Determine potentially affected occupied leks by placing a four mile boundary around 

the proposed area of physical disturbance related to the project. All occupied leks 

located within the four mile project boundary and within PHMA will be considered 

affected by the project. 

 Next, place a four mile boundary around each of the affected occupied leks. 

 The PHMA within the four mile lek boundary and the four mile project boundary 

creates the project analysis area for each individual project. If there are no occupied 

leks within the four-mile project boundary, the project analysis area will be that 

portion of the four-mile project boundary within the PHMA. 

 Digitize all existing anthropogenic disturbances identified in Table C-1, the 7 

additional features that are considered threats to sage-grouse (Table C-2), and areas of 

sagebrush loss. Using 1 meter resolution NAIP imagery is recommended. Use 

existing local data if available. 

 Calculate percent existing disturbance using the formula above. If existing 

disturbance is less than 3% anthropogenic disturbance or 5% total disturbance, 

proceed to next step. If existing disturbance is greater than 3% anthropogenic 

disturbance or 5% total disturbance, defer the project.

 Add proposed project disturbance footprint area and recalculate the percent 

disturbance. If disturbance is less than 3% anthropogenic disturbance or 5% total 

disturbance, proceed to next step. If disturbance is greater than 3% anthropogenic 

disturbance or 5% total disturbance, defer project.

 Calculate the disturbance density of energy and mining facilities (listed above). If the 

disturbance density is less than 1 facility per 640 acres, averaged across project 

analysis area, proceed to the NEPA analysis incorporating mitigation measures into 

an alternative. If the disturbance density is greater than 1 facility per 640 acres, 

averaged across the project analysis area, either defer the proposed project or colocate it into existing disturbed area.

 If a project that would exceed the degradation cap or density cap cannot be deferred 

due to valid existing rights or other existing laws and regulations, fully disclose the 

local and regional impacts of the proposed action in the associated NEPA.
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Proposed Resource Management Plan and Final Environmental Impact Statement

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Table C-1: Anthropogenic disturbance types for disturbance calculations. Data sources are 

described for the west-wide habitat degradation estimates (Table copied from the GRSG 

Monitoring Framework)

Degradation 

Type Subcategory Data Source Direct Area of Influence

Area 

Source

Energy (oil & 

gas)

Wells IHS; BLM (AFMSS) 5.0ac (2.0ha) BLM WO300

Power Plants Platts (power plants) 5.0ac (2.0ha) BLM WO300

Energy (coal) 

Mines BLM; USFS; Office of 

Surface Mining Reclamation 

and Enforcement; USGS 

Mineral Resources Data 

System

Polygon area 

(digitized)

Esri/

Google 

Imagery

Power Plants Platts (power plants) Polygon area 

(digitized)

Esri 

Imagery

Energy (wind)

Wind Turbines Federal Aviation 

Administration

3.0ac (1.2ha) BLM WO300

Power Plants Platts (power plants) 3.0ac (1.2ha) BLM WO300

Energy (solar) Fields/Power 

Plants

Platts (power plants) 7.3ac 

(3.0ha)/MW 

NREL

Energy 

(geothermal)

Wells IHS 3.0ac (1.2ha) BLM WO300

Power Plants Platts (power plants) Polygon area 

(digitized)

Esri 

Imagery

Mining Locatable 

Developments

InfoMine Polygon area 

(digitized)

Esri 

Imagery

Infrastructure 

(roads)

Surface Streets 

(Minor Roads)

Esri StreetMap Premium 40.7ft 

(12.4m) 

USGS

Major Roads Esri StreetMap Premium 84.0ft 

(25.6m) 

USGS

Interstate 

Highways

Esri StreetMap Premium 240.2ft 

(73.2m) 

USGS

Infrastructure 

(railroads)

Active Lines Federal Railroad 

Administration

30.8ft (9.4m) USGS

Infrastructure 

(power lines)

1-199kV Lines Platts (transmission lines) 100ft (30.5m) BLM WO300

200-399 kV 

Lines

Platts (transmission lines) 150ft (45.7m) BLM WO300

400-699kV Lines Platts (transmission lines) 200ft (61.0m) BLM WO300

700+kV Lines Platts (transmission lines) 250ft (76.2m) BLM WO300

Infrastructure 

(communication) 

Towers Federal Communications 

Commission

2.5ac (1.0ha) BLM WO300
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Proposed Resource Management Plan and Final Environmental Impact Statement

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Table C-2: The seven site scale features considered threats to sage-grouse included in the 

disturbance calculation for project authorizations. 

1. Coalbed Methane Ponds

2. Meteorological Towers

3. Nuclear Energy Facilities

4. Airport Facilities and Infrastructure

5. Military Range Facilities & Infrastructure

6. Hydroelectric Plants

7. Recreation Areas Facilities and Infrastructure

Definitions:

1. Coalbed Methane and other Energy-related Retention Ponds – The footprint boundary will 

follow the fenceline and includes the area within the fenceline surrounding the impoundment. If the 

pond is not fenced, the impoundment itself is the footprint. Other infrastructure associated with the 

containment ponds (roads, well pads, etc.) will be captured in other disturbance categories.

2. Meteorological Towers – This feature includes long-term weather monitoring and temporary 

meteorological towers associated with short-term wind testing. The footprint boundary includes the area 

underneath the guy wires. 

3. Nuclear Energy Facilities – The footprint boundary includes visible facilities (fence, road, 

etc.) and undisturbed areas within the facility’s perimeter.

4. Airport Facilities and Infrastructure (public and private) –The footprint boundary of will 

follow the boundary of the airport or heliport and includes mowed areas, parking lots, hangers, 

taxiways, driveways, terminals, maintenance facilities, beacons and related features. Indicators of the 

boundary, such as distinct land cover changes, fences and perimeter roads, will be used to encompass 

the entire airport or heliport.

5. Military Range Facilities & Infrastructure – The footprint boundary will follow the outer 

edge of the disturbed areas around buildings and includes undisturbed areas within the facility’s 

perimeter. 

6. Hydroelectric Plants – The footprint boundary includes visible facilities (fence, road, etc.) 

and undisturbed areas within the facility’s perimeter.

7. Recreation Areas & Facilities – This feature includes all sites/facilities larger than 0.25 acres 

in size. The footprint boundary will include any undisturbed areas within the site/facility.
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Proposed Resource Management Plan and Final Environmental Impact Statement

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Table C-3: Relationship between the 18 threats and the three habitat disturbance 

measures for monitoring and disturbance calculations.

USFWS Listing Decision Threat

Sagebrush 

Availability

Habitat 

Degradation 

Energy and 

Mining 

Density

Agriculture X

Urbanization X

Wildfire X

Conifer encroachment X

Treatments X

Invasive Species X

Energy (oil and gas wells and development 

facilities) X X

Energy (coal mines) X X

Energy (wind towers) X X

Energy (solar fields) X X

Energy (geothermal) X X

Mining (active locatable, leasable, and saleable 

developments) X X

Infrastructure (roads) X

Infrastructure (railroads) X

Infrastructure (power lines) X

Infrastructure (communication towers) X

Infrastructure (other vertical structures) X

Other developed rights-of-way X
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Proposed Resource Management Plan and Final Environmental Impact Statement

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D. Greater Sage-Grouse Effects Analysis Process

D.1 Effects Analysis Process 

The BLM/USFS will ensure that any activities or projects in greater sage-grouse habitats would: 

1) only occur in compliance with [insert plan name] greater sage-grouse goals and objectives for 

priority and general management areas; and 2) maintain neutral or positive greater sage-grouse 

population trends and habitat by avoiding, minimizing, and offsetting unavoidable impacts to 

assure a conservation gain at the scale of this land use plan and within greater sage-grouse 

population areas, State boundaries, and WAFWA Management Zones through the application of 

mitigation for implementation-level decisions. The mitigation process will 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, while also 

following Secretary of the Interior Order 3330 and consulting BLM, FWS and other current and 

appropriate mitigation guidance . If it is determined that residual impacts to greater sage-grouse 

from implementation-level actions would remain after applying avoidance and minimization 

measures to the extent possible, then compensatory mitigation projects will be used to offset 

residual impacts, or the project may be deferred or denied if necessary to achieve the goals and 

objectives for priority and general management areas in the [insert plan name]. 

To ensure that impacts from activities proposed in sage-grouse priority and general management 

areas (PHMA and GHMA) are appropriately mitigated, the BLM will apply mitigation measures 

and conservation actions and potentially modify the location, design, construction, and/or 

operation of proposed land uses or activities to comply with statutory requirements for 

environmental protection. The mitigation measures and conservation actions [Appendix AA, 

section F] for proposed projects or activities in these areas will be identified as part of the 

National Environmental Policy Act (NEPA) environmental review process, through 

interdisciplinary analysis involving resource specialists, project proponents, government entities, 

landowners or other Surface Management Agencies. Those measures selected for 

implementation will be identified in the Record of Decision (ROD) or Decision Record (DR) for 

those authorizations and will inform a potential lessee, permittee, or operator of the requirements 

that must be met when using BLM-administered public lands and minerals to mitigate, per the 

mitigation hierarchy referenced above, impacts from the activity or project such that sage-grouse 

goals and objectives are met. Because these actions create a clear obligation for the BLM to 

ensure any proposed mitigation action 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).

To achieve the goals and objectives for PHMA and GHMA in the [insert plan name], the BLM 

will assess all proposed land uses or activities such as road, pipeline, communication tower, or 

powerline construction, fluid and solid mineral development, range improvements, and 

recreational activities proposed for location in sage-grouse PHMA and GHMA in a step-wise 

manner. The following steps identify a screening process for review of proposed activities or 

projects in these areas. This process will provide a consistent approach and ensure that 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 58

authorization of these projects, if granted, will appropriately mitigate impacts and be consistent 

with the LUP goals and objectives for sage-grouse. The following steps provide for a sequential 

screening of proposals. However, Steps 2-6 can be done concurrently.

D.1.1 Step 1 – Determine Proposal Adequacy

This screening process is initiated upon formal submittal of a proposal for authorization for use 

of BLM lands. The actual documentation of the proposal would include at a minimum a 

description of the location, scale of the project and timing of the disturbance. The acceptance of 

the proposal(s) for review would be consistent with existing protocol and procedures for each 

type of use. 

D.1.2 Step 2 – Evaluate Proposal Consistency with LUP 

This initial review should evaluate whether the proposal would be allowed as prescribed in the 

Land Use Plan. For example, some activities or types of development are prohibited in PHMA or 

GHMA. Evaluation of projects will also include an assessment of the current state of the 

Adaptive Management hard and soft triggers. If the proposal is for an activity that is specifically 

prohibited, the applicant should be informed that the application is being rejected since it would 

not be allowed, regardless of the design of the project. 

D.1.3 Step 3 – Determine Proposal Consistency with Density and 

Disturbance Limitations

If the proposed activity occurs within a PHMA, evaluate whether the disturbance from the 

activity exceeds the limit on the amount of disturbance allowed within the activity or project area 

(DDCT process). If current disturbance within the activity area or the anticipated disturbance 

from the proposed activity exceeds this threshold, the project would be deferred until such time 

as the amount of disturbance within the area has been reduced below the threshold, redesigned so 

as to not result in any additional surface disturbance (collocation) or redesigned to move it 

outside of PHMA. 

D.1.4 Step 4 – Determine Projected Sage-Grouse Population and Habitat 

Impacts

Determine if the project will have a direct or indirect impact on sage-grouse populations or 

habitat within PHMA or GHMA. This will include: 

 Reviewing Greater Sage-Grouse Habitat delineation maps to initially assess potential 

impacts to sage-grouse.

