United States 

Department of 

Agriculture 

Forest 

Service 

December 2013

Final Environmental

Impact Statement

Volume I

North Billings County Allotment

Management Plan Revisions

FEIS Vol. I North Billings County Allotment Management Plan Revisions

North Billings County Allotment Management Plan Revisions

Final Environmental Impact Statement

Volume I

Lead Agency: USDA Forest Service

Dakota Prairie Grasslands

Medora Ranger District

Responsible Official: Dennis D. Neitzke

Grasslands Supervisor

1200 Missouri Ave

Bismarck, ND 58504

For information contact: Nickole Dahl, Project Leader

Medora Ranger District

99 23rd Ave W. Suite B

Dickinson, ND 58601

701-227-7800

Abstract: This Final Environmental Impact Statement (FEIS) summarizes the North Billings 

County Allotment Management Plan Revisions project. It describes the purpose and need for the 

project, issues related to the project, alternatives considered, and the effects of each alternative

on the major resource concerns and issues. The purpose of this project is to continue livestock 

grazing while meeting or moving toward the goals and objectives of the Dakota Prairie 

Grasslands Land and Resource Management Plan (Grasslands Plan). Significant issues identified 

for the project include, riparian conditions, herbaceous structure, woody draws, seral condition, 

and economics. Alternative 1 proposes the cessation of livestock grazing; Alternative 2 proposes 

to maintain existing management; Alternative 3 proposes to continue livestock grazing in an 

environmentally acceptable manner using an adaptive management approach and a variety of 

structural and nonstructural management practices. Alternative 3A was added to the SDEIS in 

response to public comment on the DEIS and is now part of the FEIS. It proposes the same 

adaptive management approach but modifies the proposed action by adding or deleting 

management actions in response to public comment. Alternative 4 is also adaptive management 

based but utilizes some initial action nonstructural practices not utilized in the other alternatives.

The effects of each alternative are described to compare and contrast the alternatives.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Table of Contents

LIST OF TABLES .....................................................................................................................................................IV

LIST OF FIGURES....................................................................................................................................................VI

SUMMARY OF THE FINAL ENVIRONMENTAL IMPACT STATEMENT .........................................................................I

INTRODUCTION...............................................................................................................................................................I

PURPOSE AND NEED......................................................................................................................................................IV

DECISION FRAMEWORK................................................................................................................................................. VII

PUBLIC INVOLVEMENT .................................................................................................................................................. VII

KEY ISSUES .................................................................................................................................................................. IX

ALTERNATIVES CONSIDERED IN DETAIL .............................................................................................................................XIII

ALTERNATIVE 1 ...........................................................................................................................................................XIII

ALTERNATIVE 2 .......................................................................................................................................................... XIV

ALTERNATIVE 3 .......................................................................................................................................................... XIV

ALTERNATIVE 3A........................................................................................................................................................XVII

ALTERNATIVE 4 .........................................................................................................................................................XVIII

PREFERRED ALTERNATIVE ............................................................................................................................................XVIII

DESIGN CRITERIA COMMON TO ACTION ALTERNATIVES.......................................................................................................XIX

MONITORING.............................................................................................................................................................. XX

IMPLEMENTATION (SHORT-TERM) MONITORING ...............................................................................................................XXI

USDA Non-Discrimination Policy

The U.S. Department of Agriculture (USDA) prohibits discrimination against its customers, 

employees, and applicants for employment on the bases of race, color, national origin, age, 

disability, sex, gender identity, religion, reprisal, and where applicable, political beliefs, marital 

status, familial or parental status, sexual orientation, or all or part of an individual’s income is 

derived from any public assistance program, or protected genetic information in employment or in 

any program or activity conducted or funded by the Department. (Not all prohibited bases will 

apply to all programs and/or employment activities.) 

Persons with Disabilities

Individuals who are deaf, hard of hearing or have speech disabilities and you wish to file either an 

EEO or program complaint please contact USDA through the Federal Relay Service at (800) 877–

8339 or (800) 845–6136 (in Spanish). Persons with disabilities who wish to file a program 

complaint, please see information above on how to contact us by mail directly or by email. If you 

require alternative means of communication for program information (e.g., Braille, large print, 

audiotape, etc.) please contact USDA’s TARGET Center at (202) 720–2600 (voice and TDD)

Data Accuracy - The Forest Service uses the most current and complete data available. GIS 

data and product accuracy may vary. They may be developed from sources of differing 

accuracy, accurate only at certain scales, based on modeling or interpretation, incomplete 

while being created or revised, etc. Using GIS products for purposes other than those for 

which they were created may yield inaccurate or misleading results. The Forest Service 

reserves the right to correct, update, modify, or replace GIS products without notification. For 

more information, contact: Dakota Prairie Grasslands, 240 W. Century Ave, Bismarck, ND 

58503; (701) 250-4443.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

ii | Summary

EFFECTIVENESS (LONG-TERM TREND) MONITORING..........................................................................................................XXII

TRIGGER POINTS........................................................................................................................................................XXIII

SUMMARY COMPARISON OF ALTERNATIVES ....................................................................................................................XXIII

CHAPTER 1 PURPOSE OF AND NEED FOR ACTION ..................................................................................................1

INTRODUCTION..............................................................................................................................................................1

OVERVIEW....................................................................................................................................................................2

HISTORIC AND LEGAL FRAMEWORK ...................................................................................................................................5

GRASSLANDS PLAN DIRECTION SPECIFIC TO PROJECT AREA ....................................................................................................7

MANAGEMENT AREA 1.31: NONMOTORIZED BACKCOUNTRY RECREATION.............................................................................10

MANAGEMENT AREA 2.1: SPECIAL INTEREST AREAS...........................................................................................................10

MANAGEMENT AREA 2.2: RESEARCH NATURAL AREAS.......................................................................................................10

MANAGEMENT AREAS 3.51A: BIGHORN SHEEP, AND 3.51B: BIGHORN SHEEP HABITAT WITH NON-FEDERAL MINERAL OWNERSHIP

................................................................................................................................................................................10

MANAGEMENT AREA 3.65: RANGELANDS WITH DIVERSE NATURAL APPEARING LANDSCAPES ....................................................10

MANAGEMENT AREA 4.22: RIVER AND TRAVEL CORRIDORS ................................................................................................11

MANAGEMENT AREA 6.1: RANGELAND WITH BROAD RESOURCE EMPHASIS ...........................................................................11

PURPOSE AND NEED.....................................................................................................................................................11

PROPOSED ACTION ......................................................................................................................................................15

ADAPTIVE MANAGEMENT..............................................................................................................................................15

SCOPE OF THE PROPOSAL ..............................................................................................................................................17

GEOGRAPHIC SCOPE.....................................................................................................................................................17

TEMPORAL SCOPE........................................................................................................................................................17

ADMINISTRATIVE SCOPE................................................................................................................................................17

DECISION FRAMEWORK.................................................................................................................................................19

TIERED AND REFERENCE DOCUMENTS..............................................................................................................................19

PUBLIC INVOLVEMENT ..................................................................................................................................................20

KEY ISSUES .................................................................................................................................................................21

ISSUES ELIMINATED FROM DETAILED STUDY......................................................................................................................27

ARCHEOLOGY..............................................................................................................................................................27

NOXIOUS WEEDS.........................................................................................................................................................29

THREATENED AND ENDANGERED PLANT SPECIES................................................................................................................30

SENSITIVE PLANT SPECIES ..............................................................................................................................................30

RECREATION ...............................................................................................................................................................31

THREATENED AND ENDANGERED WILDLIFE SPECIES............................................................................................................33

SENSITIVE SPECIES, MANAGEMENT INDICATOR SPECIES (MIS), RAPTORS ...............................................................................33

SOILS.........................................................................................................................................................................36

SOIL CAPABILITY ..........................................................................................................................................................38

SOIL PRODUCTIVITY......................................................................................................................................................40

CLIMATE CHANGE ........................................................................................................................................................40

WATER QUALITY..........................................................................................................................................................42

CHAPTER 2 ALTERNATIVES, INCLUDING THE PROPOSED ACTION......................................................................... 44

INTRODUCTION............................................................................................................................................................44

ALTERNATIVES CONSIDERED IN DETAIL .............................................................................................................................44

ALTERNATIVE 1 ...........................................................................................................................................................44

ALTERNATIVE 2 ...........................................................................................................................................................45

ALTERNATIVE 3 ...........................................................................................................................................................45

ALTERNATIVE 3A.........................................................................................................................................................47

ALTERNATIVE 4 ...........................................................................................................................................................49

PREFERRED ALTERNATIVE ..............................................................................................................................................49

DESIGN CRITERIA COMMON TO ACTION ALTERNATIVES.......................................................................................................49

ALTERNATIVES CONSIDERED BUT DROPPED FROM DETAILED ANALYSIS ...................................................................................51
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Summary | iii

MONITORING..............................................................................................................................................................54

IMPLEMENTATION (SHORT-TERM) MONITORING ...............................................................................................................55

EFFECTIVENESS (LONG-TERM TREND) MONITORING...........................................................................................................55

WATER QUALITY..........................................................................................................................................................56

TRIGGER POINTS..........................................................................................................................................................57

RIPARIAN ...................................................................................................................................................................57

GREEN ASH WOODY DRAWS .........................................................................................................................................59

HERBACEOUS STRUCTURE..............................................................................................................................................60

SERAL STAGES (PLANT COMPOSITION).............................................................................................................................61

COMPARISON OF ALTERNATIVES .....................................................................................................................................62

CHAPTER 3 PART 1 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES ..................................... 73

INTRODUCTION............................................................................................................................................................73

PROJECT AREA ............................................................................................................................................................73

GENERAL SETTING........................................................................................................................................................73

PAST, PRESENT, AND REASONABLY FORESEEABLE ACTIONS ..................................................................................................76

PAST ACTIONS.............................................................................................................................................................76

PRESENT AND REASONABLY FORESEEABLE ACTIONS............................................................................................................80

SUMMARY OF PAST, PRESENT, AND REASONABLY FORESEEABLE ACTIONS...............................................................................82

AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES ........................................................................................85

RANGE.......................................................................................................................................................................85

INTRODUCTION............................................................................................................................................................85

SPATIAL AND TEMPORAL SETTING ...................................................................................................................................86

METHODOLOGY...........................................................................................................................................................86

AFFECTED ENVIRONMENT—RANGE ................................................................................................................................93

ENVIRONMENTAL CONSEQUENCES—RANGE ...................................................................................................................101

CONSISTENCY WITH GRASSLANDS PLAN—RANGE ............................................................................................................108

RIPARIAN .................................................................................................................................................................111

INTRODUCTION..........................................................................................................................................................111

SPATIAL AND TEMPORAL SETTING .................................................................................................................................112

METHODOLOGY.........................................................................................................................................................113

AFFECTED ENVIRONMENT—RIPARIAN ...........................................................................................................................115

ENVIRONMENTAL CONSEQUENCES—RIPARIAN................................................................................................................120

CONSISTENCY WITH GRASSLANDS PLAN—RIPARIAN .........................................................................................................128

WOODY DRAWS ........................................................................................................................................................130

INTRODUCTION..........................................................................................................................................................130

SPATIAL AND TEMPORAL SETTING .................................................................................................................................132

METHODOLOGY.........................................................................................................................................................132

AFFECTED ENVIRONMENT—WOODY DRAWS..................................................................................................................135

ENVIRONMENTAL CONSEQUENCES—WOODY DRAWS ......................................................................................................148

CONSISTENCY WITH GRASSLANDS PLAN—WOODY DRAWS................................................................................................165

HERBACEOUS STRUCTURE............................................................................................................................................166

INTRODUCTION..........................................................................................................................................................166

SPATIAL AND TEMPORAL SETTING .................................................................................................................................166

METHODOLOGY.........................................................................................................................................................167

AFFECTED ENVIRONMENT—HERBACEOUS STRUCTURE .....................................................................................................169

ENVIRONMENTAL CONSEQUENCES—HERBACEOUS STRUCTURE ..........................................................................................178

CONSISTENCY WITH GRASSLANDS PLAN—HERBACEOUS STRUCTURE ...................................................................................186

SERAL STAGES ...........................................................................................................................................................186

INTRODUCTION..........................................................................................................................................................186

SPATIAL AND TEMPORAL SETTING .................................................................................................................................187

METHODOLOGY.........................................................................................................................................................187

AFFECTED ENVIRONMENT—SERAL STAGES.....................................................................................................................192
FEIS Vol. I North Billings County Allotment Management Plan Revisions

iv | Summary

ENVIRONMENTAL CONSEQUENCES—SERAL STAGES .........................................................................................................194

CONSISTENCY WITH GRASSLANDS PLAN—SERAL STAGES...................................................................................................210

SHARP-TAILED GROUSE...............................................................................................................................................210

INTRODUCTION..........................................................................................................................................................210

SPATIAL AND TEMPORAL SETTING .................................................................................................................................210

METHODOLOGY.........................................................................................................................................................211

AFFECTED ENVIRONMENT—SHARP-TAILED GROUSE.........................................................................................................211

ENVIRONMENTAL CONSEQUENCES—SHARP-TAILED GROUSE .............................................................................................214

CONSISTENCY WITH GRASSLANDS PLAN—SHARP-TAILED GROUSE.......................................................................................221

ECONOMICS..............................................................................................................................................................224

INTRODUCTION..........................................................................................................................................................224

SPATIAL AND TEMPORAL SETTING .................................................................................................................................225

METHODOLOGY.........................................................................................................................................................226

AFFECTED ENVIRONMENT—ECONOMICS .......................................................................................................................233

ENVIRONMENTAL CONSEQUENCES—ECONOMICS ............................................................................................................243

INDEX ................................................................................................................................................................ 261

VOLUME II – CHAPTER 3 PART 2

VOLUME III – CHAPTER 4, GLOSSARY, LITERATURE CITED, INDEX, APPENDICES

List of Tables

TABLE S.1 — LIVESTOCK GRAZING ALLOTMENTS INCLUDED IN THE PROPOSED ACTION.......................................................................I

TABLE S.2 — GRASSLANDS PLAN DESIRED CONDITIONS, EXISTING CONDITIONS, AND NEED FOR ACTION ..............................................V

TABLE S.3 — GRAZING MANAGEMENT TOOLBOX.................................................................................................................. XVI

TABLE S.4 — RECOMMENDATIONS INCORPORATED INTO ALTERNATIVE 3A ................................................................................XVII

TABLE S.5 — ACTIONS NOT INCLUDED IN ALTERNATIVE 3A ....................................................................................................XVIII

TABLE S.6 — DESIGN CRITERIA ...........................................................................................................................................XIX

TABLE S.7 — EFFECTIVENESS MONITORING SCHEDULE............................................................................................................XXII

TABLE S.8 — SUMMARY OF HOW THE ALTERNATIVES RESPOND TO THE PURPOSE AND NEED..........................................................XXIV

TABLE S.9 — KEY ISSUE COMPARISON OF THE ALTERNATIVES ...................................................................................................XXV

TABLE S.10 — COMPARISON OF SUMMER AUTHORIZED USE BY ALTERNATIVE.............................................................................XXX

TABLE S.11 — SUMMARY OF INITIAL ACTIONS BY ALTERNATIVE .............................................................................................. XXXII

TABLE 1.1 — LIVESTOCK GRAZING ALLOTMENTS INCLUDED IN THE PROPOSED ACTION......................................................................2

TABLE 1.2 — MANAGEMENT AREA ACREAGE IN THE PROJECT AREA..............................................................................................8

TABLE 1.3 — GRASSLANDS PLAN DESIRED CONDITIONS, EXISTING CONDITIONS, AND NEED FOR ACTION ............................................13

TABLE 1.4 – SUMMARY OF SENSITIVE SPECIES, MANAGEMENT INDICATOR SPECIES (MIS), AND RAPTOR INFORMATION IN PROJECT AREA .33

TABLE 1.5 – SUMMARY OF TOTAL DSD AREA, TOTAL ACRES OF DSD, AND TOTAL PERCENTAGE OF DSD............................................37
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Summary | v

TABLE 1.6 – SOILS STABILITY AND HYDROLOGIC FUNCTION OF SOILS, SUMMARY FOR 2008 AND 2009 FIELD SEASONS; PERCENTAGE OF 

SAMPLED ECOLOGICAL SITES BY CATEGORY BY ALLOTMENT...............................................................................................39

TABLE 2.1 — GRAZING MANAGEMENT TOOLBOX ..................................................................................................................46

TABLE 2.2 — RECOMMENDATIONS INCORPORATED INTO ALTERNATIVE 3A.................................................................................48

TABLE 2.3 — ACTIONS NOT INCLUDED IN ALTERNATIVE 3A......................................................................................................48

TABLE 2.4 — DESIGN CRITERIA ...........................................................................................................................................49

TABLE 2.5 — EFFECTIVENESS MONITORING SCHEDULE.............................................................................................................56

TABLE 2.7 – WOODY DRAW TRIGGER POINTS.........................................................................................................................60

TABLE 2.8 — HERBACEOUS STRUCTURE TRIGGER POINTS*........................................................................................................61

TABLE 2.9 — TRIGGER POINTS FOR SERAL STAGES...................................................................................................................62

TABLE 2.10 — SUMMARY OF HOW THE ALTERNATIVES RESPOND TO THE PURPOSE AND NEED .........................................................62

TABLE 2.11 — KEY ISSUE COMPARISON OF THE ALTERNATIVES ..................................................................................................64

TABLE 2.12 — COMPARISON OF SUMMER AUTHORIZED USE BY ALTERNATIVE .............................................................................69

TABLE 2.13 — SUMMARY OF INITIAL ACTIONS BY ALTERNATIVE.................................................................................................71

TABLE 3.1 — SUMMARY OF ACRES AND AUMS ASSOCIATED WITH ACTIVE AND RECLAIMED OIL AND GAS PADS AND ROADS IN THE PROJECT 

AREA ....................................................................................................................................................................80

TABLE 3.2 — SUMMARY OF PAST, PRESENT, AND REASONABLY FORESEEABLE FUTURE ACTIONS CONSIDERED IN THE CUMULATIVE EFFECTS 

ANALYSIS ...............................................................................................................................................................83

TABLE 3.3 — SAMPLED PLOTS IN MLRA 54 AND 58C ............................................................................................................91

TABLE 3.4 — COMPARISON OF ALTERNATIVES TO 3-YEAR AVERAGE MGA SUMMER PERMITTED USE................................................96

TABLE 3.5 — COMPARISON OF ALTERNATIVES TO PREFERENCE .................................................................................................98

TABLE 3.6 — AUTHORIZED USE UNDER ALTERNATIVE 2.........................................................................................................102

TABLE 3.7 — AUTHORIZED USE UNDER ALTERNATIVE 4.........................................................................................................104

TABLE 3.8 — PFC FUNCTIONALITY RATINGS AND DEFINITIONS ................................................................................................114

TABLE 3.9 — RIPARIAN FUNCTIONALITY RATINGS (MILES AND PERCENT MILES OF CHANNEL) FOR INTERMITTENT STREAMS IN THE NORTH 

BILLINGS PROJECT AREA..........................................................................................................................................116

TABLE 3.10 — RIPARIAN FUNCTIONALITY RATINGS FOR INTERMITTENT STREAMS IN THE N. BILLINGS PROJECT AREA ..........................118

TABLE 3.11 — NUMBER OF STREAM REACHES THAT WOULD IMPROVE BY ACTION ALTERNATIVE ....................................................121

TABLE 3.12 — COMPARISON OF ALTERNATIVES TO MGA 3-YEAR AVERAGE SUMMER PERMITTED USE FOR ALLOTMENTS WITH STREAMS 

REACHES RATED AS FAR-NA, FAR-D, OR NF .............................................................................................................124

TABLE 3.13 — PERCENTAGE OF SAMPLED WOODY DRAWS RATED AS HEALTHY, UNHEALTHY, OR AT RISK BY ALLOTMENT ...................135

TABLE 3.14 — CHARACTERISTICS OF TREE AND SHRUB CANOPY COVER AMONG HEALTHY, AT RISK, AND UNHEALTHY SITES ................138

TABLE 3.15 — TREE DENSITY PER ACRE BY SIZE CLASSES AMONG HEALTHY, AT RISK, AND UNHEALTHY SITES....................................139

TABLE 3.16 — SUMMARY OF EFFECTS RATIONALE BY ALLOTMENT FOR WOODY DRAWS, ALTERNATIVE 3 .........................................150

TABLE 3.17 — SUMMARY OF EFFECTS RATIONALE BY ALLOTMENT FOR WOODY DRAWS, ALTERNATIVE 3A.......................................155

TABLE 3.18 — SUMMARY OF EFFECTS RATIONALE BY ALLOTMENT FOR WOODY DRAWS, ALTERNATIVE 4 .........................................157

TABLE 3.19 — APPROXIMATE ACRES OF THE BIOLOGICALLY CAPABLE HABITAT TYPES IN THE PROJECT AREA ......................................168

TABLE 3.20 — DISTRIBUTION OF ALLOTMENTS IN RELATION TO GRASSLANDS PLAN STRUCTURE OBJECTIVES ....................................173

TABLE 3.21 — COMPARISON OF TRANSECT AND STATION AVERAGES AND GRASSLANDS PLAN STRUCTURE OBJECTIVES FOR 2004 AND 

2005 SAMPLE YEARS .............................................................................................................................................175

TABLE 3.22 — GRASSLANDS PLAN STRUCTURE OBJECTIVES FOR THE ROLLING PRAIRIE AND BADLANDS GEOGRAPHIC AREAS...............176

TABLE 3.23 — SUMMARY OF VOR TRANSECTS SUPPORTING HIGH STRUCTURE BY BIOLOGICALLY CAPABLE HABITAT TYPE ON THE MEDORA 

RANGER DISTRICT .................................................................................................................................................176

TABLE 3.24 — SUMMARY OF VOR TRANSECTS SUPPORTING HIGH STRUCTURE ON BIOLOGICALLY CAPABLE HABITAT TYPES IN THE NE

MCKENZIE FEIS PROJECT AREA ................................................................................................................................177

TABLE 3.25 — SUMMARY OF PREDICTED EFFECTS ON HIGH STRUCTURE AND STRUCTURE OBJECTIVES IN GENERAL, ALTERNATIVE 3 ......180

TABLE 3.26 — SUMMARY OF PREDICTED EFFECTS ON HIGH STRUCTURE AND STRUCTURE OBJECTIVES IN GENERAL, ALTERNATIVE 4 ......181

TABLE 3.27 — SERAL STAGE PERCENTAGES BY METHODOLOGY ...............................................................................................193

TABLE 3.28 — EFFECTS OF PROPOSED ACTIONS ON CURRENT TRENDS OF PLANT COMPOSITION UNDER ALTERNATIVE 3......................197

TABLE 3.29 — EFFECTS OF PROPOSED INITIAL ACTIONS ON PLANT COMPOSITION UNDER ALTERNATIVE 3A......................................201

TABLE 3.31 — (LEFT) 2004 AND 2005 TRANSECT HERBACEOUS STRUCTURE DISTRIBUTION WITHIN THE PROJECT AREA .....................212

TABLE 3.32 — (RIGHT) 2004 AND 2005 STATION HERBACEOUS STRUCTURE DISTRIBUTION WITHIN THE PROJECT AREA.....................212

TABLE 3.33 — 2004 AND 2005 VOR STRUCTURE DISTRIBUTION WITHIN 1 MILE OF LEKS WITHIN THE PROJECT AREA........................213
FEIS Vol. I North Billings County Allotment Management Plan Revisions

vi | Summary

TABLE 3.34 — SUMMARY OF PROJECTED EFFECTS, BY ALLOTMENT, FOR ALTERNATIVE 3 INITIAL ACTIONS ON THE NESTING AND BROODING 

HABITAT OF SHARP-TAILED GROUSE...........................................................................................................................216

TABLE 3.35 — SUMMARY OF ALTERNATIVE 4 EFFECTS ON SHARP-TAILED GROUSE NESTING AND BROODING HABITAT WITHIN 1 MILE OF 

KNOWN LEKS ........................................................................................................................................................217

TABLE 3.36 — DEMOGRAPHIC OVERVIEW FOR NORTH DAKOTA AND BILLINGS COUNTY, ND........................................................234

TABLE 3.37 — SUMMARY OF OCCUPATIONS IN NORTH DAKOTA AND BILLINGS COUNTY, ND, 2000 .............................................235

TABLE 3.38 — SUMMARY OF INDUSTRIES IN NORTH DAKOTA AND BILLINGS COUNTY, ND, 2000.................................................235

TABLE 3.39 — ANNUAL PART- AND FULL-TIME EMPLOYMENT CONTRIBUTION* FROM THE NORTH BILLINGS PROJECT AREA ................237

TABLE 3.40 — ANNUAL LABOR INCOME CONTRIBUTION* FROM THE NORTH BILLINGS PROJECT AREA.............................................238

TABLE 3.41 — AVERAGE ANNUAL RECEIPTS AND PAYMENTS RETURNED TO PROJECT AREA COUNTY ................................................240

TABLE 3.42 — PROPOSED REDUCTION SCHEDULE FOR AUTHORIZED FEDERAL AMS .....................................................................244

TABLE 3.43 — ANNUAL PART- AND FULL-TIME EMPLOYMENT AND LABOR INCOME CONTRIBUTIONS FROM FEDERAL FORAGE, ALTERNATIVE 

3* .....................................................................................................................................................................245

TABLE 3.44 — THE ECONOMIC IMPACTS OF ALTERNATIVE 3, CONSIDERING THE ECONOMIC CONTRIBUTION OF ALL COWS, YEARLINGS, AND 

CALVES THAT SPEND TIME IN THE PROJECT AREA AT SOME POINT IN THE YEAR* ..................................................................246

TABLE 3.45 — ANNUAL PART- AND FULL-TIME EMPLOYMENT AND LABOR INCOME CONTRIBUTIONS FROM FEDERAL FORAGE, ALTERNATIVE 

4* .....................................................................................................................................................................248

TABLE 3.46 — ANNUAL PART- AND FULL-TIME EMPLOYMENT AND LABOR INCOME CONTRIBUTIONS FROM FEDERAL FORAGE BASED ON THE 

ECONOMIC CONTRIBUTION OF ALL COWS, YEARLINGS AND CALVES THAT SPEND TIME IN THE PROJECT AT SOME POINT IN THE YEAR,

ALTERNATIVE 4*...................................................................................................................................................249

TABLE 3.47 — EFFECTS OF ALTERNATIVE 4 ON GRAZING FEE COLLECTIONS................................................................................249

List of Figures

FIGURE S.1 — PROJECT AREA. ..............................................................................................................................................II

FIGURE S.2 — GRAZING ALLOTMENT LOCATIONS..................................................................................................................... III

FIGURE 1.1 — PROJECT AREA...............................................................................................................................................3

FIGURE 1.2 — GRAZING ALLOTMENT LOCATIONS. ....................................................................................................................4

FIGURE 1.3 — MANAGEMENT AREAS LOCATED IN THE PROJECT AREA...........................................................................................9

FIGURE 1.4 — ADAPTIVE MANAGEMENT APPROACH FOR THE ACTION ALTERNATIVES.....................................................................18

FIGURE 3.1 — FENCELINE CONTRAST DISPLAYING RAPID TRANSITION IN RIPARIAN FUNCTIONALITY RATING.......................................113

FIGURE 3.2 — SURVEYS STREAMS AND FUNCTIONALITY RATINGS. ............................................................................................117

FIGURE 3.3 — HEALTHY WOODY DRAW CONDITIONS. ...........................................................................................................136

FIGURE 3.4 — AT RISK WOODY DRAW CONDITIONS..............................................................................................................137

FIGURE 3.5 — UNHEALTHY WOODY DRAW CONDITIONS. .......................................................................................................137

FIGURE 3.6 — DECADENT BOX ELDER TREE WITH MORE THAN 100 BASAL SPROUTS THAT HAVE BEEN REGULARLY BROWSED. ..............138

FIGURE 3.7 — (LEFT) EPHEMERAL WATER SOURCES WITH TYPICAL LIVESTOCK TRAMPLING............................................................139

FIGURE 3.8 — (RIGHT) INTERMITTENT WATER SOURCES WITH TYPICAL LIVESTOCK TRAMPLING. .....................................................139

FIGURE 3.9 — YOUNG GREEN ASH ESTABLISHING IMMEDIATELY DOWNSTREAM OF A 10- TO 15-FOOT HEADCUT AND THE TERMINUS OF 

THE EXISTING WOODY DRAW. ..................................................................................................................................140

FIGURE 3.10 — TREE DENSITY BY SIZE CLASS AMONG HEALTHY, AT RISK AND UNHEALTHY WOODY DRAWS. ....................................142

FIGURE 3.11 — AVERAGE SAPLING DENSITIES BETWEEN 1993 AND 2008. ...............................................................................142

FIGURE 3.12 — AVERAGE PERCENTAGE CANOPY COVER OF CHOKECHERRY AND WESTERN SNOWBERRY BETWEEN 1993 AND 2008. ....143

FIGURE 3.14 — 1996 TO 2001 VOR TRANSECT DATA FROM NFS LANDS, BILLINGS COUNTY, ND................................................170

FIGURE 3.15 — 1996 TO 1999 VOR TRANSECT DISTRIBUTION WITHIN PROJECT AREA. THE NUMBERS IN PARENTHESES ARE THE NUMBER

OF TRANSECTS SAMPLED IN THAT YEAR. .....................................................................................................................171

FIGURE 3.16 — HERBACEOUS DOMINATED STRUCTURE TRANSECT RESULTS EXPRESSED AS PERCENTAGES FOR THE PROJECT AREA (2004

AND 2005 RESULTS) AND GRASSLANDS PLAN OBJECTIVES.............................................................................................172
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Summary | vii

FIGURE 3.17 — 2004 AND 2005 VOR DISTRIBUTION OF STATIONS WITHIN HERBACEOUS DOMINATED TRANSECTS WITHIN THE PROJECT 

AREA. .................................................................................................................................................................174
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Summary | i

Summary of the Final Environmental Impact Statement

INTRODUCTION

The North Billings County Allotment Management Plan Revisions (North Billings) project area 

is located on the Medora Ranger District, which is part of the Dakota Prairie Grasslands. The 

Medora Ranger District encompasses National Forest System (NFS) lands located in Billings, 

Golden Valley, and Slope Counties. The project area is located in northern Billings County, 

North Dakota, and a small portion of one township in northeastern Golden Valley County, North 

Dakota. It encompasses all or portions of NFS lands located in T144N, R99W, R100W, R101W, 

and R102W; T143N, R99W, R100W, R101W, R102W, R103W; and T142N, R100W and, 

R101W (Figure S.1).