Use of the USGS report Conservation Buffer Distance Estimates for Greater SageGrouse—A Review to assess potential project impacts based upon the distance to the 
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Proposed Resource Management Plan and Final Environmental Impact Statement

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nearest lek, using the most recent active lek data available from the state wildlife agency. 

This assessment will be based upon the direction in Appendix [insert buffer appendix 

reference]:

 Review and application of current science recommendations.

 Reviewing the ‘Base Line Environment Report’ (USGS) which identifies areas of direct 

and indirect effect for various anthropogenic activities.

 Consultation with agency or State Wildlife Agency biologist.

 Evaluating consistency with (at a minimum) State sage-grouse regulations 

 Or other methods needed to provide an accurate assessment of impacts.

If the proposal will not have a direct or indirect impact on either the habitat or population, 

document the findings in the NEPA and proceed with the appropriate process for review, 

decision and implementation of the project.

D.1.5 Step 5 –Apply Avoidance and Minimization Measures to Comply with 

Sage-Grouse Goals and Objectives

If the project can be relocated so as to not have an impact on sage-grouse and still achieve 

objectives of the proposal and the disturbance limitations, relocate the proposed activity and 

proceed with the appropriate process for review, decision and implementation (NEPA and 

Decision Record). This Step does not consider redesign of the project to reduce or eliminate 

direct and indirect impacts, but rather authorization of the project in a physical location that will 

not impact Greater Sage-Grouse. If the preliminary review of the proposal concludes that there 

may be adverse impacts to sage-grouse habitat or populations in Step 4 and the project cannot be 

effectively relocated to avoid these impacts, proceed with the appropriate process for review, 

decision and implementation (NEPA and Decision Record) with the inclusion of appropriate 

mitigation requirements to further reduce or eliminate impacts to sage-grouse habitat and 

populations and achieve compliance with sage-grouse objectives. Mitigation measures could 

include disturbance buffer limits, timing of disturbance limits, noise restrictions, design 

modifications of the proposal, site disturbance restoration, post project reclamation, etc (see 

Mitigation Measures and Conservation Actions Appendix [Appendix AA, section F] for a more 

complete list of measures). Compensatory or offsite mitigation may be required (Step 6) in 

situations where residual impacts remain after application of all avoidance and minimization 

measures. 

D.1.6 Step 6 – Apply Compensatory Mitigation or Reject / Defer Proposal

If screening of the proposal (Steps 1-5) has determined that direct and indirect impacts cannot be 

eliminated through avoidance or minimization, evaluate the proposal to determine if

compensatory mitigation can be used to offset the remaining adverse impacts and achieve sagegrouse goals and objectives. If the impacts cannot be effectively mitigated, reject or defer the 

proposal. The criteria for determining this situation could include but are not limited to:
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 The current trend within the Priority Habitat is down and additional impacts, whether 

mitigated or not, could lead to further decline of the species or habitat.

 The proposed mitigation is inadequate in scope or duration, has proven to be ineffective 

or is unproven is terms of science based approach. 

 The project would impact habitat that has been determined to be a limiting factor for 

species sustainability.

 Other site specific information and analysis that determined the project would lead to a 

downward change of the current species population or habitat and not comply with sagegrouse goals and objectives.

If, following application of available impact avoidance and minimization measures, the project 

can be mitigated to fully offset impacts and assure conservation gain to the species and comply 

with sage-grouse goals and objectives, proceed with the appropriate process for review, decision 

and implementation (NEPA and Decision Record). 

The BLM/USFS, via the WAFWA Management Zone Greater Sage-Grouse Conservation Team, 

will develop a WAFWA Management Zone Regional Mitigation Strategy to guide the 

application of the mitigation hierarchy to address greater sage-grouse impacts within that Zone. 

The WAFWA Management Zone Regional Mitigation Strategy will be applicable to the 

States/Field Offices/Forests within the Zone’s boundaries. Subsequently, the BLM Billings Field 

Office’s NEPA analyses for implementation-level decisions, which have the potential to impact 

greater sage-grouse, will include analysis of mitigation recommendations from the relevant 

WAFWA Management Zone Regional Mitigation Strategy(ies). 

Implementation of the Regional Mitigation Strategy may involve managing compensatory 

mitigation funds, implementing compensatory mitigation projects, certifying 

mitigation/conservation banks, and reporting on the effectiveness of those projects. These types 

of mitigation implementation actions may be most effectively managed at the State-level, in 

collaboration with partners. BLM State Office/USFS Region may find it most effective to enter 

into an agreement with a State-level program administrator (e.g. a NGO, a State-level entity) to 

help manage these aspects of mitigation. The BLM/USFS will remain responsible for making 

decisions that affect Federal lands. 

The BLM’s Regional Mitigation Manual MS-1794 serves as a framework for developing and 

implementing a Regional Mitigation Strategy. The Appendix AA, Section E.2 provides 

additional guidance specific to the development and implementation of a WAFWA Management 

Zone Regional Mitigation Strategy. 
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E. MITIGATION

E.1 General

In undertaking BLM/USFS 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/USFS will 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 will be achieved by avoiding, minimizing, and compensating for impacts by 

applying beneficial mitigation actions. Mitigation will 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/USFS 

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 will be used to provide a net conservation gain to the species. 

Any compensatory mitigation will be durable, timely, and in addition to that which would have 

resulted without the compensatory mitigation (see glossary).

The BLM/USFS, via the WAFWA Management Zone Greater Sage-Grouse Conservation Team, 

will develop a WAFWA Management Zone Regional Mitigation Strategy that will inform the 

NEPA decision making process including the application of the mitigation hierarchy for 

BLM/USFS management actions and third party actions that result in habitat loss and 

degradation. A robust and transparent Regional Mitigation Strategy will contribute to greater 

sage-grouse habitat conservation by reducing, eliminating, or minimizing threats and 

compensating for residual impacts to greater sage-grouse and its habitat.

The BLM’s Regional Mitigation Manual MS-1794 serves as a framework for developing and 

implementing a Regional Mitigation Strategy. The following sections provide additional 

guidance specific to the development and implementation of a WAFWA Management Zone 

Regional Mitigation Strategy. 

E.2 Developing a WAFWA Management Zone Regional 

Mitigation Strategy

The BLM/USFS, via the WAFWA Management Zone Greater Sage-Grouse Conservation Team, 

will develop a WAFWA Management Zone Regional Mitigation Strategy to guide the 

application of the mitigation hierarchy for BLM/USFS management actions and third party 

actions that result in habitat loss and degradation. The Strategy should consider any State-level 

greater sage-grouse mitigation guidance that is consistent with the requirements identified in this 

Appendix. The Regional Mitigation Strategy should be developed in a transparent manner, based 

on the best science available and standardized metrics. 

As described in Chapter 2, the BLM/USFS will establish a WAFWA Management Zone Greater 

Sage-Grouse Conservation Team (hereafter, Team) to help guide the conservation of greater 
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sage-grouse, within 90 days of the issuance of the Record of Decision. The Strategy will be 

developed within one year of the issuance of the Record of Decision.

The Regional Mitigation Strategy should include mitigation guidance on avoidance, 

minimization, and compensation, as follows:

 Avoidance

o Include avoidance areas (e.g. right-of-way avoidance/exclusion areas, no surface 

occupancy areas) already included in laws, regulations, policies, and/or land use plans 

(e.g. Resource Management Plans, Forest Plans, State Plans); and,

o Include any potential, additional avoidance actions (e.g. additional avoidance best 

management practices) with regard to greater sage-grouse conservation.

 Minimization

o Include minimization actions (e.g. required design features, best management 

practices) already included in laws, regulations, policies, land use plans, and/or landuse authorizations; and,

o Include any potential, additional minimization actions (e.g. additional minimization 

best management practices) with regard to greater sage-grouse conservation.

 Compensation

o Include discussion of impact/project valuation, compensatory mitigation options, 

siting, compensatory project types and costs, monitoring, reporting, and program 

administration. Each of these topics is discussed in more detail below.

 Residual Impact and Compensatory Mitigation Project Valuation Guidance

o A common standardized method should be identified for estimating 

the value of the residual impacts and value of the compensatory 

mitigation projects, including accounting for any uncertainty 

associated with the effectiveness of the projects. 

o This method should consider the quality of habitat, scarcity of the 

habitat, and the size of the impact/project.

o For compensatory mitigation projects, consideration of durability (see 

glossary), timeliness (see glossary), and the potential for failure (e.g. 

uncertainty associated with effectiveness) may require an upward 

adjustment of the valuation.

o The resultant compensatory mitigation project will, after application of 

the above guidance, result in proactive conservation measures for 

Greater Sage-grouse (consistent with BLM Manual 6840 – Special 

Status Species Management, section .02).

 Compensatory Mitigation Options

o Options for implementing compensatory mitigation should be 

identified, such as:

 Utilizing certified mitigation/conservation bank or credit 

exchanges.

 Contributing to an existing mitigation/conservation fund.

 Authorized-user conducted mitigation projects.

o For any compensatory mitigation project, the investment must be 

additional (i.e. additionality: the conservation benefits of 
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compensatory mitigation are demonstrably new and would not have 

resulted without the compensatory mitigation project).

 Compensatory Mitigation Siting

o Sites should be in areas that have the potential to yield a net 

conservation gain to the greater sage-grouse, regardless of land 

ownership.

o Sites should be durable (see glossary).

o Sites identified by existing plans and strategies (e.g. fire restoration 

plans, invasive species strategies, healthy land focal areas) should be 

considered, if those sites have the potential to yield a net conservation 

gain to greater sage-grouse and are durable. 

 Compensatory Mitigation Project Types and Costs

o Project types should be identified that help reduce threats to greater 

sage-grouse (e.g. protection, conservation, and restoration projects).

o Each project type should have a goal and measurable objectives.

o Each project type should have associated monitoring and maintenance 

requirements, for the duration of the impact.

o To inform contributions to a mitigation/conservation fund, expected 

costs for these project types (and their monitoring and maintenance), 

within the WAFWA Management Zone, should be identified.

 Compensatory Mitigation Compliance and Monitoring

o Mitigation projects should be inspected to ensure they are 

implemented as designed, and if not, there should be methods to 

enforce compliance.

o Mitigation projects should be monitored to ensure that the goals and 

objectives are met and that the benefits are effective for the duration of 

the impact.

 Compensatory Mitigation Reporting

o Standardized, transparent, scalable, and scientifically-defensible 

reporting requirements should be identified for mitigation projects.

o Reports should be compiled, summarized, and reviewed in the 

WAFWA Management Zone in order to determine if greater sagegrouse conservation has been achieved and/or to support adaptive 

management recommendations.

 Compensatory Mitigation Program Implementation Guidelines

o Guidelines for implementing the State-level compensatory mitigation 

program should include holding and applying compensatory mitigation 

funds, operating a transparent and credible accounting system, 

certifying mitigation credits, and managing reporting requirements.

Incorporating the Regional Mitigation Strategy into NEPA Analyses

The BLM/USFS will include the avoidance, minimization, and compensatory recommendations 

from the Regional Mitigation Strategy in one or more of the NEPA analysis’ alternatives for 

BLM/USFS management actions and third party actions that result in habitat loss and 

degradation and the appropriate mitigation actions will be carried forward into the decision.
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Implementing a Compensatory Mitigation Program

The BLM/USFS 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 will be managed 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/USFS will enter into a contract or agreement with a third-party to help manage the Statelevel compensatory mitigation funds, within one year of the issuance of the Record of Decision. 