There are 43 livestock grazing allotments within the project area.

1

Table S.1 identifies the 

grazing allotments associated with the proposed action. Figure S.2 displays the location of the 

allotments within the project area. 

Table S.1 — Livestock grazing allotments included in the proposed action

126 127 128 129 130 131 132A 132H 133 133D5 134

135 136/139 140 141 142 158 220 221 230 237 239

240 241 243 244 248 249 256 258 272 277 278

281 282 283 286 287 288 289 300 301 302

These allotments cover approximately 87,262 acres of NFS land with approximately 70,871 of 

those acres being capable of sustaining grazing, as determined by the 2001 Northern Great Plains 

FEIS. In relation to grazing, the 2001 Dakota Prairie Grasslands Land and Resource 

Management Plan (Grasslands Plan) characterizes the land base as capable or incapable of 

supporting grazing activity.

The Forest Service (FS) proposes to continue to permit livestock grazing on these allotments 

through a program of actions that maintains and/or moves resource conditions towards meeting 

the Grasslands Plan objectives and desired on-the-ground conditions.

 

1 When scoped, this project proposal contained 46 grazing allotments. Since that time, the NFS lands contained 

within allotments 224, 228, 229, and pasture 4 in allotment 127 have been conveyed from federal ownership to the 

private sector. The land conveyance was done in compliance with Sec. 424. (a)Land Sale Authorization of the 

Consolidated Appropriations Act of 2008. Section 424 of the Act directs selling federal lands to offset the private 

acreage gained by the federal government in the purchase of the Elkhorn Ranch.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

ii | Summary

Figure S.1 — Project area.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Summary | iii

Figure S.2 — Grazing allotment locations.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

iv | Summary

PURPOSE AND NEED

The Forest Service rangeland allotment management process calls for periodic reviews of 

allotment conditions and management practices. Regulation 36 CFR 222.2(c) states, “Forage 

producing National Forest System lands will be managed for livestock grazing and the allotment 

management plans will be prepared consistent with land management plans.” All of the 

allotments in this analysis are due for environmental review. The Rescission Act of 1995 (P.L. 

104-19, Section 504) requires that all grazing allotments on NFS lands undergo NEPA analysis 

prior to revision of existing allotment management plans. The underlying needs for this proposal 

include:

 Some resources are not at Desired Conditions as identified by the Grasslands Plan. There 

is a need to meet or move toward Desired Conditions for those affected resources in 

accordance with Grasslands Plan direction (pp 1-2, 1-3)2 while allowing grazing on 

suitable lands and supporting local families and communities. 

 There are overall needs (a) for greater management flexibility to meet Grasslands Plan 

resource goals and objectives and to cope with fluctuations in environmental and social 

conditions including, but not limited to, annual changes in weather; (b) to be responsive 

to permittee requests for reasonable operational adjustments; and (c) to respond to 

unforeseen or changing issues. 

The project specific need for action is created by the disparity between what is present (existing 

condition) and what is wanted (desired condition) of a resource. The specific action needs for the 

allotments in this analysis are summarized in Chapter 3 of this FEIS. Table S.2 below identifies 

which resources are of concern to this analysis.

 

2 A requirement of the Demonstration Project is to “determine if Plan Goals and Objectives are achievable or need 

modification, and monitor progress towards meeting the resource objectives”. The analysis completed for North 

Billings determined that the Plan goals and objectives are achievable; therefore, modification to the Plan is not 

needed and has not been incorporated. However, monitoring progress towards meeting the resource objectives is an 

integral component of the proposed action. 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Summary | v

Table S.2 — Grasslands Plan desired conditions, existing conditions,

and need for action

Grasslands Plan

Desired Condition Existing Condition Need for Action

--------------Riparian/Streams--------------

The Grasslands Plan identifies an objective of 

meeting or moving towards Proper 

Functioning Condition on 80 percent of 

perennial streams. It also directs that corrective 

action on Functional-At Risk and 

Nonfunctional streams be initiated. Streams in 

this case include intermittent streams. 

Within the project area approximately 56.4 

miles of stream reaches associated with 11

intermittent streams were surveyed in 2004, 

2005, 2006, and 2007 to determine their 

condition. Of the 56.4 miles of stream reaches 

surveyed, 28.6 miles (51 percent) were at 

Proper Functioning Condition (PFC); 2.5 miles 

(4 percent) were Functional-At Risk-Upward 

Trend (FAR-U); 3.3 miles (6 percent) were 

Functional-At Risk-Trend Not Apparent

(FAR-NA); 2.9 miles (5 percent) were 

Functional-At Risk-Downward Trend (FARD); and 19.1 miles (34 percent) were 

Nonfunctional (NF).

The only perennial stream in the project area is 

a small portion of the Little Missouri River. A 

field review of this portion of the river in 2010 

indicated that there were no riparian concerns.

There is a need to improve riparian and/or 

stream conditions for those intermittent stream 

reaches identified as Functional-At RiskDownward Trend or Nonfunctional (21.3 

miles of stream occurring in 22 of the 43 

allotments). 

--------------Green Ash Hardwood Draws--------------

Trees cover about 10 percent of the landscape 

on the Medora Ranger District. Of the different 

types of woodlands in the project area, only 

the green ash hardwood draws are of concern. 

The desired condition for green ash draws is 

that they are self-perpetuating and exhibit a 

multi-layer and multi-age class of herbaceous 

plants, shrubs, and trees (Grasslands Plan, 

pp.1-2, 2-10, 2-17). 

Surveys (1998, and 2005-2007) of green ash 

wooded draws across the project area show 

that approximately 51 percent are in Healthy 

condition, 42 percent are At Risk, and 7 

percent are Unhealthy. 

Lack of or low tree regeneration and heavily 

impacted or absent shrub layers are the 

primary factors affecting woodland health.

There is a need to improve the health of At 

Risk and Unhealthy green ash draws in 32 of

the 43 allotments by moving them towards 

healthy self-perpetuating, multi-layered, multiaged class communities of herbaceous plants, 

shrubs, and trees.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

vi | Summary

Grasslands Plan

Desired Condition Existing Condition Need for Action

--------------Vegetative Structure--------------

Grasslands Plan direction is to maintain a 

shifting mosaic of vegetation structure across 

the landscape.

The desired vegetative mosaic is composed of 

the Badlands and Rolling Prairie geographic 

area vegetation structure objectives. These 

objectives identify a desired array of Low (10-

20 percent), Moderate (50-70 percent), and 

High (20-30 percent) structure across the 

geographic areas.

Generally, desired high and low structure 

objectives are not being met in the project 

area. 

Survey data from 1996 to 2005 show High 

structure ranged from 1 to 20 percent, 

Moderate structure ranged from 56 to 71 

percent, and Low structure ranged from 23 to 

53 percent.

There is a need to increase the amount of High 

structure and decrease the amount of Low 

structure across the project area.

--------------Vegetative Seral Stages--------------

Seral stages are the successional stages a plant 

community progresses through over the course 

of time. Seral stages range from early pioneer 

vegetation to climax vegetation. 

The desired condition for seral stage is 

composed of the Badlands and Rolling Prairie 

geographic area seral stages objectives located 

in Chapter 2 of the Grasslands Plan. Seral 

objectives are 10-15 percent in early seral 

stage, 65-75 percent in mid seral stage, and 15-

20 percent in late seral stage across the 

geographic areas. 

Surveys completed (1996-2001 and 2004-

2010) across the project area indicate that 

approximately 7 percent of the area is at early 

seral stage, 72 percent of the area is at mid 

seral stage, 5 percent of the area is at late seral 

stage, and 16 percent is at an Invaded Grass 

State where seral stage was not classified. 

There is a need to increase the amount of late 

and early seral stages and reduce the amount 

of mid seral plant communities. There is also a 

need to increase the maintenance of native 

plant communities, and limit the spread of 

invasive species and transitions to Invaded 

Grass States.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Summary | vii

DECISION FRAMEWORK

The Grasslands Supervisor is the responsible official who has decided, through alternative

selection, to continue livestock grazing on all or portions of the 43 allotments with itemized 

terms and conditions. The Grasslands Supervisor has selected the final potential alternative in 

the Draft Record of Decision (ROD) to meet or move towards Grasslands Plan objectives in a 

timely manner for these 43 allotments. The Grasslands Supervisor is authorized to select any of 

the alternatives or create a new alternative within the range of the existing alternatives. The 

Grasslands Supervisor is also responsible for determining whether or not this project requires 

any site specific amendment(s) to the Grasslands Plan.

Now that the decision process is complete, time will be allowed for the objection process to 

reach its conclusion. Comments from Objectors to the Draft ROD will be weighed and 

considered with the FEIS analysis so there is time to make any further adjustments, if the 

Grasslands Supervisor deems necessary, to publish the Final ROD. Allotment management 

plans (AMPs) will be written based on the alternative selected. The AMP is the implementation 

document by which the Forest Service communicates the management objectives and planned 

actions to accomplish those objectives.

The FEIS is not a decision document. It discloses the environmental consequences of 

implementing the proposed action and alternatives to that action. Following publication of the 

FEIS and Draft ROD, the Objection process will ensue. Lastly, the Grasslands Supervisor will 

select the alternative to be implemented and document his reasoning in a Final ROD.

PUBLIC INVOLVEMENT

A scoping letter was sent to 103 interested parties on May 23, 2008. The letter asked that 

comments on the proposed action be received by June 23, 2008. A notice of intent (NOI) to 

prepare an environmental impact statement (EIS), for the North Billings project was published in 

the Federal Register on May 15, 2008.

The Forest Service held public open-house meetings on June 17, 2008, in Dickinson, ND, and on 

June 18, 2008, in Bismarck, ND. News releases announcing the open houses were sent to the 

Bismarck Tribune, which is the DPG newspaper of record, the Dickinson Press, the Bowman 

County Pioneer, The Herald, and the Golden Valley News. An announcement was also sent to 

Dickinson and Bismarck, ND, televised Community Calendars. The Forest Service also invited 

public comment through publication of the proposal in the January 2008 Dakota Prairie 

Grasslands (DPG) Schedule of Proposed Actions (SOPA). 

The DEIS was mailed to a total of 66 individuals, groups, federal, state, and county agencies on 

June 30, and July 1, 2009. A news release announcing the release of the DEIS was sent to the 

Bismarck Tribune, six other daily newspapers, and numerous radio and television stations on 

July 1, 2009. The notice of public comment for the DEIS was published in the Bismarck Tribune 

on July 3, 2009. The North Dakota Congressional Delegation was contacted by phone and sent a 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

viii | Summary

briefing paper on July 1, 2009. The briefing paper was also faxed to the Billings and Golden 

Valley County Commissions and the Medora Grazing Association (MGA). On July 2, 2009, a 

copy of the news release announcing the release of the DEIS was faxed to the Billings and 

Golden Valley County Commission and the MGA.

The notice of availability for the DEIS appeared in the Federal Register on July 10, 2009. The 

comment period on the DEIS was to have closed on August 14, 2009. However, on August 13 it 

was discovered that the e-mail address for comments was incorrect. The district ranger extended 

the comment period to September 4, 2009, to accept any comments that may not have been 

received due to the incorrect address. A letter was sent to the project mailing list on August 25, 

2009, extending the comment period, and a new notice of public comment was published in the 

Bismarck Tribune on August 28, 2009. 

In an effort to further expand the comment base and the opportunity for public participation, the 

district ranger further extended the public comment period to October 10, 2009; however, 

comments were accepted until October 13, 2009, because of the Columbus Day holiday. A letter 

was sent to the project mailing list on September 4, 2009, and a news release announcing the 

extension was sent to numerous television, radio, and newspapers on the same day. The district 

ranger, on September 4, 2009, notified the MGA, Billings County, and the congressional 

delegation of the October extension by phone. An amended notice extending the comment period 

to October 13, 2009 was published in the Federal Register on September 18, 2009. A total of 13

comments were received on the DEIS.

In order to respond to public comments received on the DEIS, and based on the time that had 

passed (almost 2 years) since the DEIS had been distributed, the DPG decided to take an extra 

step to ensure the public had seen, and had a chance to comment on, this important document. To 

that end, the Medora Ranger District of the DPG completed the SDEIS for the North Billings 

County AMP Revisions (USDA Forest Service 2011). The SDEIS rearranged the analysis to 

display both a landscape analysis by resource issue (SDEIS, Vol. I, Chapter 3, Part 1) and an 

allotment-level analysis by resource issue (SDEIS, Vol. II, Chapter 3, Part 2). The SDEIS also 

responded to comments by including an additional alternative, 3A, which included more 

information on soil capability, soil productivity, and water quality, and included discussions to 

address unavailable information and scientific controversy to name a few of the changes. The 

notification of availability for the document was published in the Federal Register on July 8, 

2011. The SDEIS was mailed to a total of 80 individuals, groups, and federal, state, and county 

agencies on July 1, 2011. Chapter 4 of the SDEIS lists the agencies, organizations, and people 

who received copies of the SDEIS. A news release announcing the release of the SDEIS was sent 

to the Bismarck Tribune and numerous other newspapers and radio and television stations on 

July 1, 2011. The North Dakota congressional delegation was contacted by phone and sent a 

briefing paper on July 1, 2011. The Billings County Commission and MGA were called as well 

to inform them of the availability of the SDEIS. Briefings and/or question-and-answer sessions 

were provided at both the MGA July monthly board of directors meeting and the Billings County 

Commissioners August meeting. The Notice of Public Comment for the SDEIS was published in 

the Bismarck Tribune on July 8, 2011. 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Summary | ix

A news release was sent to the media, reminding the public of the August 22, 2011, deadline for 

SDEIS comments. However, in an effort to further expand the comment base and the opportunity 

for public participation, the District Ranger further extended the public comment period to 

September 21, 2011. On August 15, 2011, a letter was sent to those on the project mailing list, 

and a news release announcing the extension was sent to numerous television and radio stations 

and to newspapers on the same day. The Bismarck Tribune published the Notice of Public 

Comment extension on August 26, 2011. A total of 65 comments were received on the SDEIS.

KEY ISSUES 

An issue is an effect on a physical, biological, social, or economic resource. An issue is not an 

activity in itself; instead, it is the projected effects of the activity that create the issue. For 

example, livestock grazing is an activity, but its effects on a resource can form an issue. A key 

issue suggests different courses of action—thus suggesting alternatives and detailed analysis. 

The Forest Service identifies key issues through contact/discussion (scoping) externally with the 

public, organizations, and other state and federal agencies and internally.

The interdisciplinary team (IDT) considered external and internal comments and discussions

received during scoping, ongoing issues associated with general livestock management on the 

Medora Ranger District, and landscape information generated from the 2002 Little Missouri 

National Grassland Rangeland Assessment to identify key issues to be analyzed in this 

document. The IDT identified six key issues for the project area. The district ranger concurred 

and directed that these key issues should be carried through the analysis. The key issues, along 

with the indicator(s) of each issue, are presented below (a brief explanation of the indicator is 

also provided). Indicators are used to evaluate or measure the effects of an alternative on the 

different resources.

KEY ISSUE #1. RIPARIAN AREAS: There is a concern that livestock grazing is adversely impacting 

intermittent streams through excessive use of riparian vegetation, trampling and trailing of 

stream banks, loafing, etc. Intermittent streams typically flow seasonally when they receive 

water from surface sources such as snow melt, storm runoff, or from ground water discharge. 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

x | Summary

Major intermittent streams on NFS lands in the 

project area were surveyed from 1997 through 1999, 

and in 2004, 2006, and 2007 using the Proper 

Functioning Condition protocol (Pritchard et. al., 

1998). Approximately 56.4 miles of stream reaches 

associated with 11 streams were surveyed. Of the 

surveyed stream reaches, 28.6 miles (51 percent) 

were at Proper Functioning Condition (PFC); 2.5 

miles (4 percent) were Functional-At Risk-Upward 

Trend (FAR-U); 3.3 miles (6 percent) were 

Functional-At Risk-Trend Not Apparent (FAR-NA);

2.9 miles (5 percent) were Functional-At RiskDownward Trend (FAR-D); and 19.1 miles (34 

percent) were Nonfunctional (NF).

Functional-At Risk and NF streams exhibit an 

inadequate amount of residual vegetation to trap 

sediments from fall/spring runoff or to control 

erosive energy in the channel. They display poor 

channel morphology (structure) and are affected by 

excessive bank trampling and lack of desired riparian 

plant communities. The Grasslands Plan provides 

guidance for streams identified as non-functioning or 

functioning at risk with a downward trend that 

corrective action should be taken within three years 

of stream inventory (Grasslands Plan Ch. 1, p. 1-11). 

The Grasslands Plan also identifies to allow only 

those actions next to perennial and intermittent 

streams, seeps, springs, lakes, and wetlands that maintain or improve long-term proper 

functioning of riparian ecosystem conditions (Grasslands Plan Ch. 1, p. 1-9). Some causes of 

stream degradation include livestock grazing and road impacts.

KEY ISSUE #2. GREEN ASH HARDWOOD DRAWS: There are several different types of woodland 

communities in the project area including Rocky Mountain juniper, aspen, cottonwood, and 

green ash hardwood draws. The woody draws are generally in good condition; however, there is 

a concern that effects from livestock grazing (including browsing, trampling, lounging, etc.) are 

adversely affecting the distribution of tree and shrub age classes in green ash hardwood draws. 

From this point forward green ash hardwood draws will be referred to as woody draws. 

Proper Functioning Condition (PFC)

means that the stream has adequate 

streambank vegetation, proper stream 

morphology (structure), or instream 

structures (i.e. woody debris, rock, etc.) 

present to dissipate stream energy, 

during high flows. This results in 

benefits including, but not limited to, 

reduced erosion, sediment and 

bedload capture, floodplain 

development, improved water quality, 

ground-water recharge, and 

development of streambank root 

masses. 

Functional-At Risk means that riparian 

areas are in a functional condition but 

one or more properties(such as soil, 

water, or vegetation) are impaired,

which makes the riparian area 

susceptible to degradation. 

Nonfunctional means that the riparian 

area is not functioning properly. 

Typically, nonfunctioning riparian areas 

do not provide adequate vegetation, 

channel properties, or woody debris to 

dissipate stream energy associated 

with high flows and thus do not reduce 

erosion, improve water quality, capture 

sediment, etc.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Summary | xi

Three different sets of woody draw surveys were 

collected and used to assess woody draw 

conditions. The sampled woody draws were rated 

as Healthy, At Risk, or Unhealthy. Of the green 

ash woody draws that were surveyed, 51 percent 

were Healthy, 42 percent were At Risk and about 

7 percent were Unhealthy. 

The Grasslands Plan provides guidance for 

woody draws and riparian areas to move at least 

80 percent toward self perpetuating plant and 

water communities that have desired diversity 

and density of understory and overstory 

vegetation within site capability (Grasslands Plan 

Ch. 1, p. 1-2).

KEY ISSUE #3. VEGETATIVE STRUCTURE: There is 

a concern that livestock grazing has affected the 

mosaic of vegetative structure in the project area,

which has generally resulted in too little High 

structure and too much Low structure in light of 

Grasslands Plan structure objectives. Because the 

geographic area direction within the Grasslands Plan focuses on grass, grass-like, and some 

shrub life forms, from this point forward vegetative structure will be referred to as herbaceous 

structure. Structure is an important measure for wildlife habitat, especially ground-nesting birds, 

but also has implications for other ecosystem attributes and rangeland health. Livestock 

management influences structure through several factors including intensity, frequency and 

timing of grazing activity. 

The Grasslands Plan identifies a desired range for herbaceous structure as 10 to 20 percent in 

Low, 50 to 70 percent in Moderate, and 20 to 30 

percent in High structure (Grasslands Plan, Ch. 2, 

pp. 2-13, 2-19).

Visual Obstruction Reading (VOR) surveys 

conducted in the project area for 2004 and 2005 

show High structure ranging from 0.6 to 7 percent, 

Moderate structure ranging from 47 to 64 percent, 

and Low structure from 30 to 53 percent. These 

surveys were conducted on biologically capable 

lands within the project area. VOR surveys 

conducted from 1996 to 2001 in Billings County 

show High structure ranging from 3 to 8 percent, 

Moderate structure ranging from 47 to 83 percent, 

Healthy woody draws are defined as those 

woodlands that have self-perpetuating tree and 

shrub populations with diverse age classes, 

species composition, and multiple structural 

layers as habitat conditions permit.

At Risk woody draws tend to exhibit a moderate 

distribution of tree age classes, but lack 

consistent regeneration as expressed by sapling 

and young tree age classes. Desirable tall shrub 

(e.g., chokecherry, serviceberry) distribution 

tends to be patchy, and/or low shrubs (such as 

snowberry) dominate the shrub layer.

Unhealthy woody draws are generally 

characterized by old or decadent tree layers and 

a lack of younger age classes ranging from 

saplings to small diameter trees. The understory 

is dominated by invasive grasses or short shrubs 

such as snowberry. 

Low Structure is defined as a Visual 

Obstruction Reading (VOR) reading 

between 0 and 1.49 inches.

Moderate Structure is defined as a VOR 

reading between 1.5 and 3.5 inches.

High Structure is defined as a VOR 

reading greater than 3.5 inches.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

xii | Summary

and Low structure from 11 to 49 percent. VOR surveys specific to the project area conducted 

between 1996 to 2001 show High structure ranging from 5 to 20 percent, Moderate structure 

from 56 to 70 percent, and Low structure ranging from 23 to 36 percent.

KEY ISSUE #4. VEGETATIVE SERAL STAGES: Seral stage refers to the current composition of plant 

species that occur along a continuum between early plant establishment and a climax plant 

community. The Grasslands Plan uses vegetative seral stages to identify desired condition for 

plant species composition. From this point forward vegetative seral stages will be referred to as 

seral stages. Seral stages are expressed as early, mid, and late stages. Plant communities change 

as they move from one seral stage to the next. A mosaic of seral stages is normally spread across 

the landscape. 

There is a concern that a combination of the 

expansion of invasive grass species and current 

grazing strategies is adversely affecting the desired 

mosaic of seral stages and maintenance of native 

plant communities. The current distribution of 

seral stages across the project area is 

approximately 7 percent in early seral stage, 72 

percent in mid seral stage, and 5 percent in late 

seral stage. Approximately 16 percent of the 

sample sites are at an Invaded Grass State (NRCS, 

2009) and not included in the seral stage analysis. 

The Grasslands Plan objectives for seral stages are 

to have 10 to15 percent in early seral stage, 65 to 

75 percent in mid seral stage, and 15 to 20 percent 

in late seral stage.

KEY ISSUE #5. ECONOMICS: Potential reductions to Authorized Use are likely to have an effect 

on the economics of the individual permittee and adjacent communities. Calculating potential 

impacts to an individual permittee is very complicated and requires information not readily 

available. The broader concern, however, is related to how the range of alternatives would affect 

jobs and income in the agricultural sector, which includes livestock grazing. The economic 

analysis in this document is focused on the effects of the alternatives on jobs and income within 

an identified economic impact area of associated counties.

The analysis also considers an economic analysis completed by North Dakota State University 

(NDSU) for Billings County, ND. The NDSU analysis looks at the effects of two of the four 

alternatives in terms of changes in gross sales and net revenues from cow-calf operations and 

debt repayment capabilities.

KEY ISSUE #6. DROUGHT: A major factor affecting herbaceous structure, forage availability, and 

other resources across the landscape is drought. The Grasslands Plan (Appendix G, p. G-15) 

defines drought as any year or sequence of years when annual precipitation amounts are 75 

percent or less of normal. Based on this definition, drought has occurred in 21 percent of the 

Early seral stage is the plant community that 

occurs after a significant disturbance such as 

heavy continuous seasonlong grazing. 

Mid seral stage is the plant community that

is transitioning between early and late seral 

stages and typically develops under more 

stable environmental conditions, but can 

occur under a moderate level of disturbance.

Late seral stage is a plant community that 

develops with extended periods of no or 

little disturbance, and approaches 

composition of a climax plant community.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Summary | xiii

years in the northern Great Plains, since 1940 (Holechek et.al. 1989). Within the past 10 years 

drought has occurred on the Little Missouri National Grasslands about 40 percent of the time 

according to the U.S. Drought Monitor (http://drought.unl.edu.dm).

Lack of precipitation during the growing season (April through July) has a major impact on the 

production of forage. Less available forage results in utilization levels being reached earlier in 

the grazing season, which results in fewer days of grazing. The DPG currently does not have a 

unit-wide drought strategy but is in the process of creating one. During this interim period a 

modification of the drought strategy identified in the 2005 NE McKenzie Allotment 

Management Plan Revisions FEIS will be used. Once the DPG drought strategy is completed it 

will replace the interim strategy. Drought is an important factor affecting livestock management 

on the DPG. It is included as an issue to highlight its importance and is addressed through 

inclusion of an interim drought strategy in the Design Criteria identified in Chapter 2.

ALTERNATIVES CONSIDERED IN DETAIL

For this project, the IDT considered the following elements in the development of the action 

alternatives: key issues; the purpose of and need for this project as identified in Chapter 1; the 

goals, objectives, and desired conditions for the project area as described in the Grasslands Plan; 

comments made by the public, the state, and various agencies during the scoping process; the 

laws, regulations, and policies that govern land management on National Grasslands; and sitespecific resource information.

Four alternatives were developed and analyzed in the DEIS. After review of DEIS comments the 

responsible official decided to create and include an additional alternative in the SDEIS. The 

alternative descriptions, presented below, explain the activities that would occur if an alternative 

were selected. A detailed description of the environmental effects resulting from the alternatives 

is given in Chapter 3.

It is important to note that Authorized Use under all the alternatives, except Alternative 1, can be 

adjusted annually to account for situations that require additional resource protection. Examples 

include drought, grasshopper outbreaks, over-utilization of a pasture, etc. These adjustments are 

temporary in nature and normally encompass a single grazing season. However, if a resource 

has been severely affected, adjustments may be of longer duration.

Alternative 1

The CEQ regulations for implementing the NEPA require that a no-action alternative be 

developed as a benchmark from which the agency can evaluate the proposed action. No action in 

livestock management planning is defined as “...livestock grazing would not be authorized 

within the project area” (Forest Service Handbook [FSH] 2209.13, 92.31, Grasslands Plan ROD, 

2006).