The selection of the third-party compensatory mitigation administrator will conform to all 

relevant laws, regulations, and policies. The BLM/USFS will remain responsible for making 

decisions that affect Federal lands.
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F. MITIGATION MEASURES

F.1 Introduction

The following Mitigation Measures and Conservation Actions are a compilation of Best 

Management Practices (BMPs), Required Design Features (RDFs), and/or operating procedures 

used by the BLM to meet statutory requirements for environmental protection and comply with 

resource specific Goals and Objectives set forward in this land use plan. The BLM will apply 

mitigation measures and conservation actions to modify the operations of authorized lands uses 

or activities to meet these obligations. Additional direction regarding mitigation can be found in 

the Interim Policy, Draft - Regional Mitigation Manual Section - 1794 (IM 2013-142) or 

subsequent decision documents. 

These measures and actions will be applied to avoid, minimize, rectify, reduce, and compensate 

for impacts if an evaluation of the authorization area indicates the presence of resources of 

concern which include, but are not limited to air, water, soils, cultural resources, national historic 

trails, recreation values and important wildlife habitat in order to reduce impacts associated with 

authorized land uses or activities such as road, pipeline, or powerline construction, fluid and 

solid mineral development, range improvements, and recreational activities. The mitigation 

measures and conservation actions for authorizations will be identified as part of the National 

Environmental Policy Act (NEPA) process, through interdisciplinary analysis involving resource 

specialists, project proponents, government entities, landowners or other Surface Management 

Agencies. Those measures selected for implementation will be identified in the Record of 

Decision (ROD) or Decision Record (DR) for those authorizations and will inform a potential 

lessee, permittee, or operator of the requirements that must be met when using BLMadministered public lands and minerals to mitigate impacts from those authorizations. Because 

these actions create a clear obligation for the BLM to ensure any proposed mitigation action 

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).

Because of site-specific circumstances and localized resource conditions, some mitigation 

measures and conservation actions may not apply to some or all 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. The BLM may add additional measures as deemed necessary through the 

environmental analysis and as developed through coordination with other federal, state, and local 

regulatory and resource agencies. Application of mitigation measures and conservation actions is 

subject to valid existing rights, technical and economic feasibility. 

Implementation and effectiveness of mitigation measures and conservation actions would be 

monitored to determine whether the practices are achieving resource objectives and 

accomplishing desired goals. Timely adjustments would be made as necessary to meet the 

resource goals and objectives.
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The list included in this appendix is not limiting, but references the most frequently used sources. 

The BLM may add additional site-specific restrictions as deemed necessary by further 

environmental analysis and as developed through coordination with other federal, state, and local 

regulatory and resource agencies. Because mitigation measures and conservation actions 

change or are modified, based on new information, the guidelines will be updated periodically. 

As new publications are developed; the BLM may consider those BMPs. In addition, many BLM 

handbooks (such as BLM Manual 9113-Roads and 9213-Interagency Standards for Fire and 

Aviation Operation) also contain BMP-type measures for minimizing impacts. These BLMspecific guidance and direction documents are not referenced in this appendix. The EIS for this 

RMP does not decide or dictate the exact wording or inclusion of these mitigation measures and 

conservation actions. Rather, they are used in the RMP and EIS process as a tool to help 

demonstrate at the Land Use Plan scale how they will be applied in considering subsequent 

activity plans and site-specific authorizations. These mitigation measures and conservation 

actions and their wording are matters of policy. As such, specific wording is subject to change,

primarily through administrative review, not through the RMP and EIS process. Any further 

changes that may be made in the continuing refinement of these mitigation measures and 

conservation actions and any development of program-specific standard procedures will be 

handled in another forum, including appropriate public involvement and input.

F.2 GENERAL MITIGATION MEASURES and CONSERVATION 

ACTION RESOURCES

F.2.1 Best Management Practices

Air Resource BMPs 

Developed by: Bureau of Land Management 

Publication reference: BLM/WO Updated May 9, 2011 

Available from: Online at: 

http://www.blm.gov/wo/st/en/prog/energy/oil_and_gas/best_management_practices/technical_in

formation.html 

Description: Identifies a range of typical Best Management Practices for protecting air resources 

during oil and gas development and production operations. 

Erosion and Sediment Control Practices: Field Manual 

Developed by: Prepared for the Montana Department of Transportation 

Publication reference: FHWA/MT-030003/8165 

Available from: National Technical Information Service, Springfield, VA 21161 

Description: The Erosion and Sediment Control Best Management Practices Construction Field 

Manual was developed to assist in design, construction, and post-construction phases of MDT 

projects. This manual provides background to concepts of Erosion and Sediment Control. Most 

of MDTs Best Management Practices are listed within the manual based on application 

categories. Each BMP is described; its applications and limitations are listed, as well as its 

design criteria. Construction phase and post-construction phase BMPs are described. This 

manual is a field guide and condensed version of the Erosion and Sediment Control Design 

Construction Best Management Practices Manual. For more detailed discussion on topic found 
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within, refer to the Erosion and Sediment Control Construction Best Management Practices 

Manual.

Erosion and Sediment Control Practices: Reference Manual 

Developed by: Prepared for the Montana Department of Transportation 

Publication reference: FHWA/MT-030003/8165 

Available from: National Technical Information Service, Springfield, VA 21161 

Description: The Erosion and Sediment Control Construction Best Management Practices 

Manual was developed to assist in the design, construction, and post-construction phases of 

Montana Department of Transportation (MDT) projects. This manual provides background to 

State and Federal regulations associated with erosion and sediment control practices including a 

general overview of the erosion and sediment processes. Best management practices are listed 

within the manual based on application categories. Each BMP is described; its applications and 

limitations are listed, as well as its design criteria. The design phase includes development of 

construction plans, notice of intent (NOI), and stormwater pollution prevention plan (SWPPP). 

Construction phase includes the finalization of the SWPPP, NOI, and the implementation of 

BMPs. Post-construction phase includes monitoring, maintenance, and removal activities. 

Fluid Minerals BMPs 

Developed by: Bureau of Land Management 

Publication reference: BLM/WO/ST-06/021+3071 

Available from: 

Online at: http://www.blm.gov/bmp/ 

Online at: http://www.mt.blm.gov/oilgas/operations/goldbook/goldbook1.html 

Online at: http://www.mt.blm.gov/oilgas/operations/goldbook/Stand_Enviro_Color.pdf 

Online at: http://www.mt.blm.gov/oilgas/operations/color.pdf 

Description: BMPs for oil and gas demonstrate practical ideas which may eliminate or minimize 

adverse impacts from oil and gas development to public health and the environment, landowners, 

and natural resources; enhance the value of natural and landowner resources; and reduce conflict. 

The publication reference is to the “Gold Book” which is formally titled “Surface Operating 

Standards and Guidelines for Oil and Gas Exploration and Development.” In addition, the first 

internet citation is to a location maintained by the Washington Office of the BLM containing 

general and technical information on the use and application of BMPs. The second location 

refers the reader directly to an online version of the “Gold Book.” The third and fourth locations 

refer the reader to color charts for use in selecting paint colors for oil and gas facilities. 

Montana Guide to the Streamside Management Zone Law 

Developed by: Montana Department of Natural Resources and Conservation Service Forestry 

Bureau, in cooperation with Montana Department of Environmental Quality, Montana Logging 

Association, Montana Wood Products Association, Plum Creek Timber LP, USDA Forest 

Service, USDI Bureau of Land Management 

Publication reference: Revised August 2002 

Available from: Montana Department of Natural Resources and Conservation, 2705 Spurgin 

Road, Missoula MT 59801-3199, (406)542-4300, or local MT DNRC field office. 

Description: The Montana Guide to the Streamside Management Zone Law is a field guide to 

compliance with State of Montana Law 77-5-301[1] MCA.) Complementary BMPs are found in 
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the Water Quality BMPS for Montana Forests (also referenced in this appendix). Provides 

definitions, stream classifications, and guidelines on the seven forest practices prohibited by 

Montana law in SMZs (broadcast burning, operation of wheeled or tracked vehicles except on 

established roads, the forest practice of clearcutting, the construction of roads except when 

necessary to cross a stream or wetland; the handling, storage, application, or disposal of 

hazardous or toxic materials in a manner that pollutes streams, lakes, or wetlands, or that may 

cause damage or injury to humans, land, animals, or plants; the side casting of road material into 

a stream, lake, wetland, or watercourse; and the deposit of slash in streams, lakes, or other water 

bodies. 

Montana Non-Point Source Management Plan 

Developed by: Montana Department of Environmental Quality, Water Quality Planning Bureau, 

Watershed Protection Section 

Publication reference: 2007 

Available from: Montana Department of Environmental Quality, Water Quality Planning Bureau, 

Watershed Protection Section, P.O. Box 200901, Helena, MT 59620-0901. 

Online at: 

http://www.deq.state.mt.us/wqinfo/nonpoint/2007NONPOINTPLAN/Final/NPSPlan.pdf 

Description: This document describes the Montana Department of Environmental Quality’s 

(DEQ) updated strategy for controlling nonpoint source (NPS) water pollution, which is the 

state’s single largest source of water quality impairment. NPS pollution is contaminated runoff 

from the land surface that can be generated by most land use activities, including agriculture, 

forestry, urban and suburban development, mining, and others. Common NPS pollutants include 

sediment, nutrients, temperature, heavy metals, pesticides, pathogens, and salt. The purpose of 

the Montana NPS Pollution Management Plan (Plan) is: 1) to inform the state’s citizens about 

NPS pollution problems; and 2) to establish goals, objectives, and both long-term and short-term 

strategies for controlling NPS pollution on a statewide basis. The goal of Montana’s NPS 

Management Program is to protect and restore water quality from the impacts of non-point 

sources of pollution in order to provide a clean and healthy environment. 

Montana Placer Mining BMPs 

Developed by: Montana Bureau of Mines and Geology 

Publication reference: Special Publication 106, October 1993 

Available from: Montana Bureau of Mines and Geology, Main Hall, Montana College of Mineral 

Science and Technology, Butte MT 59701 

Description: Provides guidelines for planning, erosion control, and reclamation in arid to semiarid, alpine, and subalpine environments, to prevent or decrease environmental damage and 

degradation of water quality. 
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Water Quality BMPs for Montana Forests 

Developed by: Montana State University Extension Service 

Publication reference: Logan, R. 2001. Water Quality BMPs – Best Management Practices for 

Montana Forests. EB158, MSU Extension Forestry, Missoula, MT. 58 pp. 

Available from: MSU Extension Forestry, 32 Campus Dr., Missoula MT 59812, OR MSU 

Extension Publications, PO Box 172040 Bozeman MT 59717 

Description: Discusses methods for managing forest land while protecting water quality and 

forest soils. Intended for all forest land in Montana, including non-industrial private, forest 

industry, and state or federally-owned forests. These are preferred (but voluntary) methods that 

go beyond Montana State Law (Streamside Management Zones). Includes definitions, basic 

biological information, and BMPs for Streamside Management Zones; road design, use, planning 

and locating, construction, drainage, and closure; stream crossings, soil, timber harvesting 

methods, reforestation, winter planning, and clean-up. 