Upon implementation of the decision and resolution of any appeals, the term grazing permit with 

the Medora Grazing Association (MGA) would be modified to terminate livestock grazing in the 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

xiv | Summary

analysis area. Pursuant to FSH 2209.13, Section 16.24, this alternative could not be implemented 

until 2 years after the notification of each affected permittee (36 CFR§ 222.4(4)(1)). No permits 

would be issued for any of the 43 affected allotments. Since livestock grazing would no longer 

be authorized under this alternative, no mitigation measures for riparian habitat, woody draws, 

herbaceous structure, or seral stages would be completed. However, restoration projects could be 

planned and implemented, which would require a subsequent plan and NEPA decision.

Most range improvements currently in existence on the allotments would be abandoned.

Subsequent decisions would need to be made regarding retention of any improvements, such as 

water developments, for other resource needs and funding for maintenance would need to be 

secured. Any water developments not needed for wildlife or other purposes, and all fences, 

except Grassland boundary fences or allotment boundary fences adjacent to other active grazing 

allotments, would be removed. 

Under this alternative control of noxious weeds 

would become the sole responsibility of the Forest 

Service, as the MGA would no longer be authorized 

to graze livestock in the project area. 

Alternative 2

This alternative would maintain the status quo. Authorized Use would remain at Preference;

therefore, there would be no change in the number of livestock or season of use in the allotments 

within the project area. Some minor changes may be made in the Annual Operating Instructions 

(AOI) if needed. Existing conditions for each allotment are identified in Chapter 3 Part 2.

Alternative 3

As identified in Chapter 1, the proposed action for this project is to continue to permit livestock 

grazing at Preference, initially, on the 43 allotments in the project area through a program of 

actions that maintains and/or moves resource conditions towards meeting the Grasslands Plan 

objectives and desired on-the-ground conditions. This is to be achieved through implementation 

of initial actions and application of adaptive options, including the tool box if initial actions fail 

or cannot be implemented.

Tables x.2 and x.3 (identified by allotment number rather than chapter number) contained in each 

of the individual allotment write-ups in Chapter 3 Part 2, contain information identifying existing 

and desired conditions, need for action, initial management actions, and a set of adaptive options 

to address identified resource concerns for each allotment in the project. Taken together, the 

initial actions and adaptive options create the proposed program of actions for each individual 

allotment.

A key component of this alternative is monitoring, because it determines whether implemented 

management actions are accomplishing their intended resource goals. The starting point for each 

allotment is identified as “Initial Actions” in Table 3 of the allotment write-ups located in 

Preference is the maximum number of 

livestock for a given amount of time 

allocated to an allotment.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Summary | xv

Chapter 3 Part 2. If monitoring indicates that the initial actions are not meeting or moving a 

resource towards desired condition, then adaptive options can be applied. Monitoring is 

discussed in detail later in this document. The type, frequency, and duration of monitoring on 

each allotment is identified in Table 3 of each of the allotment write-ups.

Information contained in Chapter 3 Part 2 will be used in the development of new allotment 

management plans (AMPs) for the 43 allotments in the project area. The individual AMPs will 

be the documents that implement the selected alternative which will be identified in the Draft 

ROD for this proposal.

If initial or adaptive management options identified in the allotment write-ups located in Chapter 

3 Part 2 cannot be implemented as planned, then a team composed of Forest Service specialists, 

in consultation with the affected permittee and MGA director, would make a recommendation to 

the district ranger. The recommended course of action would be based on the adaptive options 

identified for each allotment in Chapter 3 Part 2 and/or the Grazing Management Toolbox (Table 

S.3). For example, Allotment A contains an initial or adaptive option to develop a range water 

well, pipeline, and a stock tank or two. The purpose is to pull cattle away from a riparian area 

that needs improvement. However, for economic reasons it becomes unfeasible to develop the 

well and facilities in the reasonably foreseeable future, but the resource concern still needs to be 

addressed. At this point the additional management tools identified in the toolbox would be 

available to help solve the concern. 

The toolbox is a collection of different management tools that could be used singularly or in 

combination to address resource issues if proposed initial management actions and adaptive 

options are not successfully addressing a resource concern(s). The toolbox is a compilation of all 

the different management tools identified in the 43 different allotment summary sheets. The 

different tools are not listed in any order of preference or priority for implementation. 

It is possible that new rangeland management techniques may be developed during the life of 

this project. New techniques would be incorporated into the toolbox if their implementation is 

consistent with the effects documented in the FEIS and its accompanying ROD.

Between the DEIS and SDEIS, initial actions for Alternative 3 were modified for allotments 126, 

128, 132H, and 300 based on discussion with the permittee for those allotments.
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xvi | Summary

Table S.3 — Grazing Management Toolbox

Adjust AUMs (stocking rate) by # of head &/or # of days.

Adjust AUMs based on average cow size.

Adjust season of use.

Allow early turnout on native pastures one out of 3 years on inventory permits.

Construct and/or remove cross fences.

Construct fence to create riparian unit—allow grazing under riparian grazing dates.

Construct fence to exclude livestock from areas of concern (riparian, wooded draws, springs, wetlands, 

etc.).

Construct livestock water development (well, pipeline, tanks, windmill, reservoir, dugout, or spring).

Construct temporary fence to control livestock distribution patterns.

Construct water gap to limit livestock access on stream.

Construct/harden stream crossings.

Defer native pastures until June 1, or until development of the three-and-a-half leaf stage for key 

graminoid species.

Fertilize crested wheatgrass areas.

Hay or cut-&-leave crested wheatgrass areas.

Implement BMPs for riparian pastures.

Implement deferred grazing system.

Implement DPG drought management strategy.

Implement prescribed burns.

Implement rest-rotation grazing system.

Implement twice-over grazing system.

Incorporate a range rider to disperse livestock throughout a pasture (herding).

Incorporate private “off permit” land into rotation.

Interseed pasture with native grass species.

Maintain existing developments to reestablish use.

Manage salt and supplement locations.

Manage water availability/access at water developments.

Mechanical brush management.

Move winter feeding areas off of NFS lands.

Reallocation of pastures (change allotment boundary) .

Remove/reclaim water development (well, pipeline, tanks, windmill, reservoir, dugout, or spring).

Rest for one or more seasons.

Restore/enhance riparian vegetation, i.e., willow planting.

Scarify clubmoss areas within a pasture.

Utilize biological controls for noxious weed control in woody draws.

Utilize non-native grass pastures early to defer grazing on native grasses.
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Summary | xvii

Alternative 3A

One of the MGA comments on the DEIS states that the association wanted Alternative 3 revised 

to reflect all of the MGA recommendations. They provided Exhibit 2, which compared

Alternative 3, Appendix A to the notes of each permittee meeting regarding the initial 

recommendations. In Exhibit 2, they specifically highlighted recommendations that they felt the 

Forest Service dropped from consideration, and also highlighted Forest Service additions to 

Alternative 3, which the MGA claimed the MGA members did not agree to. 

Tables 3 and 4 located in Appendix A discuss each item as highlighted in the MGA Exhibit 2.

Some of the items highlighted by the MGA in Exhibit 2 did not provide recommendations or had 

already been addressed in Alternative 3. Therefore, Alternative 3A did not incorporate these 

highlighted items in the MGA recommended proposal. 

In response to the MGA comment, the responsible official decided to include a new alternative in 

the SDEIS. The new alternative is identified as Alternative 3A. It was created by including

applicable actions identified in the MGA Exhibit 2 that the MGA recommended be added to 

Alternative 3, and excluding some actions identified in Alternative 3 that the MGA did not agree 

with. Tables S.4 and S.5 summarize the changes made.

Table S.4 — Recommendations incorporated into Alternative 3A 

Allotment # MGA Association/Member Recommendations Added to Alternative

127 Construct a water lot around the existing spring development to allow access to 

both pastures 2 and 3 in the northeast quarter of the southwest quarter of Section 

17, T144N, R101W.

129 Extend range water pipeline from well in allotment 131 pasture 3 into allotment 

129 pasture 2 in Section 11, T144N, R101W.

135 Construct a range water pipeline from pasture 8 to pasture 10 and add one stock 

tank in Section 28, T143, R101W.

142 Construct an electric cross fence running east/west in pasture one.

243 Develop a spring in pasture 1 in the southwest quarter of Section 3, T143N, 

R99W.

258 Allow a permittee to turn livestock onto native pastures the middle to third week 

of May.

272 Develop a spring in pasture 2 in the northwest quarter of the southwest quarter of 

Section 30, T143N, R99W.

287 Construct an extension to the existing range water pipeline in pasture 3 into the 

northwest quarter of Section 26, T143N, R101W.
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xviii | Summary

Table S.5 — Actions not included in Alternative 3A 

Allotment # Forest Service Actions in Alternative 3 but Not Included in Alternative 3A 

126 Reclaim existing spring developments in pastures 4 and 6.

240 Reclaim reservoir(s) in pasture 1.

244 Cross fence pasture 2, north to south. Cross fencing would create a crested 

wheatgrass pasture on the east side of pasture 2, which would be grazed early. 

The additional pasture, created through the cross fence allows the implementation 

of a two pasture deferred grazing rotation between the remaining pastures.

272 Fence woody draw located in the southwest quarter of Section 30 with temporary 

electric fence.

After construction of the pipeline is complete reclaim the dugout located in the 

southeast quarter of Section 29 pasture 1 and the reservoir located in the 

northwest quarter of the southeast quarter of Section 30 pasture 2.

278 Reclaim reservoir in pasture 2.

300 Once well is developed reclaim spring in the southeast quarter of Section 28.

301 Fence out spring areas, install check valve to dump water back into riparian areas 

once stock tanks are full.

Alternative 4 

Alternative 4 is similar to Alternative 3 in some respects. However, it differs from Alternative 3 

by establishing Authorized Use based on estimated livestock carrying capacities, and it accounts 

for changes in animal unit forage demands with changes in cow size (animal weight). Four of the 

allotments’ Preference was less than initial estimated carrying capacity. Because there were 

resource concerns in these allotments, Authorized Use was set at Preference adjusted for cow 

size as a starting point. In addition, the IDT reviewed the initial and adaptive actions identified in 

Alternative 3. They then estimated the costs of initial action projects under Alternative 3 and 

prioritized those projects in light of the resource objectives the project was designed to address. 

Estimated costs were then compared against projected funding over the next 3 years. This 

resulted in a winnowing of projects and the development of different management approaches 

for some of the allotments.

The third table in each of the allotment specific write-ups contained in Chapter 3 Part 2 identifies

the allotment-specific actions for each allotment for this alternative. This alternative is also 

adaptive by design, so if monitoring indicates a need to consider and possibly implement 

different management options, adaptation would be as discussed in Alternative 3. 

PREFERRED ALTERNATIVE

Regulation 40 CFR Section 1502.14(e) of the CEQ regulations states “Identify the agency’s 

preferred alternative or alternatives if one or more exist, in the draft [environmental impact] 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Summary | xix

statement...” At the time of the DEIS, the responsible official for this project did not have a 

preferred alternative. After review of information provided during the comment period on the 

DEIS and SDEIS, the Grasslands Supervisor has identified a combination of alternatives for the 

43 allotments as the preferred alternative for this project proposal carefully identified in the Draft 

ROD. 

DESIGN CRITERIA COMMON TO ACTION ALTERNATIVES 

Design criteria (Table S.6) are actions designed into the action alternatives (Alternatives 3, 3A, 

and 4) to reduce impacts of proposed activities. They include any requirements that must be 

complied with by law, regulation, or policy, and include aspects such as best management 

practices (BMPs), Grasslands Plan standards and guidelines, and standard operating procedures.

Table S.6 — Design criteria

Place salt and supplement to draw livestock away from woodlands and riparian areas.

On native pastures, defer turnout until June 1, or until the three-and-a-half leaf stage is reached for 

key native graminoid species, e.g., western wheat, green needle, needle and thread. 

On inventory permits, early turnout on native pastures is allowed one out of 3 years. 

Rotate placement of salt and supplement to minimize effects of concentrating livestock, trailing, etc.

Locate any new water source in uplands away from woodlands and riparian areas.

For allotments requiring a AM/AUM reduction: 

 If monitoring shows that resource objectives are being met before full implementation of the 

AM/AUM reduction has occurred, then no further reduction in AUMs will be implemented.

 If, after the reduction in AM/AUMs is complete, monitoring shows that resource objective(s) 

have not been met but a significant sustained upward trend is evident, then further AUM

adjustments will not occur unless continued monitoring indicates the upward trend is not being 

sustained.

 If, after the reduction in AM/AUMs is complete, monitoring shows that resource objective(s) 

are not being met and there is a stagnated or downward trend, then, as an adoptive option, 

further AM/AUM adjustments may be initiated.

 Temporary increases in AUMs may be granted if monitoring indicates that resource objectives 

are being exceeded.

If stocking rate adjustments are needed, annual reductions will generally not exceed 10 percent.

Move oilers, creep, and supplement feeders out of woodland and riparian areas.

When drought conditions occur, the DPG drought strategy will be followed. In the absence of the 

DPG drought strategy, the strategy identified in the NE McKenzie Allotment Management Plan 

Revisions FEIS will be followed, with some modification.* Permittees will be notified verbally and 

in writing that reductions in numbers and/or seasons may be anticipated.

Ground disturbing activities, such as installation of water developments, pipelines, fences, or 

exclosures, will require both heritage resource and sensitive species surveys approval by a Forest 

Service archeologist, botanist, and wildlife biologist prior to construction.

All new fencing will be built according to the standards identified in Grasslands Plan Appendix B.

All new or reconstructed water developments will include wildlife access and escape ramps.
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xx | Summary

Areas disturbed by rangeland improvement will be seeded with native species utilizing certified

weed seed free mixtures prescribed by the Forest Service botanist. 

Burn plans will be developed and approved for all prescribed fires prior to implementing on-theground actions. 

Assess prescribed burn areas to determine appropriate stocking levels. 

Defer prescribed burn areas from livestock grazing for a portion or all of the following growing 

season to ensure regrowth of forage species unless there is specific reason to graze early.

Range improvements will be maintained to standard by the allotment permittee prior to turning 

livestock into the affected pasture. 

Install floats and/or shut-off values to regulate inflow to livestock watering tanks. 

*The drought strategy would be incorporated into Alternatives 3, 3A, and 4, and would:

 Use the publication Drought Management on Range and Pastureland (Reece et al. 1991) to determine 

allowable stocking levels during drought, unless interdisciplinary collaboration between the Forest Service

and the Medora Grazing board provided rationale to deviate from those guides. This publication calculates 

stocking guidelines by considering weather and soil- moisture. The publication is identified in the 

Literature Cited section in this FEIS and is located in the Project Record.

 Manage grazing during drought, with the objective of maintaining at least 10 percent of herbaceous 

communities across biologically capable lands in the project area, for high structure and at least 40 percent 

for moderate structure. This will help ensure that the project area is not grazed evenly and retains plant 

cover to provide wildlife habitat, conserve soil moisture, and prevent soil erosion.

 Recognize that allowable utilization rates would be lower during drought.

 Recognize that frequent allotment inspections and early and frequent communications with permittees are 

key to ensuring that this strategy is effective.

MONITORING

Monitoring includes both grasslands-level and project-level analysis and evaluation. Grasslandslevel monitoring is discussed at length in Chapter 4 of the Grasslands Plan and is not reiterated 

here. Project-level monitoring is the focus of this section of the FEIS.

Monitoring and evaluation are key elements of adaptive management. Adaptive management is 

proposed under Alternatives 3, 3A and 4. Even under Alternatives 1 and 2, monitoring and 

evaluation would be important. Monitoring helps determine how well Grasslands Plan and 

NEPA decisions are being implemented, whether AMP implementation is achieving the desired 

outcome, or whether changes in management are needed. Through monitoring, the Forest 

Service can measure whether or not management actions are meeting or moving towards desired 

conditions in an appropriate timeframe. Through adaptive management, AMPs can remain 

dynamic, relevant, and useful documents over many years. Additional discussion of adaptive 

management is contained in Chapter 1.

Two types of monitoring are associated with initiating management actions for a grazing 

allotment—implementation monitoring and effectiveness monitoring. Implementation 

monitoring generally measures and documents whether or not Grasslands Plan standards and 

guidelines and project-level design criteria (as selected in the Draft Record of Decision for this 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Summary | xxi

project) are being applied. Effectiveness monitoring evaluates how effective management actions 

are at moving toward, achieving, or maintaining desired conditions. Under Alternatives 3, 3A, 

and 4, if a management action is determined not to be effective, the monitoring will trigger 

implementation of an adaptive management action. Under Alternatives 1 and 2, additional NEPA 

would be required before any substantive changes could be made.

Monitoring on the allotments can be accomplished by the Forest Service, permittees, or others

(such as university partners and North Dakota Game and Fish), implementing approved methods 

and providing appropriate documentation that meets specified standards. Herbaceous structure, 

composition, riparian areas, and green ash woody draws will be the focus of effectiveness 

monitoring. Table 3 under each allotment write-up located in Chapter 3 Part 2 identifies the type 

and frequency of monitoring that is proposed for each allotment. 

Implementation (Short-Term) Monitoring

Implementation monitoring is short-term monitoring that evaluates whether livestock 

management is being applied as prescribed in the AMP and implemented through the AOI. The 

Forest Service in conjunction with the MGA, under the direction of the Grazing Agreement,

conducts this type of monitoring. 

COMPLIANCE WITH ALLOTMENT MANAGEMENT PLAN (AMP) AND ANNUAL OPERATING 

INSTRUCTIONS (AOI)

An AMP is the individual plan developed for a specific allotment. It identifies desired 

conditions, goals, and objectives applicable to the allotment to move it towards, achieving or 

maintaining desired objectives. 

The AOIs implement the AMP and clearly explain how each allotment is to be managed on a 

year-to-year basis. The 2009 Grazing Agreement defines AOIs as 

detailed, FS and the MGA approved, instructions for livestock grazing 

administration to be implemented in a given year on a given allotment developed 

in conjunction with the MGA and the member. AOIs are based on the AMP and 

show number of livestock to be grazed, season of use, responsibilities for 

improvement construction or maintenance, and pasture rotation schedules. 

On-the-ground implementation of the AOI is the MGA’s and the permittees’ responsibility. 

Checks by the Forest Service and/or the MGA conducted throughout and following the grazing 

season, including discussions with the permittee, will be used to evaluate compliance with the 

AOI and AMP.
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xxii | Summary

Effectiveness (Long-Term Trend) Monitoring

Effectiveness monitoring is long-term monitoring that focuses on determining whether 

management is successful at maintaining existing desired conditions or is moving rangeland 

resources towards desired conditions. Determining trend toward or away from allotment 

objectives allows rangeland managers to accurately determine the relative success of the 

management system and to adjust management to achieve the accomplishment of objectives.

Effectiveness monitoring, as applied here, would center on responding to the “need for action” 

described in Chapter 1. The long-term health of riparian areas, herbaceous composition and 

structure, and green ash woody draws will be monitored on each allotment using the methods 

described in Table S.7. It is important to note that resources may be monitored more or less 

frequently than identified in Table S.8 if the responsible official decides there is a need to do so. 

Completing needed monitoring will require a coordinated collaborative effort between the Forest 

Service, its agent the Medora Grazing Association, and others such as the North Dakota State 

University and Dickinson State University.

Table S.7 — Effectiveness monitoring schedule

Monitoring Item Method General 

Frequency

Riparian areas PFC

Every 3 years for streams rated as 

FAR-NA, FAR-D, or NF. Every 5 

years for streams rated as PFC or 

FAR-U.

Woody draws

Sapling 

Density and 

Survival

Once within a 3- to 5-year timeframe.

Herbaceous 

structure

VOR

Approximately 25 percent of the 

allotments would be monitored 

annually for 3 years then reevaluated 

to determine monitoring frequency. A 

third of the remaining allotments

would be monitored every year over 

the same 3-year period.

Seral stages

NDSU 

Ecological 

Sites and/or

NRIS TERRA

Once within a 3- to 5-year timeframe.
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Summary | xxiii

TRIGGER POINTS

The value of monitoring under an adaptive 

management approach is that it reveals how 

management is performing relative to desired 

conditions. A natural extension of this process is to 

ask, “At what point do we consider the need to change 

management if monitoring indicates a lack of 

acceptable progress towards desired conditions?” The 

point at which monitoring indicates a possible need for 

change is called a trigger point. 

Once a trigger point is reached, the district ranger will 

convene a team, composed of Forest Service 

specialists in consultation with the affected permittee 

and MGA Director. The team will review the 

monitoring data and other pertinent information to 

determine if a management adjustment is needed. If it 

is determined that any adjustments are needed, the 

team will review the adaptive management options 

identified in Table 3 under each allotment write-up 

located in Chapter 3 Part 2 and/or the Grazing 

Management Toolbox and recommend a course of action to the district ranger.

Monitoring triggers for each of the primary resource issues are identified in Chapter 2 of the 

SDEIS. The triggers are applied at the allotment level.

SUMMARY COMPARISON OF ALTERNATIVES

The following tables briefly display the differences between the considered alternatives. Table 

S.8 summarizes the ability of the alternatives to meet the Purpose and Need. Table S.9

summarizes the effects of the alternative by Key Issue. Table S.10 summarizes the Authorized 

Use by alternative. Table S.11 presents a summary of the different initial management actions 

and other information associated with each of the alternatives.

A trigger point implements a review 

process; it doesn’t mean a 

management change is automatically 

needed. Take, for example, a stream 

that is rated at FAR-NA (Table S.9). To 

start moving the stream towards FARU, a series of initial actions are 

implemented on the allotment. If 

monitoring 5 years hence shows the 

stream has not achieved the next 

condition class, e.g., FAR-U, the 

monitoring information would be 

reviewed. If the review indicates 

significant progress is being made and 

that what is needed is an additional 1

to 2 years to achieve the next condition 

rating, the district ranger may decide to 

continue the current course of action 

with continued monitoring to ensure 

the goal is achieved in that timeframe.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

xxiv | Summary

Table S.8 — Summary of how the alternatives respond to the purpose and need

Purpose and 

Need Alternative 1 Alternative 2 Alternative 3*

Alternative 

3A*

Alternative 4*

Allow grazing 

and provide 

forage

No Yes Yes Yes Yes

Support ranching 

community No

Would 

continue to 

support 

existing 

ranching 

community. 

Would continue to 

support existing 

ranching community 

under initial actions. 

If reductions in 

Authorized Use were 

to occur as an 

adaptive action there 

is potential for a 

reduction in jobs and 

reduced income in 

the agricultural 

sector.

Same as 

Alternative 3

Is projected to 

result in the loss 

of 1-4 jobs and a 

reduction in 

revenue in the 

agricultural sector.

Meet or move 

towards Desired 

Conditions for 

resources

See Table 2.11 (in Chapter 2) for a discussion specific to each key resource.

Provide for 

management 

flexibility i.e., 

adaptive 

management

No No Yes Yes Yes

*Alternatives 3, 3A, and 4 are adaptive management alternatives. Responses in the table above are to initial actions proposed 

under each alternative to address resource concerns. The suite of additional management tools, under adaptive management, 

available to each alternative is the same. The difference among the three alternatives when considering the adaptive management 

portion of the alternatives is time. Alternative 4 initially takes more aggressive steps to address resource concerns than do 

Alternatives 3 and 3A. If under Alternatives 3 or 3A monitoring reveals that more aggressive measures are required, being able to 

implement those measures and see significant results within the 10- to 15-year timeframe associated with this project becomes 

questionable.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Summary | xxv

Table S.9 — Key issue comparison of the alternatives

Key Issue Indicator(s)

Alternatives

1 2 3 3A 4

Riparian Riparian 

vegetation 

condition, 

sediment 

entrapment, 

and 

stabilization of 

stream banks 

and beds.

Removal of 

livestock would 

afford riparian 

vegetation 

recovery which 

would increase 

sediment 

trapping abilities 

and increase 

bank 

stabilization 

which, in turn,

would bring 

affected streams 

segments to 

PFC.

Stream segments 

adversely 

affected by the 

effects of road 

construction may

continue to 

function below

PFC. 

This alternative 

would maintain 

the status quo in 

terms of the 

riparian 

vegetation 

condition and its

ability to trap 

sediment and 

stabilized stream 

banks and beds. 

Percentages of 

PFC (51), 

FAR-U (4), 

FAR-NA (6), 

FAR-D (5), and 

NF (34) stream 

segments would 

remain the same. 

Initial actions would 

provide for riparian 

vegetation recovery, 

reduced bank disturbance,

and improved sediment

capture. This would result in 

23 of the 28 stream reaches 

identified as FAR or NF

improving towards PFC. 

Eighteen of the 23 reaches 

that would improve are 

rated as FAR-D or NF. 

Seven of these 18 reaches 

could improve but could 

take several decades to 

reach PFC.

Adaptive Management:

Implementation of different 

adaptive management tools 

would see the additional 

improvement of four stream 

segments not improved with 

initial actions.

There will be no 

improvement in allotment 

277 (Scairt Woman Draw).

This is because the 

underlying cause of the 

functionality problem was 

not clearly due to the effects 

of livestock grazing; 

therefore it was not clear 

that changes in grazing 

Same as Alternative 3. Initial actions would provide 

for riparian vegetation 

recovery, reduced bank 

disturbance, and improved

sediment capture. This 

would result in 27 of the 28 

stream reaches identified as 

FAR or NF improving 

towards PFC. Twenty seven 

of the FAR and NF reaches 

would improve although two 

of the 27 reaches are 

expected to take several 

decades to reach PFC due to 

the existing condition.

Adaptive Management:

Implementation of different 

adaptive management tools 

could decrease the recovery 

time of the two reaches that 

are expected to take several 

decades to reach PFC.

There will be no 

improvement in allotment 

277 (Scairt Woman Draw)

for the same reason as 

identified under Alternative 

3.
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xxvi | Summary

Key Issue Indicator(s)

Alternatives

1 2 3 3A 4

practices would result in 

recovery during the time 

frame of this project.

Woody 

draws

Intensity, 

frequency, and 

season of 

disturbance 

relative to 

current levels 

of disturbance.

Removal of 

livestock would 

allow most At 

Risk and 

Unhealthy 

woody draws to 

recover to a 

Healthy 

condition rating. 

Some woody 

draws rated as 

Unhealthy are 

too heavily 

impacted and 

would eventually 

disappear from 

the landscape 

without an 

investment in 

additional 

resources, such 

as planting of 

trees and shrubs. 

This alternative 

would maintain 

current 

Authorized Use 

numbers and 

grazing systems, 

range facilities,

etc. Therefore 

the intensity and 

frequency of 

disturbance 

associated with 

livestock use 

would remain 

unchanged. Due 

to low sapling 

recruitment there 

is potential for 

some At Risk 

woody draws to 

shift to 

Unhealthy and 

for further 

reduction or loss 

of Unhealthy 

woody draws. 

The percentage 

of Healthy

woody draws 

would persist. 

Currently 51 

percent of the 

This alternative maintains 

Authorized Use at 

Preference and would 

implement other initial 

actions to address woody 

draw concerns. The initial 

actions would affect both 

the intensity and frequency 

of use providing an 

opportunity for some 

improvement in woody 

draw health. Of the 43 

allotments in the project 5 

have no woody draws and 6 

are meeting objectives. Of 

the remaining allotments 11

are predicted to improve, 15

would experience no change 

and 6 would decrease in 

condition. The total 

proportion of Healthy 

woody draws would not be 

expected to increase above 

55 percent.

Adaptive Management:

Adaptive management tools 

would improve impacted 

woody draws.

Under this alternative, 

woody draw 

conditions would 

improve in 8 

allotments, 15

allotments would 

experience no change, 

and in 9 allotments 

conditions would 

decrease. The total 

proportion of Healthy 

woody draws would 

not be expected to 

increase compared to 

existing conditions.

Adaptive Management:

Same as Alternative 3.

This alternative would set 

Authorized Use at initial 

estimated carrying capacity. 

Except in three allotments 

this action would result in a 

decrease in both the intensity 

and frequency of disturbance 

associated with livestock use 

of woody draws. Of the 32

allotments not meeting 

woody draw objectives, 21

are predicted to improve, 7

would experience no change,

and 4 would decrease in 

condition. The total 

proportion of Healthy woody 

draws would have the 

potential to increase to 59 

percent.

Adaptive Management:

Adaptive management tools, 

if needed, are the same as 

Alternative 3 and 3A. The 

difference between 

Alternatives 3,3A, and 4, is 

the rate of expected change.

Because more aggressive 

initial actions are 

implemented under 

Alternative 4 the expected 

rate of change would be 

higher under Alternative 4.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Summary | xxvii

Key Issue Indicator(s)

Alternatives

1 2 3 3A 4

woody draws are 

rated as Healthy, 

42 percent At 

Risk and 7 

percent as rated 

Unhealthy.

Herbaceous 

structure

Levels of 

Authorized 

Use relative to 

initial 

estimated 

carrying 

capacity.

Removal of 

livestock would 

see an increase 

in High structure 

and decrease in 

Low structure. 

Authorized Use 

would remain at 

current levels 

which in most of 

the allotments 

are above initial 

estimated 

carrying 

capacity. The 8 

allotments 

meeting 

structure

objectives would 

continue. The 

existing mosaic 

of structure on 

the remaining 

allotments would 

be maintained. 

This alternative would 

maintain Authorized Use at 

Preference and would

implement a series of 

different management 

actions. These actions 

would modify the existing 

structure mosaic but no 

increase in the amount of 

High structure is projected 

because the levels of 

Authorized Use, under 

initial actions remain at 

Preference.

Adaptive Management:

Adaptive management tools 

would move the existing 

structure mosaic towards 

structure objectives. 

Same as Alternative 3. Establishing Authorized Use 

at initial estimated carrying 

capacity would change the 

structure proportions of the 

current structure mosaic. The 

amount of Low structure 

would decrease. Moderate 

and High structure would 

increase, but to what degree 

is unknown. Monitoring 

would document the amount 

of shift. 

Adaptive Management: 

Adaptive management tools, 

if needed, are the same as 

Alternative 3 and 3A. The 

difference between 

Alternatives 3,3A, and 4, is 

the rate of expected change.

Because more aggressive 

initial actions are 

implemented under 

Alternative 4 the excepted 

rate of change would be 

higher under Alternative 4.

Seral stages Intensity,

frequency, and 

timing of 

disturbance on 

Removal of 

livestock grazing 

would allow for 

a shift towards 

Current 

management 

activities are not 

meeting early 

Initial management actions 

would see a shift towards

achieving the seral stage 

objective in 23 percent of 

Initial management 

actions would see a 

shift towards achieving 

seral stage objectives 

Initial management actions 

would see a shift towards 

achieving seral stage 

objectives in 33 percent of 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

xxviii | Summary

Key Issue Indicator(s)

Alternatives

1 2 3 3A 4

native species 

communities 

and 

communities 

dominated by 

invasive 

grasses.

late seral stages

and a decrease in 

early seral 

stages. However, 

increasing 

invasive grasses 

would have a 

high potential to 

impede 

development or 

maintenance of 

late seral native 

plant 

communities. 

and late seral 

stage objectives.

The current level 

of grazing 

intensity and 

frequency of 

disturbance on 

native species 

would maintain 

the current seral 

stage mosaic.

However, 

current trends in 

invasive grasses 

have the 

potential to 

increase the 

proportion of 

invaded grass 

states. 

the allotments.

Of the remaining 

allotments, 63 percent

would maintain their current 

seral stages, and 14 percent 

would see shifts away from 

the seral stage objective.

Invasive grass management 

issues would persist to 

varying degrees in about 70 

percent of the allotments, 

including half of the 

allotments experiencing a 

shift towards seral stage 

objectives.

Adaptive Management:

Adaptive management tools 

would move towards 

desired seral objectives, 

however, invasive grasses 

may gain a greater foothold 

before adaptive tools are 

implemented under this 

alternative.

in 16 percent of the 

allotments, 68 percent 

of the allotments 

would maintain their 

current seral stages, 

and 16 percent would 

see shifts away from 

the seral stage 

objective. Invasive 

grass management 

issues would persist to 

varying degrees in 

about 70 percent of the 

allotments with the 

potential for transitions 

to Invaded Grass 

States.

Adaptive Management:

Same as Alternative 3.

the allotments, 53 percent of 

the allotments would 

maintain their current seral 

stages, and 14 percent would 

see shifts away from the 

seral stage objective.

Reducing Authorized Use to 

initial estimated carrying 

capacity in native dominated 

communities would facilitate 

a shift towards late seral 

stage at a faster rate than 

Alternatives 3 and 3A. 

However, invasive grass 

management issues would 

persist to varying degrees in 

about 70 percent of the 

allotments with the potential 

for transitions to Invaded 

Grass States. 

Adaptive Management: 

Adaptive management 

actions would achieve seral 

objectives faster because 

there would be fewer 

allotments compared to 

Alternatives 3 and 3A to 

move towards seral 

objectives. 

Economics Combination 

of full and part 

time jobs and 

income for the 

12 county 

Loss of 20 to 39 

jobs and 

$359,497 to 

$708,453 in 

annual income.

Maintains 20 to 

39 jobs. 

Annual income 

to the economic 

Maintains 20 to 39 jobs with 

potential for two additional

jobs.

Annual income to the 

Same as Alternative 3.

Billings County 

economic analysis 

identified that 3A 

Potential loss of 1 to 4 jobs.

Annual income to the 

economic analysis area in 

year one would range from 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Summary | xxix

Key Issue Indicator(s)

Alternatives

1 2 3 3A 4

economic 

area.

Billings 

County 

economic 

analysis – net 

margins and 

ability to 

repay debt. 

The Billings 

County 

economic 

analysis did not 

address this 

alternative.

analysis area 

would range 

from 

$414,902 to 

$763,858.

The baseline 

assessment in the 

Billings County 

economic 

analysis showed 

that smaller 

operations (≤150 

head) have small 

net margins and 

little capacity to 

service debt. 

Larger 

operations (250-

350head) have 

larger margins 

and greater 

ability to service 

debt.

economic analysis area 

would range from $414,902 

to $763,858 

The Billings County 

economic analysis did not 

specifically address this 

alternative. As Authorized 

Use is initially the same as 

Alternative 2 the economic 

effects are expected to be 

similar to Alternative 2.

would not change their 

assessment as there is 

no initial change in 

Authorized Use. 

Therefore, economic 

effects are thought to 

be similar to 

Alternative 2.

$382,404 to$699,814. At 

year five, income would be 

$359,576 to $654,829.

Billings County economic 

analysis - Reductions in 

Authorized Use would 

reduce net revenues / net 

margins and ability to 

service debt. Smaller 

operations (≤150 head) have 

less capacity to service debt 

and would be more quickly 

affected than larger 250- 350 

head operations.

Drought Precipitation No drought 

strategy needed.

No drought 

strategy in place.

Would adapt 

DPG strategy 

when complete. 

Would use a modification of 

the McKenzie Ranger 

District strategy until the

DPG drought strategy is 

completed.

Same as Alternative 3. Same as Alternative 3.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

xxx | Summary

For comparison purposes in the table below the AMs authorized under Alternatives 2, 3, and 3A

were converted to AUMs by multiplying the Authorized Use AM number (Preference) by 1.15 

(see Grasslands Plan, Appendix I). This assumes that all of the animal units are larger cows 

within the range of 1,100 to1,300 pounds with an average of 1,200 pounds to get a conversion 

factor of 1.15 (the conversion factor is explained in detail in the Range section of Chapter 3). In 

some cases this will likely result in an over or under estimation, but, again, this is done for 

comparison purposes. 

Table S.10 — Comparison of summer Authorized Use by alternative

NOTE DISCLAIMERS ABOVE

Allot # Alternative 1

AUMs

Alternatives 

2, 3, and 3A

AUMs

Alternative 4

AUMs

126/128 0 2708 2178

127 0 474 345

129 0 1150 1000

130 0 729 678

131 0 55 48

132A 0 202 202 

132H 0 370 353

133 0 313 198

133D5 0 56 35

134 0 292 220

135 0 1793 1559

136/139 0 416 285

140 0 323 237

141 0 204 113

142 0 192 128

158 0 1801 1527

220 0 184 112

221 0 283 174

230 0 419 358

237 0 331 250

239 0 288 176

240 0 930 876

241 0 413 357

243 0 431 347
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Summary | xxxi

Allot # Alternative 1

AUMs

Alternatives 

2, 3, and 3A

AUMs

Alternative 4

AUMs

244 0 271 241

248 0 359 359

249 0 235 194

256 0 1830 1678

258 0 2382 1694

272 0 1694 1472

277 0 1298 1243

278 0 313 230

281 0 339 270

282 0 2441 2123

283 0 345 340

286 0 320 236

287 0 666 577

288 0 308 216

289 0 2057 1862

300 0 559 524

301 0 1916 1734

302 0 1201 1051

Total 0 32891 27801
FEIS Vol. I North Billings County Allotment Management Plan Revisions

xxxii | Summary

The Table S.11 presents a summary of the different initial management actions and other 

information associated with each of the alternatives.

Table S.11 — Summary of initial actions by alternative

Proposed Action Alt 1 Alt 2 Alt 3 Alt 3A Alt 4

# of allotments with 

adjusted Authorized Use

0 0 0 0 41

# and (miles)of new fence 0 0 5 (6.2) 7 (6.4) 5 (6.4)

Total forage production 0 102,522,760 102,522,760 102,522,760 102,522,760

Total Authorized Use 0 29,125 AMs 29,125 AMs 29,125 AMs 28,340 AUMs

# and (acreage) of new 

riparian exclosures 0 0 1(3) 1(3) 7 (479)

# of new rangeland water 

wells 0 0 9 9 6

# of sites and (acreage) 

proposed for native tree & 

shrub planting

0 0 0 0 2 (129)

# of new water tanks and 

(approximate miles of new 

pipeline)

0 0 22 (17.9) 27 (23.2) 13 (11.6)

# of allotments with burning, 

mechanical, or chemical 

treatment of juniper or sage 

encroachment

0 0 2 2 2

# of dugouts, reservoirs, or 

springs reclaimed 0 0 12 2 6

# of springs or reservoirs 

fenced 0 0 8 9 9

# of new spring

developments 0 0 0 2 0

# of woody draws fenced 0 0 2 0 4

# of allotments with stream 

crossing hardening and 

stream control structures

0 0 1 1 1

# of waterlots constructed 0 0 1 2 1

Projected cost of proposed 

rangeland facilities 0 0 $597,750 $646,826 $486,375
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Chapter 1| 1

CHAPTER 1

Purpose of and Need for Action

INTRODUCTION

The USDA Forest Service (FS) has prepared this Final Environmental Impact Statement (FEIS) 

in compliance with the National Environmental Policy Act (NEPA) and other relevant federal 

laws and regulations. This FEIS discloses the direct, indirect, and cumulative environmental 

impacts that would result from the alternatives. The document is organized into four chapters:

Chapter 1. Purpose Of and Need for Action: This chapter briefly describes the proposed 

action, the need for that action, and other purposes to be achieved by the proposal. It also

describes the public involvement process used and identifies key issues resulting from that 

process and issues eliminated from detailed study. Chapter 1 has been reorganized in the FEIS 

to more clearly provide the historical and legal context of the proposed action. 

Chapter 2. Alternatives, Including the Proposed Action: This chapter describes the five

alternatives considered in this analysis. It explains how the alternatives were developed, 

identifies alternatives considered in detail, alternatives dropped from further analysis, and 

design criteria associated with all the action alternatives. The chapter ends with a summary of 

the effects of implementing each alternative in relation to the purpose and need and the key 

issues.

Chapter 3. Affected Environment and Environmental Consequences: This chapter has 

been reformatted since the DEIS was published. There are now two parts to this chapter. Part 

1 provides an overview and summarizes the affected environment and environmental 

consequences for each resource. It also describes the methodology used in analyzing each 

resource. Part 2 provides specific information and effects analysis by allotment for each 

alternative and resource.

Chapter 4. Consultation and Coordination: This chapter provides a list of preparers and 

agencies consulted during the development of the FEIS.

Index: The index provides document topic by page number.

Appendices: The appendices provide more detailed information to support the analyses 

presented in the FEIS.

Additional documentation, including more detailed analyses of project-area resources, may be 

found in the Project Record, located at the Medora Ranger District.

Note: References to the 2001 Dakota Prairie Grasslands Land and Resource Management Plan 

(Grasslands Plan) page numbers pertain to the printed copies of the document. Equivalent page 

numbers on the CD copies of the Grasslands Plan may be slightly different.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

2 | Chapter 1

OVERVIEW

The North Billings County Allotment Management Plan Revisions (North Billings) project area 

is located on the Medora Ranger District, which is part of the Dakota Prairie Grasslands. The 

Medora Ranger District encompasses National Forest System (NFS) lands located in Billings, 

Golden Valley, and Slope Counties. The project area is located in northern Billings County, 

North Dakota, and a small portion of one township in northeastern Golden Valley County, North 

Dakota. It encompasses all or portions of NFS lands located in T144N, R99W, R100W, R101W, 

and R102W; T143N, R99W, R100W, R101W, R102W, R103W; and T142N, R100W and, 

R101W (Figure 1.1).

There are 43 livestock grazing allotments within the project area.

3

Table 1.1 identifies the 

grazing allotments associated with the proposed action. Figure 1.2 displays the location of the 

allotments within the project area. 

Table 1.1 — Livestock grazing allotments included in the proposed action

126 127 128 129 130 131 132A 132H 133 133D5 134

135 136/139 140 141 142 158 220 221 230 237 239

240 241 243 244 248 249 256 258 272 277 278

281 282 283 286 287 288 289 300 301 302

These allotments cover approximately 87,262 acres of NFS land, with approximately 70,871 of 

those acres being capable of sustaining grazing, as determined by the 2001 Northern Great Plains 

FEIS. In relation to grazing, the Grasslands Plan characterizes the land base as capable or

incapable of supporting grazing activity.

The Forest Service proposes to continue to permit livestock grazing on these allotments through 

a program of actions that maintains, and/or moves resource conditions towards meeting the 

Grasslands Plan objectives and desired on-the-ground conditions.

 

3 When scoped, this project proposal contained 46 grazing allotments. Since that time, the NFS lands contained 

within allotments 224, 228, 229, and pasture 4 in allotment 127 have been conveyed from federal ownership to the 

private sector. The land conveyance was done in compliance with Sec. 424. (a)Land Sale Authorization of the 

Consolidated Appropriations Act of 2008. Section 424 of the Act directs selling federal lands to offset the private 

acreage gained by the federal government in the purchase of the Elkhorn Ranch.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Chapter 1| 3

Figure 1.1 — Project area.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

4 | Chapter 1

Figure 1.2 — Grazing allotment locations.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Chapter 1| 5

HISTORIC AND LEGAL FRAMEWORK

The lands that constitute the Little Missouri National Grassland (LMNG), which contains the 

Medora Ranger District, were formerly held mostly in the private sector. Livestock grazing has 

occurred on what is now the Little Missouri National Grassland since the last half of the 19th 

century, when livestock were brought to the plains by ranchers and homesteaders in response to 

government programs, such as the 1862 Homestead Act. A combination of the 1929 stock 

market crash, national economic depression, and drought of the 1930s led to hard times for many 

Great Plains settlers. Hundreds of thousands of people left the region when faced with low land 

values, delinquent taxes, and foreclosures on their mortgages. As a result, banks, states, and the 

federal government acquired the title to millions of acres of land (Robinson 1966). 

During the 1930s, the federal government initiated a large-scale Land Utilization Program 

(LUP). Initially the program was designed to repurchase submarginal lands. However, it was 

expanded to include the transfer of land to its most suitable use (Olson 1997). In 1934, the 

Agricultural Adjustment Administration started purchasing submarginal lands across the nation. 

In areas of grasslands, grazing associations and districts were formed to integrate management of 

these lands with private ranch and farm operations. The LUP culminated with the passage of the 

Bankhead-Jones Farm Tenant Act of July 22, 1937. The Act states:

The Secretary [of Agriculture] is authorized and directed to develop a program of land 

conservation and land utilization, in order thereby to correct maladjustments in land use 

and thus assist in controlling soil erosion, reforestation, preserving natural resources, 

protecting fish and wildlife, developing and protecting recreation facilities, mitigating 

floods, preventing impairment of dams and reservoirs, developing energy resources, 

conserving surface and subsurface moisture, protecting the watershed of navigable 

streams, and protecting the public lands, health, safety, and welfare, but not to build 

industrial parks or establish private industrial or commercial enterprises‖ (Section 31, 

Title III, Bankhead-Jones Farm Tenant Act of 1937, as amended in 1962, 1966, and 

1981).

From 1938 to 1954, the Soil Conservation Service (SCS) administered the LUP. In 1954, the 

LUP was transferred to the Forest Service. On June 23, 1960, the USDA created 20 national 

grasslands from the LUP lands; the LMNG is one of the created grasslands.

Management of the Grasslands is governed under the provisions of the Bankhead-Jones Farm 

Tenant Act, the Forest and Range Renewable Resources Planning Act, the National Forest 

Management Act, Forest Service regulations 36 CFR 213 (Administration of Lands under Title 

III of the Bankhead-Jones Farm Tenant Act by the Forest Service) and 36 CFR 222 (Range 

Management), and other laws relating to national grasslands as NFS lands. 

The regulations at 36 CFR 213.1(b) state that “The National Grasslands shall be a part of the 

National Forest system and permanently held by the Department of Agriculture for 

administration under the provisions and purposes of title III of the Bankhead-Jones Farm Tenant 

Act.” Section 213.1(d) states “the resources shall be managed so as to maintain and improve soil 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

6 | Chapter 1

and vegetative cover, and to demonstrate sound and practical principles of land use for the areas 

in which they are located”. Section 213.4 states that any prior rules and regulations issued for 

land use utilization projects are superseded to all projects administered by the Forest Service. 

The Forest and Rangeland Renewable Resources Planning Act of 1974 required the Forest 

Service to develop land and resource management plans for all units of the National Forest 

System. The national grasslands were explicitly incorporated as part of the National Forest 

System. The National Forest Management Act of 1976 further directed how such land and 

resource management plans were to be developed. Specifically, such plans were to:

....provide for multiple use and sustained yield of the products and services obtained 

there from in accordance with the Multiple-Use Sustained-Yield Act of 1960, and in 

particular include coordination of outdoor recreation, range, timber, watershed, 

wildlife and fish, and wilderness.‖ (Section 6(e), National Forest Management Act, 

P.L. 94-588).

In response to the National Forest Management Act, the Forest Service developed a land and 

resource management plan for the Dakota Prairie Grasslands. The livestock-grazing part of the 

revised plan was adopted by two records of decision: Powell 2002 and Kimbell 2006. Those 

records of decision established livestock grazing as an allowable use, and provided guidance on 

how, when, and where such grazing could occur. Powell (2002) also established the Scientific 

Review Team (SRT), a panel of independent scientists that conducted 14 public meetings, 

starting in February 2003. The SRT reviewed the scientific basis for, and the practical 

application of, the new Grasslands Plan. The SRT’s final report, presented in May 2005, 

concluded that the Grasslands Plan could be implemented, but that it was impossible to 

determine whether projected stocking rates would attain the plan’s goals and objectives. The 

report also contained recommendations for improving the plan’s implementation and monitoring. 

Copies of the SRT report, and the Dakota Prairie Grasslands’ response, can be viewed online at 

the Dakota Prairie Grasslands’ website (http://www.fs.fed.us/r1/dakotaprairie). A discussion of 

how the SRT Report and Grasslands response was considered in this analysis may be found in 

Appendix C. 

The 2006 Record of Decision (ROD) established the Demonstration Project:

The purpose of the demonstration project is to: 1) develop and implement 

integrated AMPs [Allotment Management Plan] collaboratively with the 

respective grazing associations that share in the management of grazing on the 

National Grasslands; 2) to determine if Grasslands Plan Goals and Objectives are 

achievable or need modification; and 3) monitor progress towards meeting 

resource objectives. One key goal of the Demonstration Project is to maintain or 

improve current on-the ground conditions while maintaining, to the maximum 

extent possible, a grazing program at current AUM levels and providing sufficient 

habitat for grassland species (Kimbell 2006, pp 8, 9). 

The Rescissions Act of 1995 requires each National Forest System unit to establish and adhere to 

a schedule for completion of review under the NEPA, for all grazing allotments for which 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Chapter 1| 7

analysis was needed. The NEPA-phase of this project was initiated in May 2008, in part to 

comply with the Rescissions Act of 1995.

The Dakota Prairie Grasslands, including the project area, is also managed in accordance with 36 

CFR 222 (Range Management). Section 222.3(a) states that unless otherwise specified by the 

Chief of the Forest Service, all grazing and livestock use on National Forest System lands must 

be authorized by a grazing or livestock use permit. The Forest Service issues a grazing 

agreement (permit) to the Medora Grazing Association (MGA) for the NFS lands contained 

within the boundary of the MGA. Among other things, the grazing agreement authorizes 

livestock use on NFS lands, identifies the Preference for each allotment, and includes provision 

for the association to issue and administer grazing permits. As outlined in the grazing agreement, 

the MGA administration shall be in accordance with state and federal law and regulation, Forest 

Service policies and procedures pertaining to the National Grasslands, and LRMP and AMP 

direction. The MGA is the Forest Service’s permittee; however, in this document the term 

permittee is generally used in reference to the person(s) associated with the 43 allotments in this 

project. Each of these allotments has a site-specific management plan called an allotment 

management plan (AMP).

An AMP documents the actions and management strategies necessary to reach a given set of 

objectives. This includes such things as a description of necessary fences and water 

developments, a list of the permissible type and number of livestock, and details on the allowable 

season and regime of grazing. The AMPs are developed based on the details of the selected 

alternative. The selected alternative is identified in the ROD, which will accompany the Final 

EIS for this project.

AMPs are implemented through Annual Operating Instructions (AOIs). Annual Operating 

Instructions are developed each year by the individual permittees and the grazing association. 

The AOIs are then reviewed, modified if necessary, and approved by the Forest Service. These 

provisions are intended to react to resource issues identified during field monitoring, as well as to 

respond to yearly and seasonal fluctuations in weather or range conditions.

GRASSLANDS PLAN DIRECTION SPECIFIC TO PROJECT AREA

The Grasslands Plan provides several levels of direction including grasslands-wide direction

(Chapter 1), geographic area direction (Chapter 2), and management area direction (Chapter 3), 

applicable to the North Billings County Allotment Management Plan Revisions.

The project area is located in both the Badlands and Rolling Prairie geographic areas. These 

areas include management direction that is too specific to apply across the entire Dakota Prairie 

Grasslands. The geographic area direction is applied to the different areas in addition to the 

grasslands-wide direction in Chapter 1 and management area direction in Chapter 3. 

Approximately 60,872 acres (70 percent) of the project area is in Badlands and 26,390 acres (30 

percent) in Rolling Prairie geographic areas.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

8 | Chapter 1

The project area contains eight management areas (MAs). Figure 1.3 shows the management 

areas locations within the project area. The MA provides management direction in addition to the 

Grassland-wide direction identified in Chapter 1 of the Grasslands Plan. The MA direction 

applies only to those specific areas of the Grasslands assigned to a particular MA. Each MA 

identifies certain values and uses that are to be emphasized over others. The acreages represented 

by each MA are displayed in Table 1.2, followed by descriptions that include the management 

emphasis and total acres within the project area.

Table 1.2 — Management area acreage in the project area

Management 

Prescription Area

Management Area Title Total Acres

1.31 Nonmotorized Backcountry Recreation 7,155

2.1 Special Interest Areas 240

2.2 Research Natural Areas 1,771

3.51a Bighorn Sheep Habitat With Non-Federal 

Mineral Ownership 2,929

3.51b Bighorn Sheep Habitat With Non-Federal 

Mineral Ownership 1,727

3.65 Rangelands with Diverse Natural Appearing 

Landscapes 47,392

4.22 River and Travel Corridors 1,027

6.1 Rangeland with Broad Resource Emphasis 24,215

(Elkhorn Ranch–

No MA currently 

assigned)

Not Assigned

806

Total Acres 87,262
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Chapter 1| 9

Figure 1.3 — Management areas located in the project area.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

10 | Chapter 1

Management Area 1.31: Nonmotorized Backcountry Recreation

These areas are managed to provide nonmotorized, semi-primitive recreation

opportunities in a natural-appearing landscape. Where they occur, valid existing rights 

will be honored when development is proposed.

Management Area 2.1: Special Interest Areas

For the purpose of public use and enjoyment, special interest areas (SIA) are managed to 

protect sites with important physical, biological, and/or cultural characteristics. Where 

applicable, areas are managed to maintain or enhance plant and wildlife population 

viability.

Management Area 2.2: Research Natural Areas

Research natural areas (RNA) form a network of ecological reserves designated for nonmanipulative research, education, and maintenance of plant biodiversity. Proposed RNAs 

are managed as if they were officially designated RNAs until the regional forester makes 

a final decision.

Within RNAs, human influences on ecological processes are limited as much as possible, 

but are sometimes evident. Types of human use vary, but generally are not intensive. 

RNAs play an important role in an adaptive-management philosophy by serving as a 

“natural” reference for areas that are intensively managed for a particular objective.

Management Areas 3.51A: Bighorn Sheep, and 3.51B: Bighorn Sheep 

Habitat With Non-Federal Mineral Ownership

These areas are managed to provide quality forage, cover, escape terrain, and solitude for 

bighorn sheep while accounting for the possible development of non-federal mineral 

ownership. These areas might also allow petroleum resource development on federal 

minerals once non-federal production has been established.

Management Area 3.65: Rangelands with Diverse Natural Appearing 

Landscapes 

This management area emphasizes maintaining or restoring a diversity of desired plants, 

animals, and ecological processes and functions. It also provides a mix of other rangeland 

values and uses with limits on facilities to maintain a natural appearing landscape.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Chapter 1 | 11

Management Area 4.22: River and Travel Corridors 

This area is managed to protect or preserve the scenic values and recreation uses of the 

Little Missouri River Corridor. 

Management Area 6.1: Rangeland with Broad Resource Emphasis 

This area is primarily a rangeland ecosystem that is managed to meet a variety of 

ecological conditions and human needs. Ecological conditions will be maintained while 

emphasizing selected biological (grasses and other vegetation) structure and composition 

that considers the range of natural variability. These lands often display density of 

facilities; evidence of vegetative manipulation, and high levels of development, 

commodity uses, and activity. Users expect to see other people and evidence of human 

activities. Facilities supporting the various resource uses are common. Motorized 

transportation is common on designated roads and two-tracks.

Additional direction, policy, and guidance are provided by the following sources:

♦ Forest Service Manual (FSM) 2200, Range Management.

♦ Forest Service Handbook (FSH) 2209.13 Grazing Permit Administration Handbook; 

and FSH 2109.13 Pesticide-use Management and Coordination Handbook.

PURPOSE AND NEED

The Forest Service rangeland allotment management process calls for periodic reviews of 

allotment conditions and management practices. Regulation 36 CFR 222.2(c) states “Forage 

producing National Forest System lands will be managed for livestock grazing and the allotment 

management plans will be prepared consistent with land management plans.” All of the 

allotments in this analysis are due for environmental review. The Rescission Act of 1995 (P.L. 

104-19, Section 504) requires that all grazing allotments on NFS lands undergo NEPA analysis 

prior to revision of existing allotment management plans. The underlying needs for this proposal 

include:

 Some resources are not at Desired Conditions as identified by the Grasslands Plan. There 

is a need to meet or move toward Desired Conditions for those affected resources in 

accordance with Grasslands Plan direction (pp 1-2, 1-3)4 while allowing grazing on 

suitable lands and supporting local families and communities. 

 

4 A requirement of the Demonstration Project is to “determine if Plan Goals and Objectives are achievable or need 

modification, and monitor progress towards meeting the resource objectives”. The analysis completed for North 

Billings determined that the Plan goals and objectives are achievable; therefore, modification to the Plan is not 

needed and has not been incorporated. However, monitoring progress towards meeting the resource objectives is an 

integral component of the proposed action. 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

12 | Chapter 1

 There are overall needs (a) for greater management flexibility to meet Grasslands Plan 

resource goals and objectives and to cope with fluctuations in environmental and social 

conditions including, but not limited to, annual changes in weather; (b) to be responsive 

to permittee requests for reasonable operational adjustments; and (c) to respond to 

unforeseen or changing issues. 

The project-specific need for action is created by the disparity between what is present (existing 

condition) and what is wanted (desired condition) of a resource. The specific action needs for the 

allotments in this analysis are summarized in Chapter 3 of this FEIS. Table 1.3 identifies which 

resources are of concern to this analysis.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

C h a p t e r 1 | 13

Table 1.3 — Grasslands Plan desired conditions, existing conditions,

and need for action

Grasslands Plan

Desired Condition Existing Condition Need for Action

---------------------Riparian/Streams---------------------

The Grasslands Plan identifies an objective of 

meeting or moving towards Proper 

Functioning Condition on 80 percent of 

perennial streams. It also directs that corrective 

action on Functional-At Risk and 

Nonfunctional streams be initiated. Streams in 

this case include intermittent streams. 