Wind Energy BMPs 

Developed by: Bureau of Land Management 

Publication reference: Wind Energy Development Programmatic EIS 

Available from: FEIS Chapter 2 (section 2.2.3.2) at http://windeis.anl.gov/ 

Description: As part of the proposed action, BLM developed BMPs for each major step of the 

wind energy development process, including site monitoring and testing, plan of development 

preparation, construction, operation, and decommissioning. General BMPs are available for each 

step, and certain steps also include specific BMPs to address the following resource issues: 

wildlife and other ecological resources, Visual resources, Roads, Transportation, Noise, Noxious 

Weeds and Pesticides, Cultural/Historic Resources, Paleontological Resources, Hazardous 

Materials and Waste Management, Storm Water, Human Health and Safety, monitoring 

program, air emissions and excavation and blasting activities. 

Communication Tower BMPs

Developed by: United States Fish and Wildlife Service

Publication reference: Service Guidance on the Siting, Construction, Operation and 

Decommissioning of Communications Towers

Available from: http://www.fws.gov/habitatconservation/com_tow_guidelines.pdf

Description: These guidelines were developed by Service personnel from research conducted in 

several eastern, midwestern, and southern States, and have been refined through Regional 

review. They are based on the best information available at this time, and are the most prudent 

and effective measures for avoiding bird strikes at towers.

 Any company/applicant/licensee proposing to construct a new communications tower 

should be strongly encouraged to collocate the communications equipment on an existing 

communication tower or other structure (e.g., billboard, water tower, or building mount). 

Depending on tower load factors, from 6 to 10 providers may collocate on an existing 

tower.

 If collocation is not feasible and a new tower or towers are to be constructed, 

communications service providers should be strongly encouraged to construct towers no 

more than 199 feet above ground level, using construction techniques which do not 
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require guy wires (e.g., use a lattice structure, monopole, etc.). Such towers should be 

unlighted if Federal Aviation Administration regulations permit.

 If constructing multiple towers, providers should consider the cumulative impacts of all 

of those towers to migratory birds and threatened and endangered species as well as the 

impacts of each individual tower.

 If at all possible, new towers should be sited within existing "antenna farms" (clusters of 

towers). Towers should not be sited in or near wetlands, other known bird concentration 

areas (e.g., State or Federal refuges, staging areas, rookeries), in known migratory or 

daily movement flyways, or in habitat ofthreatened or endangered species. Towers should 

not be sited in areas with a high incidence of fog, mist, and low ceilings.

 If taller (>199 feet AGL) towers requiring lights for aviation safety must be constructed, 

the minimum amount of pilot warning and obstruction avoidance lighting required by the 

FAA should be used. Unless otherwise required by the FAA, only white (preferable) or 

red strobe lights should be used at night, and these should be the minimum number, 

minimum intensity, and minimum number of flashes per minute (longest duration 

between flashes) allowable by the FAA. The use of solid red or pulsating red warning 

lights at night should be avoided. Current research indicates that solid or pulsating 

(beacon) red lights attract night-migrating birds at a much higher rate than white strobe 

lights. Red strobe lights have not yet been studied.

 Tower designs using guy wires for support which are proposed to be located in known 

raptor or waterbird concentration areas or daily movement routes, or in major diurnal 

migratory bird movement routes or stopover sites, should have daytime visual markers on 

the wires to prevent collisions by these diurnally moving species. (For guidance on 

markers, see Avian Power Line Interaction Committee (APLIC). 1994. Mitigating Bird 

Collisions with Power Lines: The State ofthe Art in 1994. Edison Electric Institute, 

Washington, D.c., 78 pp, and Avian Power Line Interaction Committee (APLIC). 1996. 

Suggested Practices/or Raptor Protection on Power Lines. Edison Electric Institute 

Raptor Research Foundation, Washington, D. C; 128 pp. Copies can be obtained via the 

Internet at http://www.eei.org/resources/pubcat/enviro/. or by calling 1-800/334-5453).

 Towers and appendant facilities should be sited, designed and constructed so as to avoid 

or minimize habitat loss within and adjacent to the tower "footprint." However, a larger 

tower footprint is preferable to the use of guy wires in construction. Road access and 

fencing should be minimized to reduce or prevent habitat fragmentation and disturbance, 

and to reduce above ground obstacles to birds in flight.

 If significant numbers of breeding, feeding, or roosting birds are known to habitually use 

the proposed tower construction area, relocation to an alternate site should be 

recommended. If this is not an option, seasonal restrictions on construction may be 

advisable in order to avoid disturbance during periods of high bird activity.

 In order to reduce the number of towers needed in the future, providers should be 

encouraged to design new towers structurally and electrically to accommodate the 

applicant/licensee's antennas and comparable antennas for at least two additional users 

(minimum of three users for each tower structure), unless this design would require the 

addition of lights or guy wires to an otherwise unlighted and/or unguyed tower.

 Security lighting for on-ground facilities and equipment should be down-shielded to keep 

light within the boundaries of the site.
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 If a tower is constructed or proposed for construction, Service personnel or researchers 

from the Communication Tower Working Group should be allowed access to the site to 

evaluate bird use, conduct dead-bird searches, to place net catchments below the towers 

but above the ground, and to place radar, Global Positioning System, infrared, thermal 

imagery, and acoustical monitoring equipment as necessary to assess and verify bird 

movements and to gain information on the impacts of various tower sizes, configurations, 

and lighting systems.

 Towers no longer in use or determined to be obsolete should be removed within 12 

months of cessation of use.

GRAZING MANAGEMENT BEST MANAGEMENT PRACTICES (Guidelines)

Guidelines for grazing management are the types of grazing management methods and practices 

determined to be appropriate to ensure that rangeland health standards can be met or significant 

progress can be made toward meeting the standards. Guidelines are best management practices 

(BMP), treatments, and techniques and implementation of range improvements that will help 

achieve rangeland health standards. Guidelines are flexible and are applied on site specific 

situations. Standards for Rangeland Health and Guidelines for Livestock Grazing Management 

for the [INSERT NAME] Field Office can be found at: [INSERT WEB ADDRESS] 

BLM BMPs

The website below provides an introduction to BLM BMPs with links to BLM contacts, General 

BMP Information, BMP Frequently Asked Questions, BMP Technical Information, Oil and Gas 

Exploration—The Gold Book, Specific Resource BMPs, and, other BLM links. 

 http://www.blm.gov/bmp/

Visual Resources

The website below provides numerous design techniques that can be used to reduce the visual 

impacts from surface-disturbing projects. The techniques described here should be used in 

conjunction with BLM’s visual resource contrast rating process wherein both the existing 

landscape and the proposed development or activity are analyzed for their basic element of form, 

line, color, and texture. 

 http://www.blm.gov/pgdata/content/wo/en/prog/Recreation/recreation_national/RMS.htm

l

Renewable Energy Development

The following resources provide information on BMPs related to renewable energy development.

 Wind Energy Development Programmatic Environmental Impact Statement: 

http://windeis.anl.gov/documents/fpeis/index.cfm

 BLM Instruction Memorandum 2009-043, Rights-of-Way, Wind Energy: 

http://www.blm.gov/wo/st/en/info/regulations/Instruction_Memos_and_Bulletins/nationa

l_instruction/2009/IM_2009-043.htm.

 Solar Energy Development Programmatic Environmental Impact Statement:

http://www.solareis.anl.gov/
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Healthy Watersheds

The website below provides conservation approaches and tools designed to ensure healthy 

watersheds remain intact. It also provides site-specific examples. 

 http://www.epa.gov/owow/nps/

Storm Water BMPs

The website below provides BMPs designed to meet the minimum requirements for six control 

measures specified by the EPA’s Phase II Stormwater Program. 

 http://cfpub.epa.gov/npdes/stormwater/menuofbmps/index.cfm

Pasture, Rangeland, and Grazing Operations BMPs

The website below provides BMPs compiled by the EPA to prevent or reduce impacts associated 

with livestock grazing. 

 http://www.epa.gov/oecaagct/anprgbmp.html

National Range and Pasture Handbook

The website below provides procedures in support of NRCS policy for the inventory, analysis, 

treatment, and management of grazing land resources.

 http://www.nrcs.usda.gov/wps/portal/nrcs/detailfull/national/landuse/rangepasture/?cid=s

telprdb1043084

Montana Nonpoint Source Management Program

The website below provides links to information on funding for implementing nonpoint source 

controls, examples of control projects, and Montana’s current Nonpoint Source Management 

Plan. This plan identifies and provides details for BMPs to improve and maintain water quality.

 http://www.deq.mt.gov/wqinfo/nonpoint/nonpointsourceprogram.mcpx

The following would be applied, if warranted, to any BLM authorized activity.

 The total disturbance area would be minimized and to the extent possible. 

 Surface disturbances would be co-located in areas of previous or existing disturbance to 

the extent technically feasible. 

 Linear facilities would be located in the same trenches (or immediately parallel to) and 

when possible, installed during the same period of time.

 Plans of development would be required for major ROWs, renewable energy and 

minerals development. Such plans would identify measures for reducing impacts.

 Where the federal government owns the surface and the mineral estate is in nonfederal 

ownership, the BLM would apply appropriate fluid mineral BMPs to surface 

development.

 Remove facilities and infrastructure when use is completed.

 Vegetation would be removed only when necessary. Mowing would be preferred. If 

mowed, when possible work would be performed when vegetation is dormant.

 Two-track (primitive) roads would be used when possible.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 73

 Utilization of the Surface Operating Standards and Guidelines for Oil and Gas 

Exploration and Development (i.e., The Gold Book) shall be utilized for the design of 

roads, utilities, and oil and gas operations.

 Directional drilling, drilling multiple wells from the same pad, co-mingling, 

recompletion, or the use of existing well pads would be employed to the extent 

technically feasible to minimize surface impacts from oil and gas development.

 Utilities would be ripped or wheel-trenched whenever practical.

 Remote telemetry would be used to reduce vehicle traffic to the extent technically 

feasible (e.g., monitoring oil and gas operations). 

 Perennial streams would be crossed using bore crossing (directional drill) or other 

environmentally sound method.

 For activities resulting in major surface-disturbance as determined by the AO, a 

mitigation monitoring and reporting strategy would be developed and implemented (see 

the Reclamation Appendix for further guidance). 

 Operations would avoid sensitive resources including riparian areas, wetlands, 

floodplains, waterbodies and areas subject to erosion and soil degradation. 

 The BLM would, on a case-by-case basis, use temporary or permanent enclosures (e.g., 

in woody draw or riparian areas) to promote species diversity, recruitment, and structure.

 Accelerated erosion, soil loss, and impacts to water quality would be reduced by 

diverting stormwater and trapping sediment during activity. 

 Pitless or aboveground closed-loop drilling technology would be used to the extent 

technically feasible. Recycle drilling mud and completion fluids for use in future drilling 

activities. 

 Where needed, pits would be lined with an impermeable liner. Pits would not be placed 

in fill material or natural watercourses, and pits may not be cut or trenched. 

 Fertilizer would not be applied within 500 feet of wetlands and waterbodies. 

 Vehicle and equipment servicing and refueling activities would take place 500 feet from 

the outer edge of riparian areas, wet areas, and drainages. 

 Activity may be restricted during wet or frozen conditions. Mechanized equipment use 

would be avoided if the equipment causes rutting to a depth of 4 inches or greater.

 Vehicle wash stations would be used prior to entering or leaving disturbance to reduce 

the transport and establishment of invasive species.

 Invasive species plant parts would not be transported off site without appropriate disposal 

measures.

 Use alternative energy (solar or wind power) to power new water source developments.

 Overhead power lines, where authorized would follow the recommendations in the most 

recent guidance from the Avian Power Line Interaction Committee (1994, as amended 

2006, 2012).

 Weed management prescriptions would be included in all new treatment projects and 

incorporated into existing contracts, agreements, task forces, designated weed-free 

management areas, and land use authorizations that resulted in ground-disturbing 

activities. 

 Whenever possible, ROWs would be constructed within or next to compatible ROW’s, 

such as roads, pipelines, communications sites, and railroads. 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 74

 The operator shall be responsible for locating and protecting existing pipelines, power 

lines, communication lines, and other related infrastructure. 

 Potential changes in climate would be considered when proposing restoration seedings 

when using native plants. Collection from the warmer component of the species current 

range would be considered when selecting native species.

F.3 Greater Sage-Grouse Required Design Features

This appendix also includes the Required Design Features for Greater Sage-Grouse Habitat. 

Required Design Features (RDFs) are required for certain activities in all GRSG habitat. RDFs 

establish the minimum specifications for certain activities to help mitigate adverse impacts. 

However, the applicability and overall effectiveness of each RDF cannot be fully assessed until 

the project level when the project location and design are known. Because of site-specific 

circumstances, some RDFs may not apply to some projects (e.g., a resource is not present on a 

given site) and/or may require slight variations (e.g., a larger or smaller protective area). All 

variations in RDFs would require that at least one of the following be demonstrated in the NEPA 

analysis associated with the project/activity:

• A specific RDF is documented to not be applicable to the site-specific conditions of the 

project/activity (e.g.due to site limitations or engineering considerations). Economic 

considerations, such as increased costs, do not necessarily require that an RDF be varied or 

rendered inapplicable;

• An alternative RDF is determined to provide equal or better protection for GRSG or its 

habitat;

• A specific RDF will provide no additional protection to GRSG or its habitat.

Required Design Features for how to make a pond that won’t produce mosquitoes that 

transmit West Nile virus (from Doherty [2007])

1. Increase the size of ponds to accommodate a greater volume of water than is discharged. 

This will result in un‐vegetated and muddy shorelines that breeding Cx. tarsalis avoid 

(De Szalay and Resh 2000). This modification may reduce Cx. tarsalis habitat but could 

create larval habitat for Culicoides sonorensis, a vector of blue tongue disease, and 

should be used sparingly (Schmidtmann et al. 2000). Steep shorelines should be used in 

combination with this technique whenever possible (Knight et al. 2003). 

2. Build steep shorelines to reduce shallow water (>60 centimeters [cm]) and aquatic 

vegetation around the perimeter of impoundments (Knight et al. 2003). Construction of 

steep shorelines also will create more permanent ponds that are a deterrent to colonizing 

mosquito species like Cx. tarsalis which prefer newly flooded sites with high primary 

productivity (Knight et al. 2003).

3. Maintain the water level below that of rooted vegetation for a muddy shoreline that is 

unfavorable habitat for mosquito larvae. Rooted vegetation includes both aquatic and 

upland vegetative types. Avoid flooding terrestrial vegetation in flat terrain or low lying 

areas. Aquatic habitats with a vegetated inflow and outflow separated by open water 

produce 5‐10 fold fewer Culex mosquitoes than completely vegetated wetlands (Walton 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 75

and Workman 1998). Wetlands with open water also had significantly fewer stage III and 

IV instars which may be attributed to increased predator abundances in open water 

habitats (Walton and Workman 1998).

4. Construct dams or impoundments that restrict down slope seepage or overflow by 

digging ponds in flat areas rather than damming natural draws for effluent water storage, 

or lining constructed ponds in areas where seepage is anticipated (Knight et al. 2003).

5. Line the channel where discharge water flows into the pond with crushed rock, or use a 

horizontal pipe to discharge inflow directly into existing open water, thus precluding 

shallow surface inflow and accumulation of sediment that promotes aquatic vegetation.

6. Line the overflow spillway with crushed rock, and construct the spillway with steep sides 

to preclude the accumulation of shallow water and vegetation.

7. Fence pond site to restrict access by livestock and other wild ungulates that trample and 

disturb shorelines, enrich sediments with manure and create hoof print pockets of water 

that are attractive to breeding mosquitoes.

Literature Cited

De Szalay, F.A. and V.H. Resh. 2000. Factors influencing macroinvertebrate colonization of 

seasonal wetlands: responses to emergent plant cover. Freshwater Biology. 45: 295‐308.

Doherty, M.K. 2007. Mosquito populations in the Powder River Basin, Wyoming: a comparison 

of natural, agricultural and effluent coal bed natural gas aquatic habitats. M.S. Thesis. 

Montana State University, Bozeman, U.S.A.

Knight, R.L., W.E. Walton, G.F. Meara, W.K. Riesen and R. Wass. 2003. Strategies for effective 

mosquito control in constructed treatment wetlands. Ecological Engineering. 21: 211‐

232.

Schmidtmann, E.T., R.J. Bobian, R.P. Beldin. 2000. Soil chemistries define aquatic habitats with 

immature populations of the Culicoides variipennis complex (Diptera: Ceratopogonidae). 

Journal of Medical Entomology. 37: 38‐64.

Walton, W.E., and P.D. Workman. 1998. Effect of marsh design on the abundance of mosquitoes 

in experimental constructed wetlands in Southern California. Journal of the American 

mosquito control Association 14:95‐107.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 76

F.3.1 Required Design Features for Fluid Mineral Development

Priority Habitat Management Areas (PHMA)

Roads

 Design roads to an appropriate standard no higher than necessary to accommodate their 

intended purpose.

 Locate roads to avoid important areas and habitats.

 Coordinate road construction and use among right-of-way (ROW) holders. 

 Construct road crossing at right angles to ephemeral drainages and stream crossings.

 Establish speed limits on BLM system roads to reduce vehicle/wildlife collisions or design 

roads to be driven at slower speeds.

 Establish trip restrictions or minimization through use of telemetry and remote well 

control (e.g., Supervisory Control and Data Acquisition).

 Do not issue ROWs to counties on newly constructed energy development roads, unless 

for a temporary use consistent with all other terms and conditions included in this 

document.

 Restrict vehicle traffic to only authorized users on newly constructed routes (use signing, 

gates, etc.) 

 Use dust abatement practices on roads and pads.

 Close and rehabilitate duplicate roads.

Operations 

 Cluster disturbances, operations (fracture stimulation, liquids gathering, etc.), and 

facilities.

 Use directional and horizontal drilling to reduce surface disturbance.

 Place infrastructure in already disturbed locations where the habitat has not been restored.

 Consider using oak (or other material) mats for drilling activities to reduce vegetation 

disturbance and for roads between closely spaced wells to reduce soil compaction and 

maintain soil structure to increase likelihood of vegetation reestablishment following 

drilling.

 Apply a phased development approach with concurrent reclamation.

 Place liquid gathering facilities outside of priority areas. Have no tanks at well locations 

within priority areas (minimizes perching and nesting opportunities for ravens and raptors 

and truck traffic). Pipelines must be under or immediately adjacent to the road (Bui et al. 

2010).

 Restrict the construction of tall facilities and fences to the minimum number and amount 

needed. 

 Site and/or minimize linear ROWs to reduce disturbance to sagebrush habitats.

 Place new utility developments (power lines, pipelines, etc.) and transportation routes in 

existing utility or transportation corridors.

 Bury distribution power lines.

 Corridor power, flow, and small pipelines under or immediately adjacent to roads.

 Design or site permanent structures which create movement (e.g. a pump jack) to 

minimize impacts to sage-grouse. 

 Cover (e.g., fine mesh netting or use other effective techniques) all drilling and production 

pits and tanks regardless of size to reduce sage-grouse mortality.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 77

 Equip tanks and other above ground facilities with structures or devices that discourage 

nesting of raptors and corvids.

 Control the spread and effects of non-native plant species (e.g. by washing vehicles and 

equipment).

 Use only closed-loop systems for drilling operations and no reserve pits.

 Restrict pit and impoundment construction to reduce or eliminate threats from West Nile 

virus (Doherty 2007).

 Remove or re-inject produced water to reduce habitat for mosquitoes that vector West Nile 

virus. If surface disposal of produced water continues, use the following steps for 

reservoir design to limit favorable mosquito habitat:

 Overbuild size of ponds for muddy and non-vegetated shorelines.

 Build steep shorelines to decrease vegetation and increase wave actions.

 Avoid flooding terrestrial vegetation in flat terrain or low lying areas.

 Construct dams or impoundments that restrict down slope seepage or overflow.

 Line the channel where discharge water flows into the pond with crushed rock.

 Construct spillway with steep sides and line it with crushed rock.

 Treat waters with larvicides to reduce mosquito production where water occurs on the 

surface.

 The BLM would work with proponents to limit project-related noise where it would be 

expected to reduce functionality of habitats that support GRSG populations. The BLM 

would evaluate the potential for limitation of new noise sources on a case-by-case basis 

as appropriate.

 As additional research and information emerges, specific new limitations appropriate to 

the type of projects being considered would be evaluated, and appropriate limitations

would be implemented where necessary to minimize potential for noise impacts on 

GRSG population behavioral cycles.

 As new research is completed, new specific limitations would be coordinated with the 

NDGF and partners. Noise levels at the perimeter of the lek should not exceed 10 dBA 

above ambient noise.

 Require noise shields when drilling during the lek, nesting, broodrearing, or wintering 

season. 

 Fit transmission towers with anti-perch devices (Lammers and Collopy 2007).

 Require sage-grouse-safe fences.

 Locate new compressor stations outside PH and design them to reduce noise that may be 

directed towards PH.

 Clean up refuse.

 Locate man camps outside of PH.

Reclamation

 Include objectives for ensuring habitat restoration to meet sage-grouse habitat needs in 

reclamation practices/sites (Pyke 2011). Address post reclamation management in 

reclamation plan such that goals and objectives are to protect and improve sage-grouse 

habitat needs.

 Maximize the area of interim reclamation on long-term access roads and well pads 

including reshaping, topsoiling and revegetating cut and fill slopes.

 Restore disturbed areas at final reclamation to the pre-disturbance landforms and desired 

plant community.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 78

 Irrigate interim reclamation if necessary for establishing seedlings more quickly.

 Utilize mulching techniques to expedite reclamation and to protect soils. 

General Sage-Grouse Habitat Management Areas (GHMA)

 Make applicable BMPs mandatory as Conditions of Approval (COA) within GH. BMPs 

are continuously improving as new science and technology become available and 

therefore are subject to change. At a minimum include the following BMPs:

Roads

 Design roads to an appropriate standard no higher than necessary to accommodate their 

intended purpose.

 Do not issue ROWs to counties on mining development roads, unless for a temporary use 

consistent with all other terms and conditions included in this document.

 Establish speed limits on BLM system roads to reduce vehicle/wildlife collisions or design 

roads to be driven at slower speeds.

 Coordinate road construction and use among ROW holders.

 Construct road crossing at right angles to ephemeral drainages and stream crossings.

 Use dust abatement practices on roads and pads.

 Close and reclaim duplicate roads, by restoring original landform and establishing desired 

vegetation.

 Operations 

 Cluster disturbances associated with operations and facilities as close as possible.

 Use directional and horizontal drilling to reduce surface disturbance.

 Clean up refuse.

 Restrict the construction of tall facilities and fences to the minimum number and amount 

needed.

 Cover (e.g., fine mesh netting or use other effective techniques) all pits and tanks 

regardless of size to reduce sage-grouse mortality.

 Equip tanks and other above ground facilities with structures or devices that discourage 

nesting of raptors and corvids.