Within the project area approximately 56.4 

miles of stream reaches associated with eleven

intermittent streams were surveyed in 2004, 

2005, 2006, and 2007 to determine their 

condition. Of the 56.4 miles of stream reaches 

surveyed, 28.6 miles (51 percent) were at 

Proper Functioning Condition (PFC); 2.5 miles 

(4 percent) were Functional-At Risk-Upward 

Trend (FAR-U); 3.3 miles (6 percent) were 

Functional-At Risk-Trend Not Apparent

(FAR-NA); 2.9 miles (5 percent) were 

Functional-At Risk-Downward Trend (FARD); and 19.1 miles (34 percent) were 

Nonfunctional (NF).

The only perennial stream in the project area is 

a small portion of the Little Missouri River. A 

field review of this portion of the river in 2010 

indicated that there were no riparian concerns.

There is a need to improve riparian and/or 

stream conditions for those intermittent stream 

reaches identified as Functional-At RiskDownward Trend or Nonfunctional (21.3 

miles of stream occurring in 22 of the 43 

allotments). 

--------------Green Ash Hardwood Draws--------------

Trees cover about 10 percent of the landscape 

on the Medora Ranger District. Of the different 

types of woodlands in the project area, only 

the green ash hardwood draws are of concern. 

The desired condition for green ash draws is 

that they are self-perpetuating and exhibit a 

multi-layer and multi-age class of herbaceous 

plants, shrubs, and trees (Grasslands Plan, 

pp.1-2, 2-10, 2-17). 

Surveys (1998, and 2005-2007) of green ash 

wooded draws across the project area show 

that approximately 51 percent are in Healthy 

condition, 42 percent are At Risk, and 7 

percent are Unhealthy. 

Lack of or low tree regeneration and heavily 

impacted or absent shrub layers are the 

primary factors affecting woodland health.

There is a need to improve the health of At 

Risk and Unhealthy green ash draws in 32 of

the 43 allotments by moving them towards 

healthy self-perpetuating, multi-layered, multiaged class communities of herbaceous plants, 

shrubs, and trees.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

14 | C h a p t e r 1

Grasslands Plan

Desired Condition Existing Condition Need for Action

---------------------Vegetative Structure-------------------

Grasslands Plan direction is to maintain a 

shifting mosaic of vegetation structure across 

the landscape.

The desired vegetative mosaic is composed of 

the Badlands and Rolling Prairie geographic 

area vegetation structure objectives. These 

objectives identify a desired array of Low (10-

20 percent), Moderate (50-70 percent), and 

High (20-30 percent) structure across the 

geographic areas.

Generally, desired high and low structure 

objectives are not being met in the project 

area. 

Survey data from 1996 to 2005 show High 

structure ranged from 1 to 20 percent, 

Moderate structure ranged from 56 to 71 

percent, and Low structure ranged from 23 to 

53 percent.

There is a need to increase the amount of High 

structure and decrease the amount of Low 

structure across the project area.

-------------------Vegetative Seral Stages-------------------

Seral stages are the successional stages a plant 

community progresses through over the course 

of time. Seral stages range from early pioneer 

vegetation to climax vegetation. 

The desired condition for seral stage is 

composed of the Badlands and Rolling Prairie 

geographic area seral stages objectives located 

in Chapter 2 of the Grasslands Plan. Seral 

objectives are 10-15 percent in early seral 

stage, 65-75 percent in mid seral stage, and 15-

20 percent in late seral stage across the 

geographic areas. 

Surveys completed (1996-2001 and 2004-

2010) across the project area indicate that 

approximately 7 percent of the area is at early 

seral stage; 72 percent of the area is at mid 

seral stage; 5 percent of the area is at late seral 

stage; and 16 percent is at an Invaded Grass 

State where seral stage was not classified. 

There is a need to increase the amount of late 

and early seral stages and reduce the amount 

of mid seral plant communities. There is also a 

need to increase the maintenance of native 

plant communities, and limit the spread of 

invasive species and transitions to Invaded 

Grass States.
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PROPOSED ACTION

The Forest Service proposes to continue to permit livestock grazing on these allotments through 

a program of actions that maintains and/or moves resource conditions towards meeting the 

Grasslands Plan objectives and desired on-the-ground conditions. Grazing management (program 

of actions) would be carried out so that it meets or moves impacted resources towards Grasslands 

Plan desired conditions. This would be achieved by implementing initial actions and through the 

application of adaptive management strategies if initial actions fail or can’t be implemented. The 

proposed action also includes a monitoring plan and interim drought strategy which are 

described in detail in Chapter 2. It is designed to:

 Provide adaptive management flexibility to meet changing conditions. 

 Contribute to the general economic and social vitality of the local area.

 Meet direction contained in the demonstration project, including recommendations from 

the FS Final Response to the SRT Report.

 Move impacted resources towards Grasslands Plan desired conditions. 

Collectively the 43 allotments in this analysis contain approximately 87,262 acres of NFS lands. 

There are also private and state lands associated with many of the allotments. However, the 

proposed action, Alternative 3, proposes activities only on NFS lands and discloses effects 

associated with the proposed action and other alternatives.

ADAPTIVE MANAGEMENT

Three of the action alternatives contained in the analysis—Alternatives 3, 3A and 4—are built on 

the principle of adaptive management. The following discussion is presented to help the reader 

better understand this concept as applied to range analysis and range management decision 

making. 

Adaptive management is defined as, “A system of management practices based on clearly 

identified intended outcomes and monitoring to determine if management actions are meeting 

those outcomes; and, if not, to facilitate management changes that will best ensure that those 

outcomes are met or re-evaluated. Adaptive management stems from the recognition that 

knowledge about natural resource systems is sometimes uncertain” (36 CFR 220.3). It is a 

process that allows the responsible official to deal with uncertainty and changing conditions over 

time and it provides for constrained flexibility to adapt to changing conditions or unanticipated 

resource response. Adaptive management is based on the assumption that current resources and 

scientific knowledge are limited and a certain level of uncertainty exists. To a degree it also 

acknowledges the “art” of natural resource management. Nevertheless, an adaptive management

approach attempts to apply available resources and knowledge and adjusts management 

techniques as new information is revealed.
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In terms of natural resource management, adaptive management focuses on meeting or moving 

toward the desired condition objectives on the ground. This is a significant shift in how we think 

about range planning in that the proposed action focuses on what we want the ground to look like 

and what constraints are necessary to get there, rather than focusing on how many cattle to 

permit or which fence to build. 

Under the traditional approach to completing the NEPA process, issues are identified, 

management actions are proposed to address those issues, an environmental impact analysis is 

completed, and mitigation measures are created. Unfortunately, this process does not account for 

unanticipated changes in environmental conditions, inaccurate predictions, or subsequent 

information that might affect the original decision. The Council on Environmental Quality

(CEQ) recognized that by adding “monitoring and adaptation” to the traditional “predict, 

mitigate, and implement” NEPA model, the concept of adaptive management could be 

incorporated into the NEPA process. The Forest Service added direction regarding adaptive 

management in its Federal Regulations in 2008 (36 CFR 220) and its associated NEPA 

Handbook (FSH 1909.15, 14.1). 

As previously identified, the traditional approach to the NEPA process does not provide the 

decision maker with much latitude to adjust actions once a decision has been made. For example, 

say that on allotment X the decision is to permit 203 cow/calf pairs for a season of June 3 to 

September 14 under a three-pasture deferred rotation grazing system. However, after the decision 

is made an opportunity or need is presented to use some electric fencing to create a riparian 

pasture in a problem area. Essentially, there is a need to apply different techniques to better 

achieve the objectives specified in the NEPA decision. This leaves the responsible official with 

the situation of either continuing existing management, knowing that it is not meeting the current 

needs, or re-entering the NEPA process to re-evaluate new management practices and then to 

revise the existing NEPA-based decision.

Under an adaptive approach, the NEPA process considers an initial set of actions to address a set 

of issues and identifies a series of additional adaptive options that can be implemented if 

monitoring indicates there is a need to change management actions. Because these additional 

options are analyzed in the NEPA document, it provides the responsible official with 

“constrained flexibility” to adapt to changing conditions within the realm of the identified 

adaptive options. While it is impossible to predict all potential changes, or to plan for dealing 

with all uncertainty, implementing an adaptive management approach provides more flexibility 

in the management of the range and associated resources.

The key feature of adaptive management is its use of monitoring. Monitoring is the basis on 

which management changes are proposed. In other words, if some aspect of the planned 

management is shown by monitoring to be ineffective or cannot be implemented as planned, then 

a team composed of Forest Service specialists in consultation with the affected permittee and the 

Medora Grazing Association (MGA) director would make a recommendation to the district 

ranger. The recommended course of action would be based on the adaptive options identified in 

Chapter 3 Part 2 under the third table for each allotment and/or the Grazing Management 
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C h a p t e r 1 | 17

Toolbox (Table 2.4). The adaptive actions are evaluated in Chapter 3 of this analysis. Figure 1.4

is a flowchart showing how adaptive management works. 

SCOPE OF THE PROPOSAL

Geographic Scope

The Medora Ranger District has prepared this Final Environmental Impact Statement (FEIS) to 

document additional information and analysis resulting from comment and review on the Draft 

Environment Impact Statement (DEIS), and subsequently the Supplemental Environmental 

Impact Statement (SEIS). 

The project area encompasses 43 livestock grazing allotments. The allotments are made up of 

NFS, state, and private lands. 

The project area (Figure 1.1) encompasses approximately 118,354 acres of intermingled private, 

state, and NFS lands. There are approximately 87,262 acres of NFS lands associated with the 

allotments included in this analysis. The majority of the allotments in this analysis are located in 

the Badlands geographic area with the remainder located in the Rolling Prairie geographic area. 

Some of the allotments contain portions of both geographic areas.

Temporal Scope

This proposal would be implemented the grazing season following the signing of a Final ROD

for this project. Information contained in the FEIS would be used to create new AMPs for the 

allotments. The issuance of AMPs to reflect the selected alternative would not be subject to 

further NEPA documentation as long as the FEIS analysis and decision remain valid. 

Administrative Scope

AMPs will be developed from information contained in the FEIS and will be based on the 

decision associated with the FEIS. The AMPs guide livestock management within the allotments, 

with adaptive adjustments being implemented based on monitoring. 

Five alternatives were developed and analyzed in detail for this project. The alternatives are 

described in detail in Chapter 2 of this document.

The proposed action is limited to the continuation of grazing activities on NFS lands. It includes 

initial management actions to address resource concerns, adaptive management actions, 

monitoring, and feedback. 

This FEIS was developed under the implementing regulations of NEPA; the CEQ, Title 40, Code 

of Federal Regulations, Parts 1500-1508 (40 CFR 1500-1508); and the National Forest 

Management Act (NFMA). The proposal is not a general management plan for the area. The 

FEIS is the site-specific NEPA documentation for the proposal, and is not a programmatic 

analysis. General management direction is found in the Grasslands Plan.
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Figure 1.4 — Adaptive management approach

for the action alternatives.

NO

Describe the desired outcome, goals/objectives.

Ex. 80 % of riparian areas 

are at Properly Functioning 

Condition (PFC).

Apply initial management actions 

(These are identified in Chapter 3, Part 

2). Ex. Modify rotation to minimize 

impacts to stream.

Is the desired 

outcome being 

accomplished?

Ex. 80% of 

streams are at or 

moving towards 

Monitor affected resource(s).

Ex. Conduct PFC surveys on streams.

Are the 

management 

actions having a 

measurable effect?

Continue with initial 

and/or revised 

management actions.

YES

NO

Review available adaptive 

actions, select action(s) and 

implement.

Ex. Create riparian pasture.

Review available adaptive actions, select 

action(s) and implement. Ex. Develop 

other water source(s) to draw livestock 

off of stream.
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DECISION FRAMEWORK

The Grasslands Supervisor is the responsible official who will decide, through alternative

selection, whether or not to continue livestock grazing on all or portions of the 43 allotments and,

if so, under what terms and conditions so as to meet or move toward meeting Grasslands Plan 

objectives in a timely manner. He or she may select any of the alternatives or create a new 

alternative within the range of the existing alternatives. He or she is also responsible for 

determining whether or not this project requires any site-specific amendment(s) to the Grasslands 

Plan.

Once the decision process is complete AMPs will be written based on the alternative selected.

The AMP is the implementation document by which the Forest Service communicates the 

management objectives and planned actions to accomplish those objectives.

The FEIS is not a decision document. Rather it discloses the environmental consequences of 

implementing the proposed action and alternatives to that action. The Grasslands Supervisor has 

reviewed the FEIS in its entirety and has selected the alternative that is to be implemented and 

has documented his reasoning in a Draft ROD.

TIERED AND REFERENCE DOCUMENTS

Agencies are encouraged to tier their analysis documents to other analyses as a means to 

eliminate repetitive discussions of the same issues (40 CFR 1502.20). Agencies are also directed 

to incorporate, by reference, material that will help cut down the bulk of a document (40 CFR 

1502.21). All of the following documents supporting this analysis are located in the Project 

Record.

The environmental analysis documented in this assessment is tiered to the 2001 FEIS for the 

Grasslands Plan. The 2001 FEIS describes the existing condition of the DPG and evaluates the 

environmental consequences of different management alternatives. It is the analysis from which 

the Grasslands Plan was derived. 

The analysis also tiers to the 2007 Noxious Weed Management Project FEIS. This FEIS

evaluates the environmental consequences related to the use of an integrated adaptive approach 

to treating existing and future infestations of noxious weeds.

Incorporated by reference is the 2001 Dakota Prairie Grasslands Revised Land and Resource 

Management Plan (Grasslands Plan), and its 2002 and 2006 RODs. The 2002 Grasslands Plan 

establishes the management direction for the DPG in compliance with the 1976 NFMA, the 1969 

NEPA, and other laws and regulations. Detailed information concerning applicable goals, 

objectives, standards, guidelines, and other management direction from the Grasslands Plan and 

its RODs is incorporated by reference into the FEIS. 

The 2002 Little Missouri National Grassland Rangeland Assessment—specifically, information 

related to woody draws, herbaceous structure and composition, wildlife, and riparian areas—is 

incorporated by reference into this analysis. 
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The Watershed Conservation Practices Handbook (FSH 2509.22) is also incorporated by 

reference. 

PUBLIC INVOLVEMENT

A scoping letter was sent to 103 interested parties on May 23, 2008. The letter asked that 

comments on the proposed action be received by June 23, 2008. A notice of intent (NOI) to 

prepare an environmental impact statement (EIS) for the North Billings project was published in 

the Federal Register on May 15, 2008.

The Forest Service held public open-house meetings on June 17, 2008, in Dickinson, ND, and on 

June 18, 2008, in Bismarck, ND. News releases announcing the open houses were sent to the 

Bismarck Tribune, which is the DPG newspaper of record, the Dickinson Press, the Bowman 

County Pioneer, The Herald, and the Golden Valley News. An announcement was also sent to 

Dickinson and Bismarck, ND, televised Community Calendars. The Forest Service also invited

public comment through publication of the proposal in the January 2008 DPG Schedule of 

Proposed Actions (SOPA). 

The DEIS was mailed to a total of 66 individuals; groups; and federal, state, and county agencies 

on June 30, and July 1, 2009. A news release announcing the release of the DEIS was sent to the 

Bismarck Tribune, six other daily newspapers, and numerous radio and television stations on 

July 1, 2009. The Notice of Public Comment for the DEIS was published in the Bismarck 

Tribune on July 3, 2009. The North Dakota Congressional Delegation was contacted by phone 

and sent a briefing paper on July 1, 2009. The briefing paper was also faxed to the Billings and 

Golden Valley County Commissions and the Medora Grazing Association (MGA). On July 2, 

2009 a copy of the news release announcing the release of the DEIS was faxed to the Billings 

and Golden Valley County Commission and the MGA.

The notice of availability for the DEIS appeared in the Federal Register on July 10, 2009. The 

comment period on the DEIS was to have closed on August 14, 2009. However, on August 13 it 

was discovered that the e-mail address for comments was incorrect. The district ranger extended 

the comment period to September 4, 2009, to accept any comments that may not have been 

received due to the incorrect address. A letter was sent to the project mailing list on August 25, 

2009, extending the comment period, and a new Notice of Comment was published in the 

Bismarck Tribune on August 28, 2009. 

In an effort to further expand the comment base and the opportunity for public participation, the 

district ranger further extended the public comment period to October 10, 2009; however, 

comments were accepted until October 13, 2009, because of the Columbus Day holiday. A letter 

was sent to the project mailing list on September 4, 2009, and a news release announcing the 

extension was sent to numerous television, radio, and newspapers on the same day. The district 

ranger, on September 4, 2009, notified the MGA, Billings County, and the congressional 

delegation of the October extension by phone. An amended notice extending the comment period 

to October 13, 2009 was published in the Federal Register on September 18, 2009. A total of 13

comments were received on the DEIS.
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In order to respond to public comments received on the DEIS, and based on the time that had 

passed (almost 2 years) since the DEIS had been distributed, the DPG decided to take an extra 

step to ensure the public had seen, and had a chance to comment on, this important document. To 

that end, the Medora Ranger District of the DPG completed the SDEIS for the North Billings 

County AMP Revisions (USDA Forest Service 2011). The SDEIS rearranged the analysis to 

display both a landscape analysis by resource issue (SDEIS, Vol. I, Chapter 3, Part 1) and an 

allotment-level analysis by resource issue (SDEIS, Vol. II, Chapter 3, Part 2). The SDEIS also 

responded to comments by including an additional alternative, 3A; included more information on 

soil capability, soil productivity, and water quality; and included discussions to address 

unavailable information and scientific controversy to name a few of the changes. The notification 

of availability for the document was published in the Federal Register on July 8, 2011. The 

SDEIS was mailed to a total of 80 individuals, groups, and federal, state, and county agencies on 

July 1, 2011. Chapter 4 of the SDEIS lists the agencies, organizations, and people who received 

copies of the SDEIS. A news release announcing the release of the SDEIS was sent to the 

Bismarck Tribune and numerous other newspapers and radio and television stations on July 1, 

2011. The North Dakota congressional delegation was contacted by phone and sent a briefing 

paper on July 1, 2011. The Billings County Commission and MGA were called as well to inform 

them of the availability of the SDEIS. Briefings and/or question-and-answer sessions were 

provided at both the MGA July monthly board of directors meeting and the Billings County 

Commissioners August meeting. The Notice of Public Comment for the SDEIS was published in 

the Bismarck Tribune on July 8, 2011. 

A news release was sent to the media, reminding the public of the August 22, 2011, deadline for 

SDEIS comments. However, in an effort to further expand the comment base and the opportunity 

for public participation, the District Ranger further extended the public comment period to 

September 21, 2011. On August 15, 2011, a letter was sent to those on the project mailing list, 

and a news release announcing the extension was sent to numerous television and radio stations 

and to newspapers on the same day. The Bismarck Tribune published the Notice of Public 

Comment extension on August 26, 2011. A total of 65 comments were received on the SDEIS.

KEY ISSUES 

An issue is an effect on a physical, biological, social, or economic resource. An issue is not an 

activity in itself; instead, it is the projected effects of the activity that create the issue. For 

example, livestock grazing is an activity, but its effects on a resource can form an issue. A key 

issue suggests different courses of action thus suggesting alternatives and detailed analysis. The 

Forest Service identifies key issues through contact/discussion (scoping) externally with the 

public, organizations, and other state and federal agencies and internally.
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The interdisciplinary team (IDT) considered external and internal comments and discussions

received during scoping, ongoing issues associated with general livestock management on the 

Medora Ranger District, and landscape information generated from the 2002 Little Missouri 

National Grassland Rangeland Assessment to identify key issues to be analyzed in this 

document. The IDT identified six key issues for the project area. The district ranger concurred 

and directed that these key issues should be carried through the analysis. The key issues, along 

with the indicator(s) of each issue, are presented below (a brief explanation of the indicator is 

also provided). Indicators are used to evaluate or measure the effects of an alternative on the 

different resources.

KEY ISSUE #1. RIPARIAN AREAS: There is a concern that livestock grazing is adversely impacting 

intermittent streams through excessive use of riparian vegetation, trampling and trailing of 

stream banks, loafing, etc. Intermittent streams typically flow seasonally when they receive 

water from surface sources such as snow melt, storm runoff, or from ground water discharge. 

Major intermittent streams on NFS lands in the project area were surveyed from 1997 through 

1999, and in 2004, 2006, and 2007 using the Proper 

Functioning Condition protocol (Pritchard et. al., 

1998). Approximately 56.4 miles of stream reaches 

associated with 11 streams were surveyed. Of the 

surveyed stream reaches, 28.6 miles (51 percent) were 

at Proper Functioning Condition (PFC); 2.5 miles (4 

percent) were Functional-At Risk-Upward Trend

(FAR-U); 3.3 miles (6 percent) were Functional-At

Risk-Trend Not Apparent (FAR-NA); 2.9 miles (5

percent) were Functional-At Risk-Downward Trend

(FAR-D); and 19.1 miles (34 percent) were 

Nonfunctional (NF).

Functional-At Risk and NF streams exhibit an 

inadequate amount of residual vegetation to trap 

sediments from fall/spring runoff or to control erosive 

energy in the channel. They display poor channel 

morphology (structure) and are affected by excessive 

bank trampling and lack of desired riparian plant 

communities. The Grasslands Plan provides guidance 

for streams identified as non-functioning or functioning 

at risk with a downward trend that corrective action 

should be taken within three years of stream inventory 

(Grasslands Plan Ch. 1, p. 1-11). The Grasslands Plan 

also allows only those actions next to perennial and 

intermittent streams, seeps, springs, lakes, and wetlands 

that maintain or improve long-term proper functioning 

of riparian ecosystem conditions (Grasslands Plan Ch. 

Proper Functioning Condition (PFC)

means that the stream has adequate 

streambank vegetation, proper stream 

morphology (structure), or instream 

structures (i.e. woody debris, rock, etc.) 

present to dissipate stream energy, 

during high flows. This results in 

benefits including, but not limited to, 

reduced erosion, sediment and 

bedload capture, floodplain 

development, improved water quality, 

ground-water recharge, and 

development of streambank root 

masses. 

Functional-At Risk means that riparian 

areas are in a functional condition but 

one or more properties(such as soil, 

water, or vegetation) are impaired,

which makes the riparian area 

susceptible to degradation. 

Nonfunctional means that the riparian 

area is not functioning properly. 

Typically, nonfunctioning riparian areas 

do not provide adequate vegetation, 

channel properties, or woody debris to 

dissipate stream energy associated 

with high flows and thus do not reduce 

erosion, improve water quality, capture 

sediment, etc.
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1, p. 1-9). Some causes of stream degradation include livestock grazing and road impacts.

Indicators: Existing stream condition and movement towards PFC based on riparian vegetation 

condition, sediment entrapment, and stabilization of stream banks and beds.

These indicators provide a qualitative estimate of how well an alternative would move FAR and 

NF intermittent stream segments towards PFC.

KEY ISSUE #2. GREEN ASH HARDWOOD DRAWS: There are several different types of woodland 

communities in the project area including Rocky Mountain juniper, aspen, cottonwood, and 

green ash hardwood draws. The woody draws are generally in good condition; however, there is 

a concern that effects from livestock grazing including browsing, trampling, lounging, etc are 

adversely affecting the distribution of tree and shrub age classes in green ash hardwood draws. 

From this point forward green ash hardwood draws will be referred to as woody draws. 

Three different sets of woody draw surveys were collected and used to assess woody draw 

conditions. The sampled woody draws were rated as Healthy, At Risk, or Unhealthy. Of the 

green ash woody draws that were surveyed, 51 percent were Healthy, 42 percent were At Risk,

and about 7 percent were Unhealthy. 

The Grasslands Plan provides guidance for 

woody draws and riparian areas to move at least 

80 percent toward self-perpetuating plant and 

water communities that have desired diversity 

and density of understory and overstory 

vegetation within site capability (Grasslands 

Plan Ch. 1, p. 1-2).

Indicator: Existing woody draw condition and 

degree of movement towards desired conditions 

based on the effects of intensity, frequency, and 

season of disturbance on tree and shrub 

regeneration. The indicator is expressed in 

terms of Healthy, At Risk, or Unhealthy 

condition.

These indicators are intended to provide a 

qualitative measure of how well an alternative 

will improve the health of At Risk and 

Unhealthy woody draws. Intensity, frequency, 

and season of disturbance are directly related to 

the health of a woody draw. Different 

combinations of these factors can improve or adversely affect woody draw health. 

Healthy woody draws are defined as those 

woodlands that have self-perpetuating tree and 

shrub populations with diverse age classes, 

species composition, and multiple structural 

layers as habitat conditions permit. 

At Risk woody draws tend to exhibit a moderate 

distribution of tree age classes, but lack 

consistent regeneration as expressed by sapling 

and young tree age classes. Desirable tall shrub 

(e.g., chokecherry, serviceberry) distribution 

tends to be patchy, and/or low shrubs (such as 

snowberry) dominate the shrub layer.

Unhealthy woody draws are generally 

characterized by old or decadent tree layers and 

a lack of younger age classes ranging from 

saplings to small diameter trees. The understory 

is dominated by invasive grasses or short shrubs 

such as snowberry. 
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KEY ISSUE #3. HERBACEOUS STRUCTURE: There is a concern that livestock grazing has affected 

the mosaic of herbaceous structure in the project area, which has generally resulted in too little 

High structure and too much Low structure in light 

of Grasslands Plan structure objectives. Structure is 

an important measure for wildlife habitat, especially 

ground-nesting birds, but also has implications for 

other ecosystem attributes and rangeland health. 

Livestock management influences structure through 

several factors including intensity, frequency, and 

timing of grazing activity. 

The Grasslands Plan identifies a desired range for 

herbaceous structure as 10 to 20 percent in Low, 50

to 70 percent in Moderate, and 20 to 30 percent in 

High structure (Grasslands Plan, Ch. 2, pp. 2-13, 2-

19).

Visual Obstruction Reading (VOR) surveys conducted in the project area for 2004 and 2005 

show High structure ranging from 0.6 to 7 percent, Moderate structure ranging from 47 to 64

percent, and Low structure from 30 to 53 percent. These surveys were conducted on biologically 

capable lands within the project area. VOR surveys conducted from 1996 to 2001 in Billings 

County show High structure ranging from 3 to 8 percent, Moderate structure ranging from 47 to 

83 percent, and Low structure from 11 to 49 percent. VOR surveys specific to the project area 

conducted between 1996 to 2001 show High structure ranging from 5 to 20 percent, Moderate 

structure from 56 to 70 percent, and Low structure ranging from 23 to 36 percent.

Indicator: Trend of High structure.

This indicator is intended to provide a quantitative estimate of how well an alternative would 

move herbaceous vegetation towards desired structure objectives. The potential trend of High 

structure was evaluated by comparing the level of Authorized Use relative to the initial estimated 

carrying capacity, as well as how livestock management could affect High structure. When 

Authorized Use exceeds carrying capacity there is greater utilization of the existing forage, 

which results in a greater amount of Low to Moderate structure. If Authorized Use is at or below 

the carrying capacity, then High structure may increase to some degree; however, the level of 

increase would depend upon a variety of factors such as the time, intensity and duration of 

livestock grazing and would be monitored to see if additional adjustments in Authorized Use or 

timing of grazing are warranted.

KEY ISSUE #4. VEGETATIVE SERAL STAGES: Seral stage refers to the current composition of plant 

species that occur along a continuum between early plant establishment and a climax plant 

community. The Grasslands Plan uses vegetative seral stages to identify desired condition for 

plant species composition. From this point forward vegetative seral stages will be referred to as 

seral stages. Seral stages are expressed as early, mid, and late stages. Plant communities change 

Low Structure is defined as a Visual 

Obstruction Reading (VOR) reading 

between 0 and 1.49 inches.

Moderate Structure is defined as a VOR 

reading between 1.5 and 3.5 inches.

High Structure is defined as a VOR 

reading greater than 3.5 inches.
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as they move from one seral stage to the next. A mosaic of seral stages is normally spread across 

the landscape. 

There is a concern that a combination of the expansion of invasive grass species and current 

grazing strategies is adversely affecting the desired mosaic of seral stages and maintenance of 

native plant communities. The current distribution 

of seral stages across the project area is 

approximately 7 percent in early seral stage, 72 

percent in mid seral stage, and 5 percent in late 

seral stage. Approximately 16 percent of the 

sample sites are at an Invaded Grass State (NRCS, 

2009) and not included in the seral stage analysis. 

The Grasslands Plan objectives for seral stages are 

to have 10 to15 percent in early seral stage, 65 to 

75 percent in mid seral stage, and 15 to 20 percent 

in late seral stage.

Indicator: Trend of seral stages.

This indicator provides a quantitative estimate of 

how well an alternative is moving the project area 

towards desired seral stage (plant composition) objectives. Intensity, frequency, and timing of 

grazing disturbance can have differing effects on plant composition and trends towards late or 

early seral stages, as well as trends of invasive grasses.

As intensity and frequency of grazing increase in a native grass community there is generally a 

shift towards an earlier seral stage. A reduction in intensity and frequency of grazing tends to 

facilitate the development of late seral stages, but can be complicated by trends of invasive 

species. The timing of grazing disturbances also influences trends in plant composition as a 

result of differences in species palatability that change during the year, thus affecting their 

degree of desirability and selective use by grazing livestock. Species that are actively selected 

are likely to decrease in occurrence, while species that are avoided or undesired are likely to 

increase. The timing of grazing also influences the ability of plants to complete critical growth 

stages, thereby influencing plant vigor, production, and the maintenance of desired plant 

composition.

KEY ISSUE #5. ECONOMICS: Potential reductions to Authorized Use are likely to have an effect 

on the economics of the individual permittee and adjacent communities. Calculating potential 

impacts to an individual permittee is very complicated and requires information not readily 

available. The broader concern, however, is related to how the range of alternatives would affect 

jobs and income in the agricultural sector which includes livestock grazing. The economic 

analysis in this document is focused on the effects of the alternatives on jobs and income within 

an identified economic impact area of associated counties.

Early seral stage is the plant community that 

occurs after a significant disturbance such as 

heavy continuous seasonlong grazing. 

Mid seral stage is the plant community that

is transitioning between early and late seral 

stages and typically develops under more 

stable environmental conditions, but can 

occur under a moderate level of disturbance.

Late seral stage is a plant community that 

develops with extended periods of no or 

little disturbance, and approaches 

composition of a climax plant community.
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The analysis also considers an economic analysis completed by North Dakota State University 

(NDSU) for Billings County, ND. The NDSU analysis looks at the effects of two of the four 

alternatives in terms of changes in gross sales and net revenues from cow-calf operations and 

debt repayment capabilities.

Indicator: The Forest Service indicator is jobs and income generated in the agricultural 

community. The indicators associated with the NDSU study are cumulative net margins and debt 

repayment capability.

This indicator is intended to give a quantitative measure of how an alternative will affect jobs 

and income in the agricultural sector within the identified economic impact area for this project.

KEY ISSUE #6. DROUGHT: A major factor affecting herbaceous structure, forage availability, and 

other resources across the landscape is drought. The Grasslands Plan (Appendix G, p. G-15) 

defines drought as any year or sequence of years when annual precipitation amounts are 75 

percent or less of normal. Based on this definition, drought has occurred in 21 percent of the 

years in the northern Great Plains, since 1940 (Holechek et.al. 1989). Within the past 10 years 

drought has occurred on the Little Missouri National Grasslands about 40 percent of the time 

according to the U.S. Drought Monitor (http://drought.unl.edu.dm).

When there is a lack of precipitation during the growing season (April thru July) it has a major 

impact on the production of forage. Less available forage results in utilization levels being 

reached earlier in the grazing season which results in fewer days of grazing. The DPG currently 

doesn’t have a unit-wide drought strategy but is in the process of creating one. During this 

interim period a modification of the drought strategy identified in the 2005 NE McKenzie 

Allotment Management Plan Revisions FEIS will be used. Once the DPG drought strategy is 

completed it will replace the interim strategy. Drought is an important factor affecting livestock 

management on the DPG. It is included as an issue to highlight its importance and is addressed 

through inclusion of an interim drought strategy in the Design Criteria identified in Chapter 2.
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ISSUES ELIMINATED FROM DETAILED STUDY 

This section identifies issues that were dropped from detailed study and why they were not 

carried forward through the rest of the FEIS. This is consistent with Council on Environmental 

Quality (CEQ) direction concerning non-significant issues and narrowing discussion to keep an 

EIS as concise as possible. Issues eliminated from detailed study include: archeology, noxious 

weeds, threatened and endangered (TE) plants, sensitive plants, recreation, TE wildlife species, 

sensitive species, management indicator species (MIS), raptors, soils, and soil capability.

The CEQ directs that environmental impact statements shall be kept concise and shall not be 

longer than absolutely necessary to comply with NEPA and CEQ regulations (40 Code of 

Federal Regulations (CFR) 1502.2 (c)). The CEQ continues at 40 CFR 1501.7(a) (3) with 

direction to “Identify and eliminate from detailed study the issues which are not significant . . . 

narrowing the discussion of the issues in the statement to a brief presentation of why they will 

not have a significant effect on the human environment or providing a reference to their coverage 

elsewhere.” Again, at 40 CFR 1502.2(b), the CEQ identifies that “Impacts shall be discussed in 

proportion to their significance. There shall be only brief discussion of other than significant 

issues. As in a finding of no significant impact, there should only be enough discussion to show 

why more study is not warranted.”

Archeology

The following discussion summarizes information contained in the Archeology Report (Project 

Record, Specialist Reports and Notes) prepared by the Forest Service zone archeologist for the 

Little Missouri National Grasslands (LMNG). The archeology analysis covers the original 

project area which contained approximately 149,140 acres. Since then the project area was 

reduced to about 87,262 acres. The conclusions determined by the archeology report are, 

however, still valid for the smaller project area (Project Record, Specialist Reports and Notes, 

Archeology Report).

The North Billings project area is located in the Little Missouri River Study Unit according to 

the North Dakota Comprehensive Plan of Historic Preservation: Archeological Component 

(SHSND 1990). This area has witnessed the entire span of human prehistoric and historical

occupation in North Dakota over approximately the past 12,000 years. 

CULTURAL SITES

To date, 840 resource projects have been conducted in the North Billings project area. A 

complete bibliography of those projects is included in the Archeology Report. Inventories of 

ground-disturbing projects constitute the majority of the projects. A total of 55,147 acres of 

federal land have been surveyed. This represents approximately 37 percent of the total federal 

acres under study (149,140 acres). The inventories have resulted in the location and recording of 

304 cultural sites within the North Billings project area. The sites are listed in Appendix I, of the 

Archeology Report, by site number, site type, and eligibility. The site density is calculated at one 
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site per 181 acres of inventory. At this density, an additional 519 sites can be estimated to be 

present but not yet located and recorded.

Of the 304 sites, 37 (about 12 percent) are considered to be eligible for the National Register of 

Historic Places (NRHP), although none are currently listed on the National Register. An 

additional 80 sites (about 26 percent) have been formally determined ineligible for the National 

Register. The remaining 187 sites, nearly 62 percent, are of undetermined eligibility and require 

further work prior to evaluations of eligibility. Sites that are of undetermined eligibility are 

treated as if they were eligible sites until they have been proven to be not eligible.

TRADITIONAL CULTURAL PROPERTY

A Traditional Cultural Property (TCP) is defined as one that is eligible for inclusion on the 

NRHP because of its association with cultural practices or beliefs of a living community that (a) 

are rooted in that community’s history, and (b) are important in maintaining the continuing 

cultural identity of the community (USDI Bulletin 38). No TCPs are known to be present within 

the North Billings planning area.

GRAZING AND RANGELAND MANAGEMENT EFFECTS

A sampling of sites was monitored during the 1997 and 1998 field seasons in an attempt to 

assess effects on cultural resource sites from grazing and rangeland management projects. The 

results from this monitoring were summarized in Floodman (2000). Three broad categories of 

effect were utilized: livestock, range improvements, and vehicular trails. These are discussed 

briefly below.

 Livestock effects are those directly related to the presence of cattle on the site or 

movement of cattle across the site. These effects were divided into two types of effect: 

trailing and loafing/trampling.

 Range improvements are projects constructed on the ground for the improvement of 

pastures and the grazing of cattle. Range improvements defined for the study include 

spring developments, water wells, water pipelines, watering tanks, stock dams/reservoirs, 

and fences.

 Vehicular trails cross the grasslands and are used by many visitors other than for the 

permitted grazing actions. Most of the developed pipeline watering systems either 

parallel trails, or else trails have developed adjacent to the lines.

Of the 304 sites within the project study area, 141 (approximately 46 percent) were within the 

1998 monitor results. Of these, 109 (approximately 77 percent of the monitored sites) are within 

the allotment areas being studied and formed the basis of the effects analysis. The sites are listed 

in Appendix I of the Archeology Report, which is located in the Specialist Reports and Notes 

section of the Project Record.

Of the 109 sites being used for the effects analysis, 33 (approximately 30 percent) were noted to 

have some type of effects from cattle, range improvements, or vehicular use across the site 
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boundaries. Of these, severe and adverse effects were noted on 14 of the sites. Those sites with 

light to moderate impacts from cattle trailing and trampling are not considered adverse. No 

effects were noted at 76 sites, (approximately 70 percent) of the sites monitored. Of the 14 sites

with severe and adverse effects, closer examination reveals that four sites have suffered adverse 

effects due to pipeline construction, road construction, or cattle trampling or trailing. These sites 

have all been mitigated.

CONCLUSION

Adoption of management practices to address other resource issues will help to alleviate adverse 

effects on cultural resource sites due to overgrazing in some areas and from the concentration of 

cattle within site areas. All water sources are away from the cultural sites recorded in all 

instances of effect and are not a source of damage in this project area. New plans will result in 

more stable soils, increased sod cover, and will help reduce the potential for erosion of cultural 

sites and loss of integrity in the pasture areas.

Under the action alternatives, new fences, water developments, or other improvements may be 

required. A cultural resource inventory is mandated prior to any ground-disturbing action. The 

projects will be surveyed and cultural sites will be recorded and evaluated in accordance with the 

established criteria for nomination to the NRHP for all areas of potential effect for the projects.

All significant cultural resources will be avoided and preserved in place. No improvements will 

be placed within the boundaries of known or newly discovered sites.

The Forest Service zone archeologist concludes in the Archeology Report that the 

implementation of new management plans for the allotments in the North Billings area will have 

no adverse effect on cultural resources. The State Historical Society of North Dakota, after 

review of the Archeology Report, stated that “We concur with a 'No Adverse Effect'

determination, and we concur with the proposed management recommendations as outlined in 

the conclusion”(SHPO 2006). Therefore, this issue was dropped from further consideration in 

this analysis.

Noxious Weeds 

Noxious weeds are a scourge to the prairie ecosystem. They displace and crowd out native 

plants, modify wildlife habitat, reduce livestock forage, adversely impact watersheds and riparian 

areas, and are costly to control. Over the years in the Dakotas, federal agencies, state and local 

governments, county weed boards, and local grazing associations have expended millions of 

dollars and countless hours to eradicate or control noxious weed populations.

Forest Service Manual (FSM) 2080.5 defines noxious weeds as: “... plants designated as noxious 

weeds by the Secretary of Agriculture or by the responsible State official. Noxious weeds 

generally possess one or more of the following characteristics: aggressive and difficult to 

manage, poisonous, toxic, parasitic, a carrier or host of serious insects or disease, and being 

native or new to or not common to the United States or parts thereof.” 
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Noxious weeds are listed by the State of North Dakota and individual counties. There are 

currently 23 noxious weeds species associated with the state and county noxious weed lists. Of 

this number, 17 are known to occur on the DPG. Within the project area, 6 species—leafy 

spurge, Canada thistle, burdock, black henbane, field bindweed (in 2010 this plant was dropped 

from the North Dakota noxious weed list), and absinth wormwood—have been identified. The 

amount of known infestations in the individual allotments ranges from zero to approximately 263 

acres. The most prevalent noxious weeds in the project area are leafy spurge, Canada thistle, and 

burdock. Total estimated acreage in the project area is approximately 790 acres. 

Noxious weeds are of concern; however, they were not carried forward in this analysis as a key 

issue because they have been previously analyzed in the 2007 Noxious Weed Management 

Project Final Environmental Impact Statement (FEIS) and its accompanying Record of Decision 

(ROD) which are located in the Supporting Documentation–Range section of the Project Record. 

The ROD approves the use of the integrated adaptive approach to continue to treat existing and 

future infestations of noxious weeds. None of the proposed actions associated with this project 

would alter any of the provisions of the Noxious Weed FEIS. Therefore, this issue was dropped 

from further consideration in this analysis.

Threatened and Endangered Plant Species

The Forest Service botanist has concluded that there are no federally listed threatened or 

endangered (T&E) plant species, and there is no designated critical habitat for T&E plant 

species, on the Little Missouri National Grassland (Project Record, Specialist Reports and Notes, 

Botany Report). There is no plant species proposed for federal listing and there is no proposed 

critical habitat associated with the proposed project. Therefore, this issue was dropped from 

further consideration in this analysis. 

Sensitive Plant Species

There are six known populations of three sensitive plant species in the project area—Hooker’s 

townsendia (Townsendia hookeri), blue-eyed Mary (Collinsia parviflora), and Dakota 

buckwheat (Eriogonum visheri). 

Hooker’s townsendia typically occurs in sparsely vegetated habitat associated with exposed 

parent material, poorly developed soil, or recent sedimentation; however, two of the three 

population sites in the project area occurred in more heavily vegetated settings than is typical of 

most population sites. Livestock may incidentally graze or trail through Hooker’s townsendia 

population sites, but the very low stature and minimal leaf production of the plant confer an 

escape from livestock herbivory. Additionally, the primary growth and flowering period occurs 

during early spring, prior to typical livestock turn-in dates. Although some mechanical damage 

may occur from livestock trailing through a population site, a certain level of trailing and grazing 

disturbances may provide benefits of decreased competition with other plant species, 

maintenance of low structure, and creation of favorable microsites for seed germination.
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Two population sites of blue-eyed Mary (Collinsia parviflora) are documented in the project 

area and have remained persistent since their discovery in the early 1990s. Primary habitat for 

this early-season and short-lived annual species involves the understory of various tree and shrub 

communities that include woody draws and stands of Rocky Mountain juniper. The growth cycle 

of blue-eyed Mary is generally nearing completion by late May or early June when livestock 

grazing generally commences. Concurrent years of observation within the two known population 

sites suggest that livestock grazing and trailing are not having an adverse effect on the 

populations.

A new population of Dakota buckwheat (Eriogonum visheri) was discovered along a ridge 

saddle in the Blacktail Creek watershed during project fieldwork. This population is significant 

in that it is about 20 miles distant from other known populations and therefore contributes to the 

spatial distribution of the species across the LMNG. The discovered population is the only 

known site for Dakota buckwheat in the project area.

To an even greater extent than Hooker’s townsendia, Dakota buckwheat typically occurs in poor 

soil conditions that most plant species cannot tolerate. Thus, competition from other species is 

usually low or non-existent, and the population sites exhibit minimal forage value. The 

discovered population site is atypical in that it occurs on a broad ridge saddle with moderate 

amounts of inland saltgrass (Distichlis spicata). Abundant hoof prints attest to livestock trailing 

through the site, but the tallest and most vigorous Dakota buckwheat plants occurred within the 

hoof prints that collect and increase available moisture. Annual growth and flowering of Dakota 

buckwheat occurs in mid to late summer, and although some incidental grazing of plants may 

occur, minimal leaf or forage production confers a low potential for any significant degree of 

selective grazing.

The six sensitive plant populations in the project area were not affected by livestock grazing and 

in one case benefited as the largest plants were found in cattle hoof prints. The Forest Service

botanist (Project Record, Specialist Reports and Notes, Botany Report) has determined the 

proposed project would not affect the viability of existing sensitive plant populations. For these 

reasons, sensitive plants were dropped from further consideration in this analysis. 

Recreation

Dispersed recreation opportunities exist throughout the project area. Developed recreation 

opportunities; such as Magpie and Elkhorn campgrounds and the Whitetail picnic area, are 

located in or adjacent to the project area. A portion of the nationally recognized non-motorized 

Maah Daah Hey Trail passes through part of the project area. The area also contains the Ice 

Caves Special Interest Area, a favorite dispersed recreation site, and other areas of recreation 

interest including the Two Top/ BigTop and Mikes Creek Research Natural Areas, and the 

Magpie and Blacktail Inventoried Roadless Areas. 

Regardless of the amount of grazing activities in any of the action alternatives, effects on the 

recreation resource are about the same.
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Two of the developed facilities, Elkhorn and Magpie campgrounds, have been fenced to keep 

livestock out of the facilities. Whitetail picnic area is unfenced and subject to potential impacts 

including damage to structures such as tables, bulletin boards, livestock rubbing, etc. However, 

current allotment boundary fences surrounding the picnic area mitigate potential livestock 

effects. No adverse impacts to developed recreation sites located in the project area are expected 

under any alternative.

Dispersed recreation includes the Maah Daah Hey Trail, outfitters, individual hunting, and bird 

watching to mention a few. All the allotments contain a variety of dispersed recreation activities. 

The Maah Daah Hey Trail would likely have the greatest impacts from continuation of grazing, 

or new range developments, such as new fencing. Livestock utilize the trail as a walking path, 

and walking on the trail during wet conditions roughens up the trail surface creating potential 

safety problems for hikers and mountain bikers. The trampling of the trail surface by livestock 

could affect the drainage along the trail and create increased maintenance concerns and costs for 

the Forest Service. Some users complain about cow manure on trails.

Range permittees have experienced problems from recreating publics who leave gates open. This 

has allowed cattle to enter other pastures or allotments or private properties. They have also 

reported having water tanks turned on and floats tampered with.

The proposed grazing seasons range from seasonlong to year-around and overlap with a variety 

of hunting seasons, including upland bird and big game seasons. Although hunting seasons and 

grazing seasons overlap, no adverse effects on hunting opportunities for either individual hunters 

or outfitters are expected. 

Winter activities in the project area are of a minimal nature and consist primarily of cross 

country snowmobiling when there is enough snow present to allow that activity. There may be 

some incidental cross country skiing use. Most cattle are off the range during the deep winter 

months and would not be affected.

Motorized travel in the project area is limited to existing roads and trails. Off-road motorized 

travel is allowed for permit holders such as grazing permittees and oil and gas companies. Travel 

is restricted to administration of their permits. The use of motorized equipment to administer 

permits can create problems for recreation users. Over time, continued off-road use can leave 

identifying marks on the ground that appear to the general public as acceptable activities. The 

average off-road motorized recreationist tends to follow tracks already defined in the grassland, 

regardless of where they go and who put them there. The development of a Travel Management 

Plan will analyze these issues.

Alternative 1 – No Grazing (No Action) would eliminate grazing. This alternative would 

eliminate all concerns or problems that develop between visiting publics and grazing livestock. 

Alternatives 2, 3, and 3A would maintain current numbers and seasons of use. Effects of grazing 

activities on recreational use would likely remain status quo. Alternative 4 would see a reduction, 

in most cases, of authorized AUMs, which would result in reduced numbers of grazing livestock 

in the project area. Opportunities for conflicts between livestock and other public land users, 

already very low, may decrease further under this alternative. 
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The array of alternatives would maintain or reduce livestock use in the project area, so no 

cumulative effects on recreation are expected. Therefore, this issue was dropped from further

consideration in this analysis. 

Threatened and Endangered Wildlife Species

The Forest Service wildlife biologist has concluded that there are no federally listed TE wildlife 

species on the LMNG (Project Record, Specialist Reports and Notes, Wildlife Report). There is 

no designated critical wildlife habitat and there are no wildlife species proposed for federal 

listing; further, there is no proposed critical habitat associated with the proposed project. 

Therefore, this issue was dropped from further consideration in this analysis. 

Sensitive Species, Management Indicator Species (MIS), Raptors

A detailed description and analysis of sensitive species, management indicator species (MIS),

and raptors is contained in the BA, which is located in Appendix D of the Wildlife Report

(Project Record, Specialist Reports and Notes). Table 1.4 summarizes information for each 

species. 

Table 1.4 – Summary of sensitive species, management indicator species (MIS), and raptor 

information in project area

Species

Designation

Habitat on or Near

LMNG

Occurrence 

within 

Project 

Area

Potential for 

Project Area 

Impacts on 

Habitat or 

Population

Effects Call

Bald eagle 

(Haliaeetus 

leucocephalus)

S

1

Large trees for perching and 

roosting, areas with carrion, 

small mammals or fish. Use at 

this time is restricted to spring 

and fall migration.

UQ2 None

All Alts:

No Impact

American 

peregrine falcon 

(Falco peregrinus)

S

Peregrine falcons will use 

almost any habitat type that 

provides hunting opportunities. 

Potential use is strictly 

migratory.

(This species was removed 

from the FS Region 1 Sensitive 

Species List in May of 2011.)

UQ None All Alts:

No Impact

Baird’s sparrow 

(Ammodramus 

bairdii)

S

Idle native or tame grasslands 

or lightly to moderately grazed 

pastures.

K

3 High

Alts 1, 2: 

May impact*

Alts 3, 3A, 4: 

Beneficial 
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Species

Designation

Habitat on or Near

LMNG

Occurrence 

within 

Project 

Area

Potential for 

Project Area 

Impacts on 

Habitat or 

Population

Effects Call

Burrowing owl 

(Athene 

cunicularia)

S

Well drained, gentle grassland 

with sparse vegetation; usually 

rely on burrowing mammals for 

nest sites; One small prairie dog 

colony (<1 acre in size) in 

project area.

UQ None All Alts:

No Impact

Loggerhead shrike 

(Lanius 

ludovicianus)

S

Open habitat with low stature 

grasses and forbs and shrubs or 

low trees.

Likely Moderate

Alts 1, 2: May 

impact*

Alts 3, 3A, 4: 

Beneficial 

Long-billed 

curlew

(Numenius 

americanus)

S

Expansive, open, gentle 

grassland with short vegetation. PSH4 Low All Alts: May impact*

Sprague’s pipit 

(Anthus spragueii)

S

Grasslands of intermediate 

height and sparse to 

intermediate vegetation.

K High

Alts 1, 2: May 

impact*

Alts 3, 3A, 4: 

Beneficial 

Rocky Mountain 

bighorn sheep

(Ovis canadensis 

canadensis)

S

Badlands and other steep 

grassland for escape cover, with 

shrubs, grasses, sedges and 

forbs for food.

K Low All Alts: May 

impact*

Dakota skipper 

(Hesperia dacotae)

S

Undisturbed tallgrass to mixed 

grass prairies; East: low (wet) 

bluestem prairie; West: upland 

(dry) prairie dominated by 

bluestems and needlegrasses.

UQ None All Alts:

No Impact

Ottoe skipper 

(Hesperia ottoe)

S

Undisturbed mid-grass to tall 

grass prairie, drier sites/hilltops. PSH Moderate

Alts 1, 2: May 

impact*

Alts 3, 3A, 4: 

Beneficial 

Regal fritillary 

(Speyeria idalia)

S

Tallgrass to mixed grass 

bluestem prairies. UQ None All Alts:No Impact

Tawny crescent 

(Phyciodes 

batessi)

S

North-facing or other mesic 

sites – green ash forest margins 

that border bluestem prairie.

K Moderate

Alts 1, 2: May 

impact*

Alts 3, 3A, 4: 

Beneficial 

Sturgeon chub 

(Hybopsis gilida)

S

Primarily inhabits large turbid 

rivers with rock or gravel 

bottoms; present in the 

Missouri River and historically 

the Little Missouri River.

UQ None All Alts:

No Impact
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Species

Designation

Habitat on or Near

LMNG

Occurrence 

within 

Project 

Area

Potential for 

Project Area 

Impacts on 

Habitat or 

Population

Effects Call

Northern redbelly 

dace

(Phoxinus eos)

S

Slower and clearer waters with 

some vegetation.

Impoundments like beaver 

ponds and pools in headwaters. 

Has been found in the 

Cannonball and the Little 

Missouri River on the LMNG.

UQ None All Alts:

No Impact

Golden eagle

(Aquila 

chrysaetos) R

5 Nests: Trees, Cliffs; Prey: 

opportunistic K Low No Measurable Impacts

Prairie falcon

(Falco mexicanus) R Cliffs K Low No Measurable 

Impacts

Merlin

(Falco 

columbarius) R Forested draws PSH Low No Measurable Impacts

Ferruginous hawk

(Buteo regalis)

R Nests: Isolated buttes, trees, etc UQ None All Alts:

No Impact

Greater sage 

grouse 

(Centrocercus 

urophasianus)

S &

MIS6 Sagebrush shrubland. UQ None All Alts:No Impact

Black-tailed 

prairie dog

(Cynomys 

ludovicianus)

S &

MIS

Gentle grassland terrain; short 

grass communities; not forested 

or wet. One small prairie dog 

colony (<1 acre in size) in 

project area.

K Low All Alts: May 

impact habitat

1

S=Sensitive 2UQ=Unlikely or Questionable 3K=Known 4PSH=Potential Suitable Habitat

5R=Raptor 6MIS=Management Indicator Species

*May Impact =May impact individuals but will not lead to federal listing or a loss of viability in the LMNG. 

SENSITIVE SPECIES

Effects on the sensitive species listed in Table 1.4 indicate that the alternatives will have no 

impact, will be beneficial, or may affect individuals of a population. Reasons vary for the 

determinations including but not limited to the following. Several of the species such as the

greater sage grouse, burrowing owl, and Dakota skipper are not known to occur in the project 

area. For two species, bald eagle and peregrine falcon, the project area may be used only during 

spring or fall migration periods. Alternatives 3, 3A, and 4 move the project area toward the 

Grasslands Plan objectives thus would benefit some species, e.g. Baird’s sparrow and Sprague’s 

pipit. Alternatives 1 and 2, which are not projected to move conditions towards Grasslands Plan 
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36 | C h a p t e r 1

objectives, would result in a “may impact” determination but will not lead to federal listing or 

lost viability for these same species. However, none of the alternatives would threaten the 

viability of any sensitive species in the project area. See the Wildlife Report (Project Record, 

Specialist Reports and Notes) for further discussion. For the above reasons, the sensitive species 

identified were dropped from further consideration in this analysis.

MANAGEMENT INDICATOR SPECIES (MIS)

There are three MIS species for the LMNG: greater sage grouse, black-tailed prairie dogs (prairie 

dogs), and sharp-tailed grouse. Sharp-tailed grouse will be addressed in Chapter 3. The closest 

known greater sage grouse occur approximately 35 to 40 air miles southwest of the project area. 

There are approximately 2,600 acres of big sagebrush habitat located in the project area. 

However, it is scattered across approximately 52,400 acres of Badlands and does not occur in 

large enough blocks to support a sage grouse population. Additionally, there are no greater sage 

grouse leks or sightings in the project area. There is one small prairie dog colony, less than 1 acre 

in size, in the project area; however, none of the alternatives would have an effect on this town. 

For the above reasons, greater sage grouse and prairie dogs were dropped from further 

consideration in this analysis.

RAPTORS

The golden eagle and the prairie falcon are both known to occur in the project area. In general, 

nest site availability and non-forested habitat are critical components for these two species. 

These species are adapted to the presence of herbivore activity, which has no effect on nesting 

sites. None of the alternatives propose any activity that would affect nesting sites for these 

species. The array of alternatives, to varying degrees, may affect the prey base for these species;

however, it is not possible to determine if this would have any significant effect on them. 

The merlin is not known to occur in the project area; however, the project does support potential 

foraging and nesting habitat for the species. As with the species above, herbivores have no effect 

on potential nesting sites. The array of alternatives may affect the availability of prey species;

however, it is not possible to determine the magnitude of those effects at this time. 

The Forest Service wildlife biologist concluded that the project area provides marginal habitat, at 

best, for ferruginous hawks. This is due to their need for large expanses of open rolling prairie 

and high densities of prey such as prairie dogs, which are scarce in the project area (Project 

Record, Specialist Reports and Notes, Wildlife Report). 

For the above reasons, this issue was dropped from further consideration in this analysis. 

SOILS

Soils and soil condition are of primary importance because they are the foundation upon which a 

healthy ecosystem is built. Soil condition is determined through an evaluation of soil quality 

based on an interpretation of factors that affect three primary soil functions. The primary soil 

functions evaluated are: soil hydrology, soil stability, and nutrient cycling (USDA 1999). Soil 
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condition objectives apply to lands where long-term soil productivity and satisfactory watershed 

condition are principle objectives, such as on the LMNG.