 Use remote monitoring techniques for production facilities and develop a plan to reduce 

the frequency of vehicle use.

 Control the spread and effects of non-native plant species (Gelbard and Belnap 2003, 

Bergquist et al. 2007).

 Restrict pit and impoundment construction to reduce or eliminate augmenting threats from 

West Nile virus (Doherty 2007).

Reclamation

 Include restoration objectives to meet sage-grouse habitat needs in reclamation 

practices/sites. Address post reclamation management in reclamation plan such that goals 

and objectives are to protect and improve sage-grouse habitat needs.

Literature Cited

Blickley, J.L., D. Blackwood, and G.L. Patricelli. In preparation. Experimental evidence for 

avoidance of chronic anthropogenic noise by greater sage‐grouse. University of 

California‐Davis, California, USA.

Bui, T.D., J.M. Marzluff, and B. Bedrosian. 2010. Common raven activity in relation to land use 
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 79

in western Wyoming: implications for greater sage‐grouse reproductive success. Condor 

112:65‐78.

Doherty, M.K. 2007. Mosquito populations in the Powder River Basin, Wyoming: a comparison 

of natural, agricultural and effluent coal‐bed natural gas aquatic habitats. M.S. thesis, 

Montana State University, Bozeman, Montana, USA.

Evangelista, P.H., A.W. Crall, and E. Bergquist. 2011. Invasive plants and their response to 

energy development. Pages 115‐129 in D.E. Naugle, editor. Energy development and 

wildlife conservation in western North America. Island Press, Washington, D.C., USA.

Lammers, W.M., and M.W. Collopy. 2007. Effectiveness of avian predator perch deterrents on 

electric transmission lines. Journal of Wildlife Management 71:2752‐2758.

Lyon, A.G. and S.H. Anderson. 2003. Potential gas development impacts on sage grouse nest 

initiation and movement. Wildlife Society Bulletin 31: 486‐491.

Patricelli, G.L., J.L. Blickley, and S. Hooper. 2010. Incorporating the impacts of noise pollution 

into greater sage‐grouse conservation planning. 27th Meeting of the Western Agencies Sage 

and Columbian Sharp‐tailed Grouse Technical Committee Workshop. Twin Falls, Idaho, 

USA.

Pyke, D.A. 2011. Restoring and rehabilitating sagebrush habitats. Pp. 531‐548 in S.T. Knick and

J.W. Connelly (editors). Greater sage‐grouse: ecology and conservation of a landscape species 

and its habitats. Studies in Avian Biology 38. University of California Press. Berkeley, CA.

F.3.2 Required Design Features for Fire & Fuels

F.3.2.1 Fuels Management

1. Where applicable, design fuels treatment objective to protect existing sagebrush 

ecosystems, modify fire behavior, restore native plants, and create landscape patters which most 

benefit sage‐grouse habitat.

2. Provide training to fuels treatment personnel on sage‐rouse biology, habitat requirements, 

and identification of areas utilized locally.

3. Use fire prescriptions that minimize undesirable effects on vegetation or soils (e.g., 

minimize mortality of desirable perennial plant species and reduce risk of hydrophobicity).

4. Ensure proposed sagebrush treatments are planned with interdisciplinary input from BLM 

and /or state wildlife agency biologist and that treatment acreage is conservative in the context of 

surrounding sage-grouse seasonal habitats and landscape.

5. Where appropriate, ensure that treatments are configured in a manner (e.g., strips) that 

promotes use by sage‐grouse (See Connelly et al. 2000*)

6. Where applicable, incorporate roads and natural fuel breaks into fuel break design.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 80

7. Power‐wash all vehicles and equipment involved in fuels management activities prior to 

entering the area to minimize the introduction of undesirable and/or invasive plant species.

8. Design vegetation treatment in areas of high frequency to facilitate firefighting safety, 

reduce the risk of extreme fire behavior; and to reduce the risk and rate of fire spread to key and 

restoration habitats.

9. Give priority for implementing specific sage‐grouse habitat restoration projects in annual 

grasslands first to sites which are adjacent to or surrounded by sage‐grouse key habitats. Annual 

grasslands are second priority for restoration when the sites not adjacent to key habitat, but 

within two miles of key habitat. The third priority for annual grasslands habitat restoration 

projects are sites beyond two miles of key habitat. The intent is to focus restoration outward from 

existing, intact habitat.

10. As funding and logistics permit, restore annual grasslands to a species composition 

characterized by perennial grasses, forbs, and shrubs.

11. Emphasize the use of native plant species, recognizing that non‐native species may be 

necessary depending on the availability of native seed and prevailing site conditions.

12. Remove standing and encroaching trees within at least 100 meters of occupied sage‐

grouse leks and other habitats (e.g., nesting, wintering, and brood rearing) to reduce the 

availability of perch sites for avian predators, as appropriate, and resources permit.

13. Protect wildland areas from wildfire originating on private lands, infrastructure corridors, 

and recreational areas.

14. Reduce the risk of vehicle or human‐caused wildfires and the spread of invasive species 

by planting perennial vegetation (e.g., green‐strips) paralleling road rights‐of‐way.

15. Strategically place and maintain pre‐treated strips/areas (e.g., mowing, herbicide 

application, and strictly managed grazed strips) to ail in controlling wildfire should wildfire 

occur near key habitats or important restoration areas (such as where investments in restoration 

have already been made).

F.3.2.2 Fire Management

1. Develop state‐specific sage‐grouse toolboxes containing maps, a list of resource advisors, 

contact information, local guidance, and other relevant information.

2. Provide localized maps to dispatch offices and extended attack incident commanders for 

use in prioritizing wildfire suppression resources and designing suppression tactics.

3. Assign a sage‐grouse resource advisor to all extended attack fires in or near key sage‐

grouse habitat areas. Prior to the fire season, provide training to sage‐grouse resource advisors on 

wildfire suppression organization, objectives, tactics, and procedures to develop a cadre of 

qualified individuals.

4. On critical fire weather days, pre‐position additional fire suppression resources to 

optimize a quick and efficient response in sage‐grouse habitat areas.

5. During periods of multiple fires, ensure line officers are involved in setting priorities.

6. To the extent possible, locate wildfire suppression facilities (i.e., base camps, spike 

camps, drop points, staging areas, heli‐bases) in areas where physical disturbance to sage‐grouse 

habitat can be minimized. These include disturbed areas, grasslands, near roads/trails or in other 

areas where there is existing disturbance or minimal sagebrush cover.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 81

7. Power‐wash all firefighting vehicles, to the extent possible, including engines, water 

tenders, personnel vehicles, and all-terrain vehicles prior to deploying in or near sage‐grouse 

habitat areas to minimize noxious weed spread.

8. Minimize unnecessary cross‐country vehicle travel during fire operations in sage‐grouse 

habitat.

9. Minimize burnout operations in key sage‐grouse habitat areas by constructing direct 

fireline whenever safe and practical to do so.

10. Utilize retardant and mechanized equipment to minimize burned acreage during initial 

attack.

11. As safety allows, conduct mop‐up where the black adjoins unburned islands, dog legs, or 

other habitat features to minimize sagebrush loss.

Literature Cited

Connelly, J.W., M.A Schroeder, A.R. Sands, and C.E. Braun 2000. Guidelines to Manage 

Sage‐grouse Populations and Their Habitats. Wildlife Society Bulletin 28:967‐985.

F.3.3 Required Design Features for Solid Minerals

Introduction

The following measures would be applied as RDFs for all solid minerals. They would also apply 

to locatable minerals consistent with applicable law. The RDFs or BMPs would be applied as 

appropriate in PH and GH, and to the extent allowable by law (i.e., to prevent unnecessary and 

undue degradation). 

Roads

 Design roads to an appropriate standard no higher than necessary to accommodate their 

intended purpose.

 Locate roads to avoid important areas and habitats.

 Coordinate road construction and use among ROW holders.

 Construct road crossing at right angles to ephemeral drainages and stream crossings.

 Establish speed limits on BLM system roads to reduce vehicle/wildlife collisions or 

design roads to be driven at slower speeds.

 Do not issue ROWs to counties on mining development roads, unless for a temporary use 

consistent with all other terms and conditions included in this document.

 Restrict vehicle traffic to only authorized users on newly constructed routes (e.g., use 

signing, gates, etc.)

 Use dust abatement practices on roads and pads.

 Close and reclaim duplicate roads, by restoring original landform and establishing desired 

vegetation.

Operations

 Cluster disturbances associated with operations and facilities as close as possible.

 Place infrastructure in already disturbed locations where the habitat has not been restored.

 Restrict the construction of tall facilities and fences to the minimum number and amount 

needed.

 Site and/or minimize linear ROWs to reduce disturbance to sagebrush habitats.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 82

 Place new utility developments (power lines, pipelines, etc.) and transportation routes in 

existing utility or transportation corridors.

 Bury power lines.

 Cover (e.g., fine mesh netting or use other effective techniques) all pits and tanks 

regardless of size to reduce sage‐grouse mortality.

 Equip tanks and other above ground facilities with structures or devices that discourage 

nesting of raptors and corvids.

 Control the spread and effects of non‐native plant species (Gelbard and Belnap 2003, 

Bergquist et al. 2007).

 Restrict pit and impoundment construction to reduce or eliminate threats from West Nile 

virus (Doherty 2007).

 Remove or re‐inject produced water to reduce habitat for mosquitoes that vector West 

Nile virus. If surface disposal of produced water continues, use the following steps for 

reservoir design to limit favorable mosquito habitat:

 Overbuild size of ponds for muddy and non‐vegetated shorelines.

 Build steep shorelines to decrease vegetation and increase wave actions.

 Avoid flooding terrestrial vegetation in flat terrain or low lying areas.

 Construct dams or impoundments that restrict down slope seepage or overflow.

 Line the channel where discharge water flows into the pond with crushed rock.

 Construct spillway with steep sides and line it with crushed rock.

 Treat waters with larvicides to reduce mosquito production where water occurs on the 

surface.

 Require sage‐grouse‐safe fences around sumps.

 Clean up refuse (Bui et al. 2010).

 Locate man camps outside of PH.

Reclamation

 Include restoration objectives to meet sage‐grouse habitat needs in reclamation 

practices/sites.

 Address post reclamation management in reclamation plan such that goals and objectives 

are to protect and improve sage‐grouse habitat needs.

 Maximize the area of interim reclamation on long‐term access roads and well pads 

including reshaping, topsoiling and revegetating cut and fill slopes.

 Restore disturbed areas at final reclamation to pre‐disturbance landform and desired plant 

community.

 Irrigate interim reclamation as necessary during dry periods.

 Utilize mulching techniques to expedite reclamation.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 83

Literature Cited

Bergquist, E., P. Evangelista, T. J. Stohlgren, and N. Alley. 2007. Invasive species and coal bed 

methane development in the Powder River Basin, Wyoming. Environmental Monitoring 

and Assessment 128:381‐394.

Bui, T.D., J.M. Marzluff, and B. Bedrosian. 2010. Common raven activity in relation to land use 

in western Wyoming: implications for greater sage‐grouse reproductive success. Condor 

112:65‐78.

Doherty, M.K. 2007. Mosquito populations in the Powder River Basin, Wyoming: a comparison 

of natural, agricultural and effluent coal bed natural gas aquatic habitats. Thesis. Montana 

State University, Bozeman, U.S.A.

Gelbard, J.L., and J. Belnap. 2003. Roads as conduits for exotic plant invasions in a semiarid 

landscape. Conservation Biology 17:420‐432.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 84

G. Greater Sage-Grouse: Applying Lek Buffers

G.1 Buffer Distances and Evaluation of Impacts to Leks

The BLM will evaluate impacts to leks from actions requiring NEPA analysis. In addition to

any other relevant information determined to be appropriate (e.g., state wildlife agency plans), 

the BLM will assess and address impacts from the following activities using the lek bufferdistances as identified in the USGS Report Conservation Buffer Distance Estimates for Greater 

Sage-Grouse – A Review (Open File Report 2014-1239). The BLM will apply the lek bufferdistances specified as the lower end of the interpreted range in the report unless justifiable

departures are determined to be appropriate (see below). The lower end of the interpreted range

of the lek buffer-distances is as follows:

 linear features (roads) within 3.1 miles of leks

 infrastructure related to energy development within 3.1 miles of leks.

 tall structures (e.g., communication or transmission towers, transmission lines) within 2

miles of leks.

 low structures (e.g., fences, rangeland structures) within 1.2 miles of leks.

 surface disturbance (continuing human activities that alter or remove the natural

vegetation) within 3.1 miles of leks.

 noise and related disruptive activities including those that do not result in habitat loss

(e.g., motorized recreational events) at least 0.25 miles from leks.

Justifiable departures to decrease or increase from these distances, based on local data, best

available science, landscape features, and other existing protections (e.g., land use allocations, 

state regulations) may be appropriate for determining activity impacts. The USGS report

recognizes that “because of variation in populations, habitats, development patterns, social

context, and other factors, for a particular disturbance type, there is no single distance that is an 

appropriate buffer for all populations and habitats across the sage-grouse range.” The USGS

report also states that “various protection measures have been developed and implemented... 

[which have] the ability (alone or in concert with others) to protect important habitats, sustain

populations, and support multiple-use demands for public lands.” All variations in lek bufferdistances will require appropriate analysis and disclosure as part of activity authorization.

In determining lek locations, the BLM will use the most recent active or occupied lek data 

available from the state wildlife agency.

G.2 For Actions in General Habitat Management Area (GHMA)

The BLM will apply the lek buffer-distances identified above as required conservation

measures to fully address the impacts to leks as identified in the NEPA analysis.

 Impacts should first be avoided by locating the action outside of the applicable lek

buffer-distance(s) identified above. Impacts should first be avoided by locating the 

action outside of the applicable lek buffer-distance(s) identified above. 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AA AA - 85

 The BLM may approve actions in GHMA that are within the applicable lek buffer 

distance identified above only if: 

o Based on best available science, landscape features, and other existing

protections, (e.g., land use allocations, state regulations), the BLM determines 

that a lek buffer-distance other than the applicable distance identified above

offers the same or a greater level of protection to Greater Sage-Grouse and its

habitat, including conservation of seasonal habitat outside of the analyzed 

buffer area; or

o The BLM determines that impacts to Greater Sage-Grouse and its habitat are

minimized such that the project will cause minor or no new disturbance (ex. 

co-location with existing authorizations); and

o Any residual impacts within the lek buffer-distances are addressed through 

compensatory mitigation measures sufficient to ensure a net conservation

gain, as outlined in the Mitigation Strategy

G.3 For Actions in Priority Habitat Management Area (PHMA)

The BLM will apply the lek buffer-distances identified above as required conservation

measures to fully address the impacts to leks as identified in the NEPA analysis. Impacts

should be avoided by locating the action outside of the applicable lek buffer-distance(s) 

identified above.

The BLM may approve actions in PHMA that are within the applicable lek buffer distance

identified above only if:

 The BLM, with input from the state fish and wildlife agency, determines, based on best

available science, landscape features, and other existing protections, that a buffer 

distance other than the distance identified above offers the same or greater level of 

protection to Greater Sage-Grouse and its habitat, including conservation of seasonal

habitat outside of the analyzed buffer area.

Range improvements which do not impact GRSF, or, range improvements which provide a 

conservation benefit to GRSG such as fences for protecting important seasonal habitats, meet 

the lek buffer requirement.

The BLM will explain its justification for determining the approved buffer distances meet these 

conditions in its project decision.
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Appendix AB: 

Crosswalk between Billings and Pompeys Pillar 

National Monument RMP/EIS and the COT Report
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Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AB AB - 1

INTRODUCTION to

SUMMARY of B&PPNM RMP IMPACTS to GREATER SAGE-GROUSE POPULATIONS

AS RELATED TO COT THREATS

A number of threats and risks to greater sage-grouse and their habitat have been identified during conservation planning efforts and 

assessments. Range wide issues were covered in listing decisions made by FWS in 2007 and 2010. This summary table describes

impacts to greater sage-grouse from BLM RMP decisions related to the identified threats.

In addition to the actions identified in the RMP alternatives and this table, the Montana/Dakotas Bureau of Land Management (BLM) 

Greater Sage-Grouse Mitigation Measures and Conservation Actions (Appendix AB), are a compilation of measures employed by the 

BLM to further mitigate impacts from surface disturbance in priority, restoration, and general sage-grouse habitat, in order to meet the 

Goals and Objectives set forward in the BLM National Sage-grouse Conservation Strategy and in individual land use plans.
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Appendix AB AB - 2 

SUMMARY of BIFO RMP IMPACTS to GREATER SAGE-GROUSE POPULATIONS AS RELATED TO COT THREATS

Threats are characterized as: Y= threat is present and widespread,

 L = threat present but localized, 

 N = threat is not known to be present, 

 U = Unknown.

Management Zone 1, Yellowstone Watershed Population1

Threats:

Isolated/ Small Size- N; Urbanization-N; Mining-N; Free-Roaming Equids-N; 

Sagebrush Elimination-L; Fire-L; Conifers-L; Recreation-L; 

Agriculture Conversion-Y; Weeds/ Annual Grasses-Y; Energy-Y; Infrastructure-Y; Grazing-Y;

Management Zone II, Wyoming Basin Population1

Threats:

Isolated/ Small Size- N; Agriculture Conversion-N; 

Sagebrush Elimination-L; Fire-L; Conifers-L; Weeds/ Annual Grasses-L; Mining-L; Free-Roaming Equids-L; Urbanization-L

Energy-Y; ; Infrastructure-Y; Grazing-Y; Recreation-Y; 

Wildlife Habitat - Management Common to Action Alternatives: 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. 

1-U.S. Fish and Wildlife Service. 2013. Greater Sage-grouse (Centrocercus urophasianus)

Conservation Objectives: Final Report. U.S. Fish and Wildlife Service, Denver, CO. February

2013. (Sage Grouse Threat Summary is from the COT Report.)
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AB AB - 3

COT Report Threat – Isolated/Small Populations, Agriculture, and Ex-urban Development1

Alternative A Alternative B Alternative C Alternative D

Acres delineated as PH 0 191,543 (154,140)2 191,543 (154,140)2 191,543 (154,140)2

Acres delineated as RH 0 63,437(45,555)2 63,437(45,555)2 63,437(45,555)2

Acres delineated as GH 0 116,452(78,575)2 116,452(78,575)2 116,452(78,575)2

Summary of Impacts to GRSG 

from Isolated/Small populations

Alternative A does not delineate any PH, RH, or GH. However, all action alternatives delineate PH, RH, and GH; constraints placed on 

other resources/uses are listed below and these vary by alternative. The action alternatives are in agreement with the following 

conservation measures identified in the COT report specific to PACs:

 Retain GRSG habitats within PACs.

 If PACs are lost to catastrophic events, implement appropriate restoration efforts. 

 Restore and rehabilitate degraded GRSG habitats in PACs.

Land Tenure disposal (acres)

Category III3(acres available) 

 

7,529

(2,088 acres identified for 

further study) 

 50 4,223

 

 170

Land Tenure: Retention Category 

I (acres)

26,616 acres (no Category I or II 

)

 68,300 

 108,184 

 80,060

Land Tenure: Retention Category 

II (acres)

26,616 acres (no Category I or II 

)

 365,804 

 321,747 

 353, 924

Summary of Impacts to GRSG from Agriculture/ Urbanization:

Across all action alternatives, the BLM would take advantage of opportunities to consolidate GRSG habitat. All Alternatives technically allow for disposal of lands; however, 

GRSG habitat would be considered in the analysis. The 170 acres identified for disposal in Alternative D are outside of GRSG habitat. 

Retention / Acquisition Criteria (Appendix J, J.2.2, J.2.3, pages 6, 7) identify areas for Special Status Wildlife Species (includes sage-grouse). 

 

1 Urbanization is listed as” Not Known to be Present” in the Yellowstone Watershed population, although it is listed as a , “Present but localized 

threat,” in Management Zone II, Wyoming Basin, in the COT Report threats list; however, the alternatives for BIFO contain actions under the realty program 

that would address this issue (e.g., no disposal of BLM-administered lands within PH). 2Larger acreage is BLM Administered Federal Mineral Estate, Acreage in 

parentheses are BLM Administered Surface.

3 Refer to Appendix J, pages J-3 and 4 for Land tenure Category descriptions.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AB AB - 4

The action alternatives are in agreement with the following conservation options identified in the COT report specific to ex-urban development:

 Acquire and manage GRSG habitat to maintain intact ecosystems.

While agricultural conversion is considered a wide spread threat to Greater Sage Grouse within the planning area, it is not occurring on BLM administered public lands in 

Greater Sage Grouse habitat. Future occurrences are unlikely given the land retention criteria presented in Appendix J. Also, due to the larger percentage of private lands 

in the Yellowstone population area, BLM considers Urbanization a greater threat in the Yellowstone population versus the Wyoming Basin population. The Wyoming Basin 

has a greater percentage of public lands that would not be available for Urbanization.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AB AB - 5

COT Report Threat – Energy and Mining

Alternative A Alternative B Alternative C Alternative D

Areas closed to fluid mineral

leasing –No Lease (acres) 39,730 302,713 65,891 72,915

Areas open to mineral leasing with 

NSO stipulation (acres) 32,595 28,110 64,135 263,185

Controlled Surface Use (CSU) 

(acres) 28,337 76,556 102,682 21,436

Timing Limitation (TL)-(acres) 308,116 249,460 316,602 315,317

Acres of long-term (2015-2030) /

1

short-term surface disturbance

(includes interim reclamation)- All 

Ownerships –Total Annual 

Disturbance

54/108 54/108 54/108 54/108

Acres of long-term /short-term1

(2010-2014) surface disturbance –

All Ownerships – Total Annual 

Disturbance

37.5/86 37.5/86 37.5/86 37.5/86

Federal Oil and Gas Wells – estimated 2-4 wells per year with short -term disturbance of 13.5-27 acres per year and long-term disturbance of 5.5-15.5 acres per year, when 

BLM interim reclamation guidelines are followed. 1

1-Data from “Billings/ Pompeys Pillar Reasonably Foreseeable Development Scenario.”

Leased Fluid Minerals

Restrictions on surface 

disturbance for leased fluid 

minerals

Lowest level of protection for 

GRSG in GH and PH

Highest level of protection for 

GRSG, RH, in PH

Moderate level of protection 

for GRSG in PH, RH, and GH

High level of protection for GRSG in 

PH, RH, and GH

Summary of Impacts to GRSG 

from Oil and Gas Development

Alternatives C, and D, are NSO for PH to leasing and Alternative B closes PH to leasing. Since most of the high development potential 

has already been leased, and due to the small amount of BLM minerals in the planning area, the surface disturbance acreages do not 

change among the alternatives (even between the alternatives that have no lease vs. the no-action).
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AB AB - 6

The action alternatives are in agreement with the following conservation measures identified in the COT report specific to Energy 

Development:

 Avoid energy development in PACs (Doherty et al. 2010). Identify areas where leasing is not acceptable,

 or not acceptable without stipulations for surface occupancy that maintains GRSG habitats.