Direction from the Forest Service Northern Region (Region 1) is to manage NFS lands under 

ecosystem management principles without permanent impairment of land productivity and to 

maintain or improve soil quality (USDA 1999). Soil quality standards are met when detrimental 

soil disturbance (DSD) from management activities occur on no more than 15 percent of an 

activity area or allotment. Detrimental soil disturbance is defined as activities that result in 

compaction, displacement, rutting, severe burning, surface erosion, loss of surface organic 

matter, and soil mass movement.

Livestock management activities associated with DSD includes watering locations, mineral sites, 

corrals, livestock trails, and use of two-track trails. These activities result in various levels of soil 

compaction, rutting, displacement, and surface erosion. 

A soil compaction study was completed on the Little Missouri National Grassland by Gonzalez 

et al. (2005). The results indicated there was no long-term soil compaction on upland soils as a 

result of livestock activities except at the specific site types noted in the above paragraph.

Table 1.5 lists a summary of total DSD area, acreage, and percentage within the project area. The 

total project area DSD is 0.45 percent, which is negligible and well below the 15 percent regional 

direction.

Table 1.5 – Summary of total DSD area, total acres of DSD, and total percentage of DSD

Allotment # Alt. 1 Alt. 2 Alt. 3 Alt. 3A Alt. 4

Total acres of NFS lands in 

project area 87,265 87,265 87,265 87,265 87,265

Total DSD acres 30 392 376 395 386

DSD percent 0.0003 0.45 0.43 0.45 0.44

Alternative 1 would see the removal of stock tanks, mineral sites, corrals, etc. Over time, these 

sites as well as cattle trails would heal. Assuming the two-track trails continue to be used for 

other purposes, existing DSD acres would be reduced to 30 acres and the total DSD reduced 

from 0.45 to 0.0003 percent. Alternative 2 would maintain the status quo, and the total DSD (392 

acres) would be expected to remain at about 0.45 percent.

Alternative 3 proposes to construct 22 livestock water tanks, 9 rangeland water wells, and 1 

waterlot that would result in new DSD. The alternative also proposes to reclaim 12 dugouts, 

reservoirs, or springs, which would result in a reduction in DSD after successful reclamation is 

complete. The net change in DSD as result of this alternative is a reduction of 15.8 acres and 

0.02 percent DSD, equating to a total DSD of 0.43 percent.
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In comparison to Alternative 3, Alternative 3A proposes to construct five additional livestock 

water tanks and one additional waterlot which would result in new DSD. The net change in DSD 

as result of this alternative is an addition of 3 acres and 0.003 percent DSD, equating to a total 

DSD of 0.453 percent.

Alternative 4 proposes to construct 13 livestock water tanks, 6 rangeland water wells, and 1 

waterlot that would result in new DSD. The alternative also proposes to reclaim 6 dugouts, 

reservoirs, or springs, which would result in a reduction in DSD after successful reclamation is 

complete. The net change in DSD as result of this alternative is a reduction of 6.2 acres and 0.01

percent DSD, equating to a total DSD of 0.44 percent.

The total DSD in the project area is 0.45 percent, which is well below the regional standard of 15 

percent. All of the alternatives, except Alternative 2, would lower the DSD. Because this project 

would maintain (Alt. 2) or reduce (Alts. 1, 3, 3A, and 4) the already low percentage of soil 

compaction or disturbance, and because it is well below the 15 percent DSD regional soil 

standard, no additional analysis is needed.

Soil Capability

The Forest Service, in cooperation with North Dakota State University (NDSU) and the MGA,

has formed a cooperative effort to collect monitoring data on the LMNG. NDSU started the data 

collection on the Medora Ranger District in 2008 in North Billings County. By the end of 2009 

they had collected information on 34 of the 43 allotments in the project area. A more detailed 

description of this cooperative effort is located in Chapter 3. 

The 17 Indicators of Rangeland Health (Pellantet al. 2006) assessment was conducted on 30 of 

the allotments. This produced 115 samples, of which 98 were used and 17 were discarded 

because the surveys had not been fully completed. The 17 Indicators of Rangeland Health is a 

rapid assessment method that looks at 17 different indicators to gauge the health of the range. 

The assessment compares the observed indicator to a reference or desired condition for that 

indicator to determine the level of departure if any. Each indicator then receives a rating from 1 

to 5:

1 indicates an extreme departure from the reference condition, 

2 is an extreme to moderate departure, 

3 is a moderate departure, 

4 is a moderate to slight departure, and 

5 indicates a slight to no departure from reference conditions. 

Of the indicators, 9 apply to soil stability and 11 apply to hydrologic function of the soils; 8 of 

these indicators overlap. These indicators provide an indication of soil health and functionality. 

Table 1.6 shows the percentage of sampled ecological sites and their ratings within each 

allotment. As the table shows, almost all of the ecological sites in the project area are in 

categories 4 and 5. This means that the soils are functioning properly in regards to nutrient 

cycling and hydrologic function and they are not eroding off the landscape, i.e., they’re stable. In 
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other words, the soils are capable of maintaining the diverse native plant communities associated 

with the different soil types. 

Table 1.6 – Soils stability and hydrologic function of soils, summary for 2008 and 2009 field 

seasons; percentage of sampled ecological sites by category by allotment

Allotment 

#

1 2 3 4 5

%1 Extreme % Extreme 

to Moderate % Moderate % Moderate to Slight

% None to 

Slight

SS2 HF

3

SS HF SS HF SS HF SS HF

126 0 0 0 0 0 5 5 10 95 85

128 0 0 0 0 0 0 10 17 90 83

129 0 0 0 0 4 8 10 12 86 80

131 0 0 0 0 7.5 15 10 10 82.5 75

132 0 0 0 0 0 0 0 7 100 93

135 0 0 0 0 0 0 30 40 70 60

136 0 0 0 0 0 0 0 0 100 100

140 0 0 0 5 0 10 0 0 100 85

158 0 0 0 0 0 0 10 10 90 90

220 0 0 0 0 0 0 0 10 100 90

230 0 0 0 0 0 0 0 0 100 100

239 0 0 0 0 0 0 3 17 97 83

240 0 0 0 0 0 8 20 28 80 64

241 0 0 0 0 0 5 5 15 95 80

243 0 0 0 0 0 10 10 10 90 80

244 0 0 0 0 0 10 0 0 100 90

248 0 0 0 0 0 10 7 7 93 83

256 0 0 0 0 0 0 30 40 70 60

258 0 0 0 0 0 5 5 10 95 85

272 0 0 0 0 0 10 0 0 100 90

277 0 0 2.5 5 10 12.5 15 20 72.5 62.5

278 0 0 0 0 0 10 0 10 100 80

279 0 0 0 0 0 0 20 10 80 90

280 0 0 0 0 0 0 17 23 83 77

282 0 0 0 0.5 2 3.5 17 21 81 75

288 0 0 0 0 0 10 0 0 100 90

289 0 0 0 0 0 1 20 20 80 79
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Allotment 

#

1 2 3 4 5

%1 Extreme % Extreme 

to Moderate % Moderate % Moderate to Slight

% None to 

Slight

SS2 HF

3

SS HF SS HF SS HF SS HF

300 0 0 0 0 0 0 0 10 100 90

301 0 0 0 0 4 5 17.5 19 78.5 76

302 0 0 6 10 26 28 8 10 60 52

1 This is the percentage of sampled ecological sites within each allotment, in each category.

2

SS=Soil Stability.

3 HF=Hydrologic Function

Soil Productivity

Annual forage production, Indicator #15 of the 17 Indicators of Rangeland Health, can serve as a 

surrogate for soil productivity. Of the 115 sites surveyed 90.5 percent were at or near reference 

condition for forage production. Approximately 9.5 percent (11 sample sites) had a moderate or 

greater departure from reference conditions. Closer review of the 11 sites found that four were 

located on the wrong ecological site, two had incomplete data, and three didn’t follow the 

protocol correctly, which resulted in incorrect category determinations. The remaining two sites 

had been sampled correctly but an incorrect category determination was made. 

It is important to understand that the 115 samples reviewed for this indicator represent about half 

of the samples that are to be collected by NDSU for the various ecological sites in the project 

area. It will take several more years to complete the sampling. What can be said at this point is 

that based on the existing survey information, there is no indication the productivity of the soils 

in the project area has been compromised. 

Because the soils in the project area are stable, functioning properly in regards to nutrient cycling 

and hydrologic function, and their productivity is intact this issue is dropped from further 

consideration in this analysis. Additional information is available in the Supporting 

Documentation–Watershed section of the Project Record.

CLIMATE CHANGE

Livestock affect climate change through the production of methane gas (CH4), which is produced 

as part of normal digestive processes in ruminant animals. During digestion, microbes present in 

an animal’s digestive system ferment food consumed by the animal. This microbial fermentation 

process, referred to as enteric fermentation, produces CH4 as a by-product, which can be exhaled 

or eructated by the animal. Methane is a potent greenhouse gas that is 21 times more effective at 

trapping heat in the atmosphere than carbon dioxide on a kilogram per kilogram basis (Wood et 

al. 1998). 

Livestock can also play a beneficial role in relation to climate change. The LMNG evolved under 

the herbivory of ungulates such as bison, deer, elk, and antelope. As such, the native plant 
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communities associated with the LMNG are adapted to herbivory. Livestock have, for the most 

part, replaced the large herds of wild ungulates on the grasslands, and they have a role in 

maintaining healthy grasslands. Information from the EPA website 

(http://www.epa.gov/methane/rlep/index.html) states that properly managed grazing “can reduce 

atmospheric concentrations of carbon dioxide through the mechanism of soil carbon 

sequestration on grazing lands.”

The agricultural sector in 2006 was responsible for 6 percent of the total U.S. greenhouse gas 

emissions (EPA, 2008). Beef cattle are responsible for the production of 20 percent of the 6 

percent of greenhouse gases generated from agriculture sources. Stated another way, beef cattle 

produce approximately 1.2 percent of U.S. greenhouse gases. On a percentage basis, the 

estimated 5,200 head of cattle that currently graze within the project area would account for 

0.0000006 percent of the methane produced by beef cattle produced in the United States. 

Alternative 1, which removes livestock from NFS lands in the project area, may or may not lead 

to a reduction in methane production. The permittees might maintain their existing herd numbers 

on their own or rented properties. They might reduce a certain portion of their herds or get out of 

livestock production entirely. It is impossible to predict what each permittee would do. In general 

terms it is possible to say that, under this alternative, methane production produced by cattle in 

this project area could range from zero to what is currently produced. 

A possible indirect effect of removing livestock from lands in the project area relates to potential 

effects on the plant communities and their abilities to serve as carbon sinks. It is generally,

though not universally, accepted that in grassland ecosystems grazing is needed to maintain the 

health of associated plant communities. The cessation of grazing in the project area may result in 

increases in plant community health in the short term, but eventually these communities would 

likely decline due to litter build up and the presence of invasive grasses. As the vigor of any 

herbaceous plant community decreases, so does its ability to effectively sequester carbon. 

Alternative 2 would maintain current Authorized Use, and Alternatives 3 and 3A would initially 

as well. Therefore, the amount of methane would stay more or less the same as what is currently 

produced. The ability of the NFS lands in the project area to sequester carbon would likely 

remain the same as current conditions.

Alternative 4 would reduce Authorized Use, which may result in decreased methane production. 

However, as explained under Alternative 1, it would depend on what the permittee decides to do 

with the cattle removed from the NFS lands in the project area. Reduced Authorized Use under 

this alternative is projected to improve the mosaic of herbaceous structure and seral stages, 

which should also improve carbon sequestration but to what degree is unknown. 

The livestock that graze in the project area produce a minute amount of the total methane 

produced by the beef cattle industry of the United States. Maintaining the current numbers of 

cattle in the project area would continue to affect climate as it currently does; however, it is 

difficult to identify what the effect would be in terms of global climate change. Reducing the 

number of cattle may or may not result in less methane production for reasons previously stated. 

Even if all the livestock were removed and not replaced, it would be difficult at best to determine 
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42 | C h a p t e r 1

what the effect of such a minute reduction in methane would have on climate change. For these 

reasons this issue was dropped from further consideration in this analysis.

A more detailed discussion of climate change can be found in the Climate Change report located 

in the Specialist Reports and Notes section of the Project Record. 

WATER QUALITY

The following information has been added to the SDEIS in response to comments presented by 

the EPA.

The North Dakota State Department of Health (NDDoH) has jurisdiction over the quality of 

waters of the state. The ND Century Code 33-16 authorizes the state to establish a system for 

classifying waters of the state; provide standards of water quality for waters of the state; and 

protect existing and potential beneficial uses of waters of the state (NDDoH 2001).

The Little Missouri River (LMR), which generally flows northward, is the only perennial stream 

in the project area. A perennial stream flows continuously throughout most years. It is classified 

as a Class II stream, which means that the waters of the stream are suitable for fish, aquatic biota, 

recreation, agricultural uses, and with treatment for municipal or domestic use (NDDoH 2001). 

Approximately 27 miles of the river are located within the project area. Roughly 6 of the 27 

miles of the river actually abut NFS lands within the project area, equating to about 1 percent of

the total length of the LMR. The remaining 21 miles of the river bank in the project area are 

either privately owned or owned by the state. The other streams within the project area are 

intermittent and are classified as Class III streams for water quality standards. The waters of 

Class III streams are suitable for agricultural and industrial uses but must be maintained to 

protect secondary contact recreation use (e.g., wading), fish, aquatic biota, and wildlife (NDDoH 

2001). 

The reach of the LMR flowing through the project area has not been assessed for water quality 

by the state. Two reaches of the LMR above and two below the project area have been rated for 

water quality by the state. Three of these reaches are rated as “Fully Supporting but Threatened” 

for recreation and one as “Not Supporting” based on levels of fecal coliform contamination 

(NDDoH 2008). The probable sources, as identified by the state, are livestock grazing or feeding 

operations and onsite sewage treatment systems. Contributions of fecal coliform are thought to 

originate on private, state, and federal lands bordering the river. The intermittent streams in the 

project area may contribute some quantity of fecal coliform to the LMR through sources 

previously mentioned and wildlife. Livestock managed on private and state lands within the 

project area are also potential contributors of fecal coliform to the LMR and intermittent streams 

in the project area. There are no water bodies within the project area listed on the Clean Water 

Act Section 303(d) list for water quality impairment.

All of the alternatives except Alternative 2 would improve riparian vegetation conditions and 

contaminant filtering capability. Recent studies (Shirmohammadi and Montas 2003, Pachepsky 

et al. 2006, Sullivan et al. 2007) indicate that vegetation filter strips are highly effective in 
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removing nutrients and fecal coliform from overland flow and preventing these contaminants 

from entering the stream flow. Therefore, actions that increase riparian vegetation will directly 

decrease sediment transport as well as transport of sediment laden contaminants such as fecal

coliform.

Currently there is no readily available information establishing the water quality for the LMR or 

intermittent streams in the project area. To better address this in the future this project proposes 

to establish water quality monitoring for the LMR, within the project area, and at the confluences 

of the LRM and two major intermittent streams, which drain much of the project area. The 

Monitoring section in Chapter 2 of this document provides more detailed information regarding 

the proposed monitoring. 

Water quality was not carried through detailed analysis because there is no known impairment to 

water quality of the LMR as a result of proposed actions within the project area. A more detailed 

discussion of water quality can be found in the Water Quality Report (Project Record, Specialist 

Reports and Notes).
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CHAPTER 2

Alternatives, Including the Proposed Action

INTRODUCTION

This chapter describes the five alternatives considered in this analysis. It explains how the 

alternatives were developed and identifies alternatives considered in detail, alternatives dropped 

from further analysis, and design criteria associated with all the action alternatives (Alternatives

3, 3A, and 4). The chapter ends with a summary of the effects of implementing each alternative

in relation to the purpose and need and the key issues.

ALTERNATIVES CONSIDERED IN DETAIL

For this project, the IDT considered the following elements in the development of the action 

alternatives: key issues; the purpose of and need for this project as identified in Chapter 1; the 

goals, objectives, and desired conditions for the project area as described in the Grasslands Plan; 

comments made by the public, the state, and various agencies during the scoping process; the 

laws, regulations, and policies that govern land management on National Grasslands; and sitespecific resource information.

Four alternatives were developed and analyzed in the DEIS. After review of DEIS comments the 

responsible official decided to create and include an additional alternative in the SDEIS. The 

alternative descriptions, presented below, explain the activities that would occur if an alternative 

were selected. A detailed description of the environmental effects resulting from the alternatives 

is given in Chapter 3.

It is important to note that Authorized Use under all the alternatives, except Alternative 1, can be 

adjusted annually to account for situations that require additional resource protection. Examples 

include drought, grasshopper outbreaks, over-utilization of a pasture, etc. These adjustments are 

temporary in nature and normally encompass a single grazing season. However, if a resource 

has been severely affected, adjustments may be of longer duration.

Alternative 1

The CEQ regulations for implementing NEPA require that a no-action alternative be developed 

as a benchmark from which the agency can evaluate the proposed action. No action in livestock 

management planning is defined as “...livestock grazing would not be authorized within the 

project area” (Forest Service Handbook [FSH] 2209.13, 92.31, Grasslands Plan ROD, 2006).

Upon implementation of the decision and resolution of any appeals, the term grazing permit with 

the MGA would be modified to terminate livestock grazing in the analysis area. Pursuant to FSH

2209.13, Section 16.24, this alternative could not be implemented until 2 years after the 

notification of each affected permittee (36 CFR§ 222.4(4)(1)). No permits would be issued for 
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any of the 43 affected allotments. Since livestock grazing would no longer be authorized under 

this alternative, no mitigation measures for riparian habitat, green ash woody draws (woody 

draws), herbaceous structure, or seral stages would be completed. However, restoration projects 

could be planned and implemented, which would require a subsequent plan and NEPA decision.

Most range improvements currently in existence on the allotments would be abandoned.

Subsequent decisions would need to be made regarding retention of any improvements, such as 

water developments, for other resource needs and funding for maintenance would need to be 

secured. Any water developments not needed for wildlife or other purposes, and all fences, 

except Grassland boundary fences or allotment boundary fences adjacent to other active grazing 

allotments, would be removed. 

Under this alternative control of noxious weeds would become the sole responsibility of the 

Forest Service because the Medora Grazing Association (MGA) would no longer be authorized 

to graze livestock in the project area.

Alternative 2

This alternative would maintain the status quo. Authorized Use would remain at Preference;

therefore, there would be no change in the number of livestock or season of use in the allotments 

in the project area. Some minor changes may be made in the Annual Operating Instructions 

(AOI) if needed. Existing conditions for each allotment are identified in Chapter 3 Part 2.

Alternative 3

As identified in Chapter 1, the proposed action for 

this project is to continue to permit livestock 

grazing at Preference, initially, on the 43 allotments 

in the project area through a program of actions 

that maintains and/or moves resource conditions 

towards meeting the Grasslands Plan objectives and desired on-the-ground conditions. This is to 

be achieved through implementation of initial actions and application of adaptive options, 

including the tool box if initial actions fail or can’t be implemented.

The second and third tables contained in each of the individual allotment write-ups, located in 

Chapter 3 Part 2, contain information identifying existing and desired conditions, need for action, 

initial management actions, and a set of adaptive options to address identified resource concerns 

for each allotment in the project. Taken together, the initial actions and adaptive options create 

the proposed program of actions for each individual allotment.

A key component of this alternative is monitoring, as it determines if implemented management 

actions are accomplishing their intended resource goals. The starting point for each allotment is 

identified as “Initial Actions” in Table 3 of the allotment write-ups located in Chapter 3 Part 2. If 

monitoring indicates that the initial actions are not meeting or moving a resource towards desired 

condition, then adaptive options can be applied. Monitoring is discussed in detail later in this 

Preference is the maximum number of 

livestock for a given amount of time 

allocated to an allotment.
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chapter. The type, frequency, and duration of monitoring on each allotment is identified in Table 

3 of each of the allotment write-ups in Chapter 3 Part 2.

Information contained in Chapter 3 Part 2 will be used in the development of new Allotment 

Management Plans (AMPs) for the 43 allotments in the project area. The individual AMPs will 

be the documents that implement the selected alternative which will be identified in the Final 

ROD for this proposal.

If monitoring indicates that Grasslands Plan objectives are not being met or progress towards 

those objectives is not occurring through the implementation of initial or adaptive management

options identified in the allotment write-ups located in Chapter 3 Part 2, then a team, composed

of Forest Service specialists in consultation with the affected permittee and MGA Director, 

would make a recommendation to the district ranger. The recommended course of action would 

be based on the adaptive options identified for each allotment in Chapter 3 Part 2 and/or the

Grazing Management Toolbox (Table 2.1). For example, Allotment A contains an initial action

to develop a range water well, pipeline, and a stock tank or two. The purpose is to pull cattle 

away from a riparian area that needs improvement. However, after implementation of these 

actions, monitoring shows that an upward trend in PFC is not occurring. At this point the 

additional management tools identified in the adaptive options or the Grazing Management 

Toolbox would be available to help solve the concern. 

The toolbox is a collection of different management tools that could be used singularly or in 

combination to address resource issues if proposed initial management actions and adaptive 

options are not successfully addressing a resource concern(s). The toolbox is a compilation of all 

the different management tools identified in the 43 different allotment summary sheets. The 

different tools are not listed in any order of preference or priority for implementation. 

It is possible that new rangeland management techniques may be developed during the life of 

this project. New techniques would be incorporated into the toolbox if their implementation is 

consistent with the effects documented in the FEIS and its accompanying Final ROD.

Between the DEIS and SDEIS, initial actions for Alternative 3 were modified for allotments 126, 

128, 132H, and 300 based on discussion with the permittee for those allotments.

Table 2.1 — Grazing Management Toolbox

Adjust AUMs (stocking rate) by # of head &/or # of days.

Adjust AUMs based on average cow size.

Adjust season of use.

Allow early turnout on native pastures one out of three years on inventory permits.

Construct and/or remove cross fences.

Construct fence to create riparian unit — allow grazing under riparian grazing dates.

Construct fence to exclude livestock from areas of concern (riparian, wooded draws, springs, wetlands, 

etc.).

Construct livestock water development (well, pipeline, tanks, windmill, reservoir, dugout, or spring).

Construct temporary fence to control livestock distribution patterns.
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Construct water gap to limit livestock access on stream.

Construct/harden stream crossings.

Defer native pastures until June 1, or until development of the three-and-a-half leaf stage for key 

graminoid species.

Fertilize crested wheatgrass areas.

Hay or cut-&-leave crested wheatgrass areas.

Implement BMPs for riparian pastures.

Implement deferred grazing system.

Implement DPG drought management strategy.

Implement prescribed burns.

Implement rest-rotation grazing system.

Implement twice-over grazing system.

Incorporate a range rider to disperse livestock throughout a pasture (herding).

Incorporate private “off permit” land into rotation.

Interseed pasture with native grass species.

Maintain existing developments to reestablish use.

Manage salt and supplement locations.

Manage water availability/access at water developments.

Mechanical brush management.

Move winter feeding areas off of NFS lands.

Reallocation of pastures (change allotment boundary)

Remove/reclaim water development (well, pipeline, tanks, windmill, reservoir, dugout, or spring).

Rest for one or more seasons.

Restore/enhance riparian vegetation, i.e., willow planting.

Scarify clubmoss areas within a pasture.

Utilize biological controls for noxious weed control in woody draws.

Utilize non-native grass pastures early to defer grazing on native grasses.

Alternative 3A 

One of the MGA comments on the DEIS states that the association wanted Alternative 3 revised 

to reflect all of the MGA recommendations. They provided Exhibit 2, which compared

Alternative 3, Appendix A to the notes of each permittee meeting regarding the initial 

recommendations. In Exhibit 2, they specifically highlighted recommendations that they felt the 

ForestService dropped from consideration and also highlighted Forest Service additions to 

Alternative 3, which the MGA claimed the MGA members did not agree to. 

Tables 3 and 4 located in Appendix A discuss each item as highlighted in the MGA Exhibit 2.

Some of the items highlighted by the MGA in their Exhibit 2 did not provide recommendations 

or had already been addressed in Alternative 3. Therefore, Alternative 3A did not incorporate 

these highlighted items in the MGA recommended proposal. 
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In response to the MGA comment, the responsible official decided to include a new alternative in 

the SDEIS. The new alternative is identified as Alternative 3A. Alternative 3A was created by 

including applicable actions identified in the MGA Exhibit 2 that the MGA recommended be 

added to Alternative 3, and excluding some actions identified in Alternative 3 that the MGA did 

not agree with. Tables 2.2 and 2.3 summarize the changes made.

Table 2.2 — Recommendations incorporated into Alternative 3A 

Allotment # MGA Association/Member Recommendations Added to Alternative

127 Construct a water lot around the existing spring development to allow access to 

both pastures 2 and 3 in the northeast quarter of the southwest quarter of Section 

17, T144N, R101W.

129 Extend range water pipeline from well in allotment 131 pasture 3 into allotment 

129 pasture 2 in Section 11, T144N, R101W.

135 Construct a range water pipeline from pasture 8 to pasture 10 and add one stock 

tank in Section 28, T143, R101W.

142 Construct an electric cross fence running east/west in pasture 1.

243 Develop a spring in pasture 1 in the southwest quarter of Section 3, T143N, 

R99W.

258 Allow a permittee to turn livestock onto native pastures the middle to third week 

of May.

272 Develop a spring in pasture 2 in the northwest quarter of the southwest quarter of 

Section 30, T143N, R99W.

287 Construct an extension to the existing range water pipeline in pasture 3 into the 

northwest quarter of Section 26, T143N, R101W.

Table 2.3 — Actions not included in Alternative 3A 

Allotment # Forest Service Actions in Alternative 3 but not included in Alternative 3A 

126 Reclaim existing spring developments in pastures 4 and 6.

240 Reclaim reservoir(s) in pasture 1.

244 Cross fence pasture 2, north to south. Cross fencing would create a crested 

wheatgrass pasture on the east side of pasture 2, which would be grazed early. 

The additional pasture, created through the cross fence, allows the 

implementation of a two-pasture deferred grazing rotation between the remaining 

pastures.

272 Fence woody draw located in the southwest quarter of Section 30 with temporary 

electric fence.

After construction of the pipeline is complete, reclaim the dugout located in the 

southeast quarter of Section 29 pasture 1 and the reservoir located in the 

northwest quarter of the southeast quarter of Section 30 pasture 2.

278 Reclaim reservoir in pasture 2.
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Allotment # Forest Service Actions in Alternative 3 but not included in Alternative 3A 

300 Once well is developed reclaim spring in the southeast quarter of Section 28.

301 Fence out spring areas, install check valve to dump water back into riparian areas 

once stock tanks are full.

Alternative 4 

Alternative 4 is similar to Alternative 3 in some respects. However, it differs from Alternative 3 

by establishing Authorized Use based on estimated livestock carrying capacities and accounts for 

changes in animal unit forage demands with changes in cow size (animal weight). Four of the 

allotments’ Preference was less than initial estimated carrying capacity. Because there are 

resource concerns in these allotments, Authorized Use was set at Preference adjusted for cow 

size as a starting point. In addition, the IDT reviewed the initial and adaptive actions identified in 

Alternative 3. They then estimated the costs of initial action projects under Alternative 3 and 

prioritized those projects in light of the resource objectives the project was designed to address.

Estimated costs were then compared against projected funding over the next three years. This 

resulted in a winnowing of projects and the development of different management approaches 

for some of the allotments.

The third table in each of the allotment specific write-ups contained in Chapter 3 Part 2 identifies

the allotment specific actions for each allotment for this alternative. This alternative is also 

adaptive by design, so if monitoring indicates a need to consider and possibly implement 

different management options, it would be as discussed in Alternative 3. 

PREFERRED ALTERNATIVE

40 CFR Section 1502.14(e) of the CEQ regulations states, “Identify the agency’s preferred 

alternative or alternatives if one or more exist, in the draft [environmental impact] statement....” 

At the time of the DEIS, the responsible official for this project did not have a preferred 

alternative. After review of information provided during the comment period on the DEIS and 

SDEIS, the Grasslands Supervisor has identified a combination of alternatives for the 43 

allotments as the preferred alternative for this project proposal carefully identified in the Draft 

ROD.