 If avoidance is not possible within PACs due to pre-existing valid rights, adjacent development or split estate issues, 

development should only occur in non-habitat areas, including all appurtenant structures, with an adequate buffer that is 

sufficient to preclude impacts to GRSG habitat from noise and other human activities.

By limiting disturbances within PH (Alternative B, C and D), RH, and GH (Alternatives B, C, and D), the action alternatives would work 

towards the objective of reducing threats to intact shrubland. Alternative B would have more restrictions on fluid mineral development 

than Alternatives C and D, and Alternative A would have the fewest restrictions of all alternatives.

Mining

Alternative A Alternative B

 

Alternative C

 

Alternative D

Locatable minerals – areas closed 

and recommended for withdrawal

(acres) 

39,700 270,977

Recommend a withdrawal from 

locatable mineral entry in PH

36,955

Recommend a withdrawal

from locatable mineral entry in 

PH and GH

54,761

Mineral materials (acres)

(acres closed)

44,583 343,745

PH would be closed to mineral 

material sales

251,927

PH and GH would be closed 

to mineral material sales

272,122

PH would be closed to mineral 

material sales

Coal mining - areas closed to 

leasing (acres)

26,131 290,048 264,450 280,971

(only allowed if underground)

Summary of Impacts to GRSG 

from Mining

Alternatives B and D would be more protective to GRSG and GRSG habitat than Alternatives A and C. 

All of the action alternatives are in agreement with the following COT conservation options:

 Avoid new mining activities and/or any associated facilities within occupied habitat, including seasonal habitats.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AB AB - 7

COT Report Threat – Infrastructure

 Alternative A Alternative B Alternative C Alternative D

ROW avoidance areas (acres) 24,203

No ROW avoidance area for 

sage grouse

185,607

RH and GH would be avoidance 

areas

355,601

PH would be

Avoidance, RH and GH-ROWs 

would be allowed if suitable sagegrouse habitat can be maintained 

349,358

RH and GH-ROWs would be allowed if 

suitable sage-grouse habitat can be 

maintained 

ROW exclusion areas (acres) 44,014

No ROW exclusion area for 

sage grouse

211,384

PH would be a ROW exclusion 

area

39,491

RH and GH-ROWs would be allowed 

if suitable sage-grouse habitat can 

be maintained 

48,258

 RH and GH-ROWs would be allowed if 

suitable sage-grouse habitat can be 

maintained 

Travel management- routes within 

0.6 miles of leks

15% Closed- 7 miles 85% 

Open- 40 miles Limited = 0% 

 27%=Open, 13 miles 

47%=Closed, 22 miles 

25%=Limited, 12 miles

1%=Closed, 0.5miles 

93%=Open, 44 miles 

6%=Limited, 2.5 miles

6% =Closed- 1 mile 

41% =Open, 25 miles 

53%=Limited, 22 miles

Travel Management –routes 

within 4 miles of leks

11% =Closed, 89 miles 

84%=Open, 619 miles 

1%=Open with restrictions, 13 

miles 3%=Limited, 22 miles 

42%=Closed, 316 miles 

29%=Open 217 miles 

28%=Limited, 209 miles

2%=Closed, 4 miles 87% 

=Open, 690 miles 11%=

Limited, 48 miles 

8% =Closed, 48miles 

41%=Open, 451 miles 

51%= Limited, 236 miles

Travel Management Routes in 

Greater Sage-grouse PH’s

92% =Open, 326 miles 

8%= Closed, 32 miles 

27%=Open,97miles 

64%=Closed, 163miles 

27%=Limited, 99 miles 91% =Open, 359 miles 

9%=Closed, 19 miles

40% =Open, 102 miles 

60%= Closed*, 153 miles

*-Closed includes Open routes with 

restrictions including seasonal 

closures, etc.

Summary of Impacts to GRSG 

from Infrastructure

Alternatives B, C and D restrict ROWs in PH, which responds to the need (identified in the COT report) to stop population decline and 

habitat loss by eliminating activities known to negatively impact GRSG and their habitats through reduction in the threat of habitat loss, 

degradation and fragmentation.

The action alternatives are in agreement with the following conservation objectives/options identified in the COT report specific to 

infrastructure:

 Avoid development of infrastructure within PACs (objective).

 Avoid construction of these features in GRSG habitat, both within and outside of PACs.

 Restrictions limiting use of roads should be enforced.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AB AB - 8

 Motorized travel on BLM-administered land (outside of established TMA’s) would be limited to existing roads and trails.

Alternative A, in general, has the least protections for GRSG and GRSG habitat from development of infrastructure. All alternatives limit 

OHV use to existing roads and trails, but Alternative C also contains a 4-mile buffer from leks for route construction. All action 

alternatives have limitations on route construction and realignments to minimize impacts to GRSG.
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AB AB - 9

COT Report Threat - Fire

Alternative A Alternative B Alternative C Alternative D

Fire and Fuels

Fire and fuels management Prescribed burning would be 

implemented to manipulate 

vegetation on areas identified 

for treatment in the range, 

forestry, and wildlife programs. 

Prescribed fire would not be 

allowed in the Greater SageGrouse Habitat ACEC, Greater 

Sage-Grouse PPAs, or RAs. 

Prescribed fire would be 

allowed in Greater SageGrouse PPAs and RAs if the 

activity would benefit 

sagebrush communities (ex: 

achieve a diversity of age 

class). 

Prescribed fire would be allowed in 

Greater Sage-Grouse PPAs and RAs 

if the activity would benefit sagebrush 

communities (ex: achieve a diversity 

of age class). 

Wildfire

Fire operations Fire management is categorized 

into six (6) Fire Management 

Units (FMUs). 

5 FMUs where negative effects 

of wildfire and one FMU where 

wildfire is desired with 

significant implementation 

constraints.

Wildfires (natural ignitions) 

that occur within or adjacent to 

an area identified for 

vegetation or fuels treatment 

would be managed to meet 

the desired management 

objectives. 

Wildfire management 

(natural ignitions) for 

resource benefit not 

authorized.

Heavy equipment use 

not restricted, unless 

otherwise restricted 

(e.g. ACEC’s, WSA’s, 

etc.)

Wildfire management (natural 

ignitions) for resource benefit would 

be considered for the following 

areas: (5 ACEC’s and 4 WSA’s) 

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 
Billings and Pompeys Pillar National Monument 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Appendix AB AB - 10

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.

Summary of Impacts to GRSG 

from Fire Management

The alternatives are in agreement with the following conservation options from the COT report:

 Implement the BLM WO IM 2013-128 (Sage-Grouse Conservation in Fire Operations and Fuels Management) until a decision

is made on whether or not to incorporate the measure identified in the IM into RMPs. The measures in this IM are referenced

in Appendix AA (BMPs or Design Features) of this document.
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AB AB - 11

COT Report Threats - Grazing and Range Management Structures

Alternative A Alternative B Alternative C Alternative D 

Total acres permitted for livestock 

grazing: 

387,057 386,092 386,822 387,057

Available AUMs 54,873 54,873 54,873 54,873

Grazing Allotment Categories Maintain existing allotment 

management categories (see 

Appendix S)

Designate those allotments 

within or containing Sage-Grouse 

PPAs 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

Allotment Monitoring 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 sagegrouse PPAs / RAs) Contain 

impaired streams 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 

sage-grouse PPAs / RAs). Contain 

impaired streams. Contain nonfunctional 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.

Livestock Grazing – Management Common to All Alternatives:

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. sage-grouse/fence 

conflicts). 
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Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AB AB - 12

Site specific greater sage-grouse habitat and management objectives would be developed for BLM land within greater sage-grouse priority areas. These objectives 

would be incorporated into the respective allotment management plans or livestock grazing permits as appropriate. 

Summary of Impacts to GRSG 

from Grazing

GRSG habitat considerations within livestock grazing allotments would be similar across all action alternatives because the majority of 

allotments within Priority Habitat are meeting standards (Refer to Table 3.16). Under all alternatives, grazing would be managed to 

continue to achieve the standards of rangeland health. 

Include (at a minimum) indicators and measurements of structure/condition/composition of vegetation specific to achieving sage‐grouse 

habitat objectives (Doherty et al. 2011). If local/state seasonal habitat objectives are not available, use sage‐grouse habitat 

recommendations from Connelly et al. 2000b and Hagen et al. 2007. (Appendix AB, pg. AB-7)
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AB AB - 13

COT Report Threats - Sagebrush Elimination, Conifer Invasion, Invasive Species (Vegetation Management)

Alternative A Alternative B Alternative C Alternative D 

CConversion of Crested Wheatgrass toto 

Native Rangeland (29,727 acres Total)

Crested wheatgrass (160 acres) 

would be hayed or mechanically 

treated to increase forage 

production, improve range 

conditions, and reduce erosion. 

Fifteen percent (4,459 acres) of 

crested wheatgrass 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 sage-grouse PPAs, RAs and 

general habitat. 

Five percent (1,459 acres) of 

crested wheatgrass in high 

density sage grouse 

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 sage-grouse 

PPAs, RAs and general 

habitat. 

Eight percent (2,378 acres) of crested 

wheatgrass 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 sage-grouse 

PPAs, RAs and general habitat. 

Areas prioritized for vegetation 

treatments

Manage rangelands to meet 

health standards consistent with 

the Standards for Rangeland 

Health (Standards 1 and 5).

No specific habitat restoration or 

vegetation management actions 

in the Billings RMP for GRSG

Across all action alternatives, treatments would be prioritized to consider GRSG habitat requirements

-Within sage-grouse priority protection 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. 

-Identify priority treatment areas for conifer encroachment, including big game winter range, WUIs, 

current and historic sagebrush habitat, forest meadows and bighorn sheep habitat. 

-Treatment priorities would be established consistent with State of Montana Noxious Weed guidance. 

Summary of Impacts to GRSG The action alternatives are in agreement with the following conservation objective/conservation measures from the COT report:
Billings and Pompeys Pillar National Monument

Proposed Resource Management Plan and Final Environmental Impact Statement

Appendix AB AB - 14

from Vegetation Management  Avoid sagebrush removal or manipulation in GRSG breeding or wintering habitats (objective).

COT Report Threat - Recreation2

Alternative A Alternative B Alternative C Alternative D 

Issuance of SRPs -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.

-SRPs would only be allowed in priority habitat if they are consistent with the goals and objectives for that habitat or species. 

 

-Motorized off-road big game retrieval would be authorized by the Field Manager for individuals with a disabled hunter access permit 

(issued by FWP). Refer to “Travel Management” in “Infrastructure” section above.

Summary of Impacts to GRSG 

from Recreation

There are no areas open to off-road travel within the planning area in any alternative. All alternatives are in agreement with the following 

conservation option from the COT report:

 Close important GRSG use areas to off-road vehicle use.

 

2 The alternatives for BIFO do contain an action for SRPs. Travel Management is listed under Infrastructure section above.
Appendix AC AC - i

Appendix AC: 

 Billings Field Office and Pompeys Pillar National 

Monument Sign Plan
Appendix AC AC - ii

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Appendix AC AC - 17
MAPS

Shepherd Ah-Nei Recreation Area 2005

MAPS