DESIGN CRITERIA COMMON TO ACTION ALTERNATIVES 

Design criteria (Table 2.4) are actions designed into the action alternatives (Alternatives 3, 3A, 

and 4) to reduce impacts of proposed activities. They include any requirements that must be 

complied with by law, regulation, or policy, and include things such things as best management 

practices (BMPs), Grasslands Plan standards and guidelines, and standard operating procedures.

Table 2.4 — Design criteria

Place salt and supplement to draw livestock away from woodlands and riparian areas.
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On native pastures, defer turnout until June 1, or until the three-and-a-half leaf stage is reached for key native 

graminoid species, e.g., western wheat, green needle, needle and thread. 

On inventory permits, early turnout on native pastures is allowed one out of 3 years. 

Rotate placement of salt and supplement to minimize effects of concentrating livestock, trailing, etc.

Locate any new water source in uplands away from woodlands and riparian areas.

For allotments requiring a AM/AUM reduction: 

 If monitoring shows that resource objectives are being met before full implementation of the AM/AUM

reduction has occurred, then no further reduction in AUMs will be implemented.

 If, after the reduction in AM/AUMs is complete, monitoring shows that resource objective(s) have not been 

met but a significant sustained upward trend is evident, then further AUM adjustments will not occur unless 

continued monitoring indicates the upward trend is not being sustained.

 If, after the reduction in AM/AUMs is complete, monitoring shows that resource objective(s) are not being 

met and there is a stagnated or downward trend, then, as an adaptive option, further AM/AUM adjustments 

may be initiated.

 Temporary increases in AUMs may be granted if monitoring indicates that resource objectives are being 

exceeded.

If stocking rate adjustments are needed, annual reductions will generally not exceed 10 percent.

Move oilers, creep, and supplement feeders out of woodland and riparian areas.

When drought conditions occur, the DPG drought strategy will be followed. In the absence of the DPG drought 

strategy, the strategy identified in the NE McKenzie Allotment Management Plan Revisions FEIS will be followed,

with some modification.* Permittees will be notified verbally and in writing that reductions in numbers and/or 

seasons may be anticipated.

Ground-disturbing activities—such as installation of water developments, pipelines, fences, or exclosures—will 

require both heritage resource and sensitive species surveys approval by a Forest Service archeologist, botanist, and 

wildlife biologist prior to construction.

All new fencing will be built according to the standards identified in Grasslands Plan Appendix B.

All new or reconstructed water developments will include wildlife access and escape ramps.

Areas disturbed by rangeland improvement will be seeded with native species utilizing certified weed seed free 

mixtures prescribed by the Forest Service botanist. 

Burn plans will be developed and approved for all prescribed fires prior to implementing on-the-ground actions. 

Assess prescribed burn areas to determine appropriate stocking levels. 

Defer prescribed burn areas from livestock grazing for a portion or all of the following growing season to ensure 

regrowth of forage species unless there is specific reason to graze early.

Range improvements will be maintained to standard by the allotment permittee prior to turning livestock into the 

affected pasture. 

Install floats and/or shut-off values to regulate inflow to livestock watering tanks.

*The drought strategy would be incorporated into Alternatives 3, 3A, and 4, and would:

 Use the publication Drought Management on Range and Pastureland (Reece et al. 1991) to determine 

allowable stocking levels during drought, unless interdisciplinary collaboration between the Forest Service

and the Medora Grazing board provided rationale to deviate from those guides. This publication calculates 

stocking guidelines by considering weather and soil moisture. The publication is located in the Literature 

Cited section of the Project Record.

 Manage grazing during drought, with the objective of maintaining at least 10 percent of herbaceous 

communities across biologically capable lands in the project area, for High structure and at least 40 percent 

for Moderate structure. This will help ensure that the project area is not grazed evenly and retains plant 

cover to provide wildlife habitat, conserve soil moisture, and prevent soil erosion.

 Recognize that allowable utilization rates would be lower during drought.
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 Recognize that frequent allotment inspections and early and frequent communications with permittees are 

key to ensuring that this strategy is effective.

ALTERNATIVES CONSIDERED BUT DROPPED FROM DETAILED ANALYSIS

1) When originally scoped, this project had five alternatives. Alternative 5 was an 

alternative similar to Alternative 4 in that it contained the same initial and adaptive 

management actions as Alternative 4. It differed in that it utilized livestock carrying 

capacity to set Authorized Use for each allotment. 

After a closer review of the alternatives it became apparent that the differences between 

Alternatives 4 and 5 were relatively small and that an opportunity existed to combine the 

two alternatives. Combining alternatives created a more robust alternative for public 

review. This action would also reduce the complexity of the document making it easier 

for the public to track. The district ranger decided to accept the IDT’s recommendation to 

consolidate Alternatives 4 and 5; thus, Alternative 5 as a separate alternative was dropped 

from consideration in this analysis.

2) Another alternative considered was a native ecosystem (or “ecosystem management”) 

alternative that would allow the public to see how differently the project and planning 

area would function and appear if it were managed for native species instead of private 

livestock. 

This was an alternative brought forward during the DEIS comment period. An 

“Ecosystem Management” alternative as described would have many legal, cultural, 

economic, and other hurdles involved. A replication of historical conditions would be 

difficult given the existing parameters and the multiple unknowns of historical 

conditions. In addition, taking this alternative to its logical conclusion, reintroducing the 

native carnivorous assemblage (such as the plains grizzly, gray wolf, etc.) on such a small

scale would be difficult or impossible as some of these species are now extinct.

To entertain this alternative, even on a limited scale, would require that all interior fences 

would need to be removed from the project area to allow for free-roaming animals.

However, this is not practical because of the extensive intermingling of private, state, and 

federal lands in the project area. Also, the Forest Service has no authority to remove 

existing private fences in the project area. Currently, grazing permittees have the option

to graze bison under the 2006 Grazing ROD for the DPG (page 9) and the Medora 

Grazing Agreement 2009, (Management of Livestock, Number 8, page 36. MGA Bison 

Policy, revised, June 3, 2005). However, bison grazing would not necessarily result in 

improved conditions relative to cattle grazing because it is the manner in which grazing 

animals are managed that will affect the condition and composition of plant resources.

For instance, confining a given number of cattle or bison within a fenced pasture until a 

certain percentage of utilization has occurred would provide similar results. Although 

bison may exhibit different landscape-level grazing patterns than cattle, including less 

time spent within woody draws or riparian systems and decreased selection for forb 
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52 | C h a p t e r 2

species (Steuter and Hidinger, 1999), these differences would be diminished within 

pastures of a limited size. 

Additionally, an alternative for free-roaming bison was considered but eliminated from 

detailed analysis in the Northern Great Plains FEIS (see 2003 WO appeal decision, 

starting at page 19). It was eliminated for several reasons: first, the state would need to 

fully support and participate in such an alternative; and second, a similar response from 

the mixed-grass prairie can be gained by domestic livestock. Conditions today are the 

same as they were during the Grasslands Plan revision.

For the above reasons this alternative was dropped from detailed analysis. 

3) “The AMP DEIS needs to include LRMP amendments that will include deletion of the ‘no 

net’ increase in range structures, revision of high structure and VOR standards to reflect 

site capability and maintaining grazing levels, revision of PFC criteria designed for 

western North Dakota, and revision of woody draw standards to reflect historical 

distribution and trend data, will recalculate AUMs and evaluate whether larger livestock 

affect forage health and vigor adversely, and will include all lands in calculation of 

carrying capacity.”

This was an alternative brought forward during the DEIS comment period. This 

alternative would revise or remove a number of Grasslands Plan goals, objectives, and 

standards and guidelines in order to keep on-the-ground conditions “as is” and maintain 

grazing levels.

‘No net’ increase in range structures.

The Grasslands Plan allows for an increase in range structures. The no net increase 

limit on range structures was in the Draft Grasslands Plan but was changed between 

the draft and the Final Northern Great Plains EIS. The Grasslands Plan guideline for 

range infrastructure is to “Use nonstructural range management techniques such as 

water management, herding, riding, and mineral management to achieve desired 

conditions. If nonstructural management methods are not successful, then new 

structural development may be used to achieve desired conditions” (Grasslands Plan, 

pp. 2-15, 2-22). In addition, Alternatives 3, 3A, and 4 all include an increase in range 

structures; therefore this component has already been considered.

All of the action alternatives in the analysis contain provisions for additional range 

infrastructure. These are summarized in Table 2.15.

Revise high structure and VOR standards to reflect site capability and maintaining 

grazing levels.

As identified in the Herbaceous section of Chapter 3 of this FEIS, the habitat types 

used to define biologically capable areas are fully capable of producing High 

herbaceous structure as defined by the current VOR value for High structure.

Therefore, a Grasslands Plan amendment is not needed.
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The Grasslands Plan is an outcome-based document; it defines desired resource 

conditions, goals, and objectives. It does not specify maintaining set levels of grazing, 

recreation, oil and gas production, or any other resource. Maintaining set grazing 

levels does not provide needed management flexibility to attain the Grassland goals 

and objectives. Grazing is a tool used to help achieve desired conditions; saying the 

tool must always be used the same way, maintaining current grazing levels, is 

inconsistent with the basic tenet of the Grasslands Plan. 

Revision of PFC criteria designed for western North Dakota.

This request was not carried forward because it addresses how to analyze impacts, not 

how to manage impacts.

Revision of woody draw standards to reflect historical distribution and trend data.

There are no standards in the Grasslands Plan associated with woody draws. The 

Grasslands Plan goals, objectives, and guidelines (Grasslands Plan, pp. 1-2, 1-3, 1-13, 

2-10, 2-17) identify the desired conditions for existing woody draws. Distribution and 

trends for woody draws are addressed in Chapter 3 of this FEIS

Recalculate AUMs and evaluate whether larger livestock affect forage health and vigor 

adversely.

Some commenters felt the Forest Service approach to calculating AUMs was not 

correct. The method used by the Forest Service was peer reviewed by the Agricultural 

Research Station (ARS) and utilized production information provided by the NRCS. 

The methodology is explained in detail in the Range section of Chapter 3 of this

FEIS. Differing methods of calculating carrying capacity does not dictate the need to 

amend the Grasslands Plan. 

The Grasslands Plan doesn’t evaluate actions; rather it provides guidance on how to 

manage the DPG to obtain desired goals and objectives. The question of forage health 

is not tied to animal size alone. Rather it is associated with the timing, duration,

season, and number of livestock grazed in a particular setting such as an allotment. If 

a permittee is grazing at the wrong time (i.e. season), for too long a period, and with 

too high a stocking level, damage to resources will occur regardless of livestock size. 

Include all lands in calculation of carrying capacity.

The DPG has addressed this request in its response to SRT Recommendation I-2. 

However, this analysis did consider production on all areas capable of producing 

forage. See the Range section in Chapter 3 of this FEIS for more detailed information.

Maintaining the existing condition in this project area would not be consistent with the 

rest of the Grasslands Plan, the SRT report and the Forest Service response. Throughout 

the Northern Great Plains planning process, the SRT reports and the Demonstration 

project itself, the need for a different weighting of multiple uses on the ground is a key 

theme. The SRT itself, in response to one of the comments raised by the Heritage 
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54 | C h a p t e r 2

Alliance of North Dakota (HAND), states “[i]t is the opinion of the SRT that the 

perceived problems associated with the current FEIS and LRMP stem largely from 

differences among affected parties in value systems rather than scientific shortcomings” 

(2006 ROD, p. 4).

The SRT further states in another response:

[i]t is also critical that all affected parties understand that proposed 

changes in resource use cannot be solely driven by available ecological 

monitoring data. Rather, public land management goals and objectives 

must include, by law, public driven, multiple use goals and objectives, 

many of which are driven by factors other than ecological condition. 

Livestock production is still the dominant feature of the new Plan, but the 

Plan must and does include other goals and objectives that reflect public 

land use desires (2006 ROD, p. 5).

It is not at all certain that, over the long term, managing to maintain grazing levels as 

requested in this alternative would leave the ground capable of supporting even a single 

use management of livestock production. Excessive use over time may result in on-theground conditions that would produce fewer pounds of forage per acre and result in the 

need to reduce time on the ground, livestock numbers, or a combination of both. 

For the above reasons, this alternative was not considered in further in this analysis.

4) An alternative that would require that grazing levels (Authorized Use) be maintained. 

This alternative is addressed in the analysis under Alternative 2.

MONITORING

Monitoring includes both grasslands-level and project-level analysis and evaluation. Grasslandslevel monitoring is discussed at length in Chapter 4 of the Grasslands Plan and is not reiterated 

here. Project-level monitoring is the focus of this section of the FEIS.

Monitoring and evaluation are key elements of adaptive management. Adaptive management is 

proposed under Alternatives 3, 3A, and 4. Even under Alternatives 1 and 2, monitoring and 

evaluation would be important. Monitoring helps determine how well Grasslands Plan and 

NEPA decisions are being implemented, whether AMP implementation is achieving the desired 

outcome, or whether changes in management are needed. Through monitoring, the Forest 

Service can measure whether or not management actions are meeting or moving towards desired 

conditions in an appropriate timeframe. Through adaptive management, AMPs can remain 

dynamic, relevant, and useful documents over many years. Additional discussion of adaptive 

management is contained in Chapter 1.

Two types of monitoring are associated with initiating management actions for a grazing 

allotment—implementation monitoring and effectiveness monitoring. Implementation 

monitoring generally measures and documents whether or not Grasslands Plan standards and 
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guidelines and project-level design criteria (as selected in the record of decision for this project) 

are being applied. Effectiveness monitoring evaluates how effective management actions are at 

moving toward, achieving, or maintaining desired conditions. Under Alternatives 3, 3A, and 4, if 

a management action is determined not to be effective, the monitoring will trigger

implementation of an adaptive management action. Under Alternatives 1 and 2, additional NEPA 

would be required before any substantive changes could be made.

Monitoring on the allotments can be accomplished by the Forest Service, permittees, or others

(such as university partners and North Dakota Game and Fish), implementing approved methods 

and appropriate documentation that meets specified standards. Herbaceous structure, 

composition, riparian areas, and green ash woody draws will be the focus of effectiveness 

monitoring. Table 3 under each allotment write-up located in Chapter 3 Part 2 identifies the type 

and frequency of monitoring that is proposed for each allotment. 

Implementation (Short-Term) Monitoring

Implementation monitoring is short-term monitoring that evaluates whether livestock 

management is being applied as prescribed in the AMP and implemented through the AOI. The 

Forest Service in conjunction with the MGA, under the direction of the Grazing Agreement,

conducts this type of monitoring. 

COMPLIANCE WITH ALLOTMENT MANAGEMENT PLAN (AMP) AND ANNUAL OPERATING 

INSTRUCTIONS (AOI)

An AMP is the individual plan developed for a specific allotment. It identifies desired 

conditions, goals, and objectives applicable to the allotment to move it towards, achieving or 

maintaining desired objectives. 

The AOIs implement the AMP and clearly explain how each allotment is to be managed on a 

year-to-year basis. The 2009 Grazing Agreement defines AOIs as “detailed, FS and the MGA

approved, instructions for livestock grazing administration to be implemented in a given year on 

a given allotment developed in conjunction with the MGA and the member. AOIs are based on 

the AMP and show number of livestock to be grazed, season of use, responsibilities for 

improvement construction or maintenance, and pasture rotation schedules.” On-the-ground 

implementation of the AOI is the MGA’s and the permittees’ responsibility. Checks by the 

Forest Service and/or the MGA conducted throughout and following the grazing season, 

including discussions with the permittee, will be used to evaluate compliance with the AOI and 

AMP.

Effectiveness (Long-Term Trend) Monitoring

Effectiveness monitoring is long-term monitoring that focuses on determining whether

management is successful at maintaining existing desired conditions or is moving rangeland 

resources towards desired conditions. Determining trend toward or away from allotment 
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objectives allows rangeland managers to accurately determine the relative success of the 

management system and to adjust management to achieve the accomplishment of objectives.

Effectiveness monitoring, as applied here, would center on responding to the “need for action” 

described in Chapter 1. The long-term health of riparian areas, herbaceous composition and 

structure, and green ash woody draws will be monitored on each allotment using the methods 

described in Table 2.5 below. It is important to note that resources may be monitored more or 

less frequently than identified in Table 2.5 if the responsible official decides there is a need to do 

so. Completing needed monitoring will require a coordinated collaborative effort between the 

Forest Service, its agent the Medora Grazing Association, and others such as the North Dakota 

State University and Dickinson State University.

Table 2.5 — Effectiveness monitoring schedule 

Monitoring Item Method General 

Frequency

Riparian areas PFC

Every 3 years for streams rated as 

FAR-NA, FAR-D, or NF. Every 5 

years for streams rated as PFC or 

FAR-U.

Woody draws Sapling 

Density Once within a 3 to 5 year timeframe.

Herbaceous 

structure VOR

Approximately 25 percent of the 

allotments would be monitored 

annually for 3 years then reevaluated 

to determine monitoring frequency. A 

third of the remaining allotments, 

would be monitored every year over 

the same 3-year period.

Seral stages

NDSU 

Ecological 

Sites and/or

NRIS TERRA

Once within a 3- to 5-year timeframe.

WATER QUALITY 

In response to comment provided by the EPA on the DEIS, water quality monitoring is proposed 

for a portion of the Little Missouri River (LMR), Whitetail, Mikes, and Magpie Creeks. 

Water quality monitoring is proposed in the main stem of the LMR above and below the 

confluences with Whitetail and Mikes Creeks. If Whitetail and Mikes Creeks are flowing at the 

time the LMR is sampled, then water quality data and discharge data will be collected at their
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confluence with the LMR. These two intermittent creeks and their supporting tributaries 

encompass a majority of the project area and therefore, were selected for monitoring. 

The state of North Dakota has recently replaced sampling for fecal coliform with testing for E. 

coli; therefore, sampling done during the monitoring period will be for E. coli. A minimum of 

five samples will be collected during a 30-day period between June 1st and September 30th to 

facilitate comparison with North Dakota’s water quality standards. All established state water 

quality sampling and laboratory testing protocols will be followed.

PFC surveys, which would serve as a surrogate for assessing water quality in relation to fecal 

coliform, will be conducted on Magpie Creek. As a stream reach improves towards PFC, so does 

its associated riparian wetland plant community. As the riparian habitat improves, so does its 

ability to filter out fecal coliform, resulting in improved water quality (Shirmohammadi and 

Montas 2003, Pachepsky et al. 2006, Sullivan et al. 2007).

TRIGGER POINTS

The value of monitoring under an adaptive management approach is that it reveals how 

management is performing relative to desired conditions. A natural extension of this process is to 

ask, “At what point do we consider the need to change management if monitoring indicates a 

lack of acceptable progress towards desired conditions?” The point at which monitoring indicates 

a possible need for change is called a trigger point. 

Once a trigger point is reached, the district ranger will convene a team. The team, composed of 

Forest Service specialists in consultation with the 

affected permittee and MGA Director, will review 

the monitoring data and other pertinent information 

to determine if a management adjustment is needed. 

If it is determined that any adjustments are needed, 

the team will review the adaptive management 

options identified in Table 3 under each allotment 

write-up located in Chapter 3 Part 2 and/or the 

Grazing Management Toolbox and recommend a 

course of action to the District Ranger.

Monitoring triggers for each of the primary resource 

issues are identified below. The triggers are applied 

at the allotment level.

Riparian

The long-term health of riparian areas will be 

monitored using Proper Functioning Condition

protocol. This protocol assesses and classifies 

streams as: PFC, FAR-U, FAR-NA, FAR-D, or NF

A trigger point implements a review 

process; it doesn’t mean a 

management change is automatically 

needed. Take, for example, a stream 

that is rated at FAR-NA (Table 2.9). To 

start moving the stream towards FAR-U 

a series of initial actions are 

implemented on the allotment. If 

monitoring 5 years hence shows the 

stream hasn’t achieved the next 

condition class, e.g., FAR-U, the 

monitoring information would be 

reviewed. If the review indicates 

significant progress is being made and 

that what is needed is an additional 1

to 2 years to achieve the next condition 

rating, the district ranger may decide to 

continue the current course of action 

with continued monitoring to ensure 

the goal is achieved in that timeframe.
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(Table 2.9). These ratings are a classification of riparian condition based on the presence or 

absence of specific vegetation and the interactions of that vegetation with geology, hydrology, 

and soils.

The techniques and protocols for monitoring riparian areas are listed in the Riparian Area 

Management TR 1737-15, 1998, A User Guide to Assessing Proper Functioning Condition and 

Supporting Science for Lotic Areas. Table 2.6 identifies the triggers associated with riparian 

monitoring. 

Table 2.6 — Riparian monitoring trigger points

Existing Stream 

Condition

Trigger Point

Every 3rd or 5th year post 

implementation*

Trigger Point

Every 6th or10th year post 

implementation

Nonfunctional

(NF)

Stream has not improved to 

FAR status in 3 years. 

Determine which processes are 

nonfunctional and what the 

cause(s) are. Identify 

management modifications.

If stream has not improved 

to FAR-U status in 6 years, 

determine which processes 

are nonfunctional and what 

the cause(s) are. Identify 

management modifications.

Functional-At RiskDownward Trend

(FAR-D)

FAR-U is not met in 3 years. 

Determine which processes are 

functional at risk and what the 

cause(s) are. Identify 

management modifications.

If stream is not at PFC in 6

years, determine which 

processes are FAR and what 

the cause(s) are. Identify 

management modifications.

Functional-At RiskTrend Not Apparent

(FAR-NA)

FAR-U is not met in 3 years. 

Determine which processes are 

functional at risk and what the 

cause(s) are. Identify 

management modifications.

If stream is not at PFC in 6

years, determine which 

processes are FAR and what 

the cause(s) are. Identify 

management modifications.

Functional-At RiskUpward Trend

(FAR-U)

PFC is not met in 5 years.

Determine which processes are 

preventing attainment of PFC 

and identify management 

modifications.

PFC is not met in 10 years.

Determine which processes 

are preventing attainment of 

PFC and identify 

management modifications.

Proper Functioning 

Condition

(PFC)

If no management change is 

needed, continue to monitor 

stream every 5 years.

If no management change is 

needed, continue to monitor 

stream every 5 years.

*Depending on the alternative selected, the district hydrologist has determined that three to eight stream reaches 

may take several decades to achieve PFC. Therefore, the monitoring frequency timeframes to reach PFC, 

identified in Table 2.9 would not be met. Further detailed information regarding these stream reaches is located in 

Chapter 3 of this document.
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Green Ash Woody Draws

The long-term health of woody draws will be monitored based on the number of surviving tree 

saplings. Among other variables, researchers have identified sapling numbers and cover of the 

tall shrub layer as key indicators of woody draw condition (Leisica 2001a; Jensen 1991; Butler 

and Goetz 1984; Bjugstad and Girard 1984; Hansen et al. 1984a; Butler 1983; Nelson 1961, 

1960; Severson and Boldt 1978; Boldt et al. 1978). Table 2.7 identifies the triggers derived from 

sample averages of Healthy, At Risk, and Unhealthy woody draws measured in the project area.
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Table 2.7 – Woody draw trigger points

Current Woody

Draw Rating

Trigger Points

3 to 5 years post 

implementation of initial 

management actions

Trigger Points

6 to 10 years post 

implementation of initial 

management actions

Unhealthy

Averaged 61 saplings* per 

acre, 44 trees/acre between 

1 and4 inch dbh, and/or 6 

percent choke cherry, 

serviceberry, or 

combination thereof.

Average number of 

saplings in a woody draw is 

less than 85/acre, and there 

are fewer than 35 trees/acre 

between 1 and 4 inch dbh, 

and/or less than11 percent 

choke cherry, serviceberry, 

or combination thereof.

Average number of saplings 

in a woody draw is fewer

than 359 per acre and/or 

less than 24 percent choke 

cherry, serviceberry, or 

combination thereof.

At Risk

Averaged 85 saplings per 

acre, 35 trees/acre between 

1 and 4 inch dbh, and/or less 

than11 percent choke 

cherry, serviceberry, or 

combination thereof.

Average number of 

saplings in a woody draw is 

fewer than 85 per acre and 

there are fewer than 35 

trees/acre between 1 and 4 

inch dbh, and/or less than 

11 percent choke cherry, 

serviceberry, or 

combination thereof.

Average number of saplings 

in a woody draw is fewer

than 359 per acre and/or 

less than 24 percent choke 

cherry, serviceberry, or 

combination thereof.

Healthy

Averaged 359 saplings per 

acre, 150 trees/acre between 

1 and 4 inch dbh, and/or 24 

percent choke cherry, 

serviceberry, or 

combination thereof.

Average number of 

saplings falls below 359 

per acre and there are fewer

than150 trees/acre between 

1 and 4 inch dbh, and/or 

less than 24 percent choke 

cherry, serviceberry, or 

combination thereof.

Average number of saplings 

falls below 359 per acre 

and/or less than 24 percent 

choke cherry, serviceberry, 

or combination thereof.

*Saplings refer to deciduous tree species found in green ash hardwood draws that are greater than 2.5 feet 

in height and less than 1 inch in diameter at breast height (dbh). 

Herbaceous Structure

Herbaceous structure refers to the vertical structure and density of vegetation types dominated by

grasses, sedges, and forbs, and where shrubs are absent or a minor component. It will be 

monitored through the collection of Visual Obstruction Readings (VOR). The Robel Pole 

methodology (Robel et al. 1970, Benkobi and Uresk 2000, Warm 2000) is used to collect the 

VOR information. Table 2.8 identifies the triggers associated with Herbaceous Structure 

monitoring. 
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Table 2.8 — Herbaceous structure trigger points*

 *This applies to all allotments except 133D5 because portions of this allotment are hayed on an annual basis.

If monitoring indicates that the existing herbaceous structure condition on a grazing allotment is 

less than the Tier I objective, shown in Table 2.10, a 3-year period is allotted to meet the 

herbaceous structure objectives of that tier. This is followed by another 3-year period to reach 

Tier II and a final 3-year period to reach Tier III, which is the Grasslands Plan Desired Condition 

for herbaceous structure. The same process is followed regardless of the tier level the existing 

condition falls into, except for Tier III. If at the end of each 3-year period monitoring indicates 

that the objectives haven’t been met, then a trigger point is tripped, which initiates the review 

and decision process identified above. 

Seral Stages (Plant Composition)

Plant composition for this analysis refers to the diversity of grasses, forbs, and grass-like species 

in a plant community. This composition is classified into early, mid, and late seral stages.

The trigger point tied to seral stages is the amount of the project area that is in each seral stage

(Table 2.9). The Grasslands Plan objectives for seral stages are 10 to 15 percent in early, 65 to75 

percent in mid, and 15 to 20 percent in late seral. 

The trigger for seral stages is based on incrementally moving towards desired early, mid, and late 

seral stage objectives across the landscape. Currently, the mid seral stage objective is being met, 

however, early and late seral stages are falling short of the desired future condition. Under the 

seral stages trigger, if the percentage of early and late seral stages does not increase to 10 percent 

Monitoring 

Frequency

Percentage of 

allotment in

LOW 

Structure

Percentage of 

allotment in

MODERATE 

Structure

Percentage of 

allotment in

HIGH 

Structure

Trigger 

Points

Third year post 

implementation

(Tier I)

25-30 percent 50-70 percent ≥10 percent

Structure 

objectives not 

met at end of 

third year of 

monitoring.

Sixth year post 

implementation

(Tier II)

15-25 percent 50-70 percent ≥15 percent

Structure 

objectives not 

met at end of 

sixth year of 

monitoring.

Ninth year post 

implementation

(Tier III - Grasslands 

Plan Structure 

Objectives Met)

10-20 percent 50-70 percent 20-30 percent

Structure 

objectives not 

met at end of 

ninth year of 

monitoring
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in 3 to 5 years after initial actions are initiated, then the trigger point is tripped, which initiates 

the review and decision process identified above. If desired seral stage objectives are not being 

met by the end of the second monitoring period, then the trigger point is tripped. Also, any 

increase in the percentage of Invaded Grass State would trigger the need for the review and 

decision process.

Table 2.9 — Trigger points for seral stages

Existing Seral Stages

Condition in Project Area

Trigger Point, 3 to 5 Years 

Post Implementation

Trigger Point, 6 to 10 Years 

Post Implementation

7% Early

72% Mid

5% Late

16% Invaded Grass State*

<10%

Maintain 65 to75 %

<10%

> 16% 

Not Maintaining 10 to15%

Not Maintaining 65 to 75%

Not Maintaining 15 to 20%

> 16%

*Invaded Grass State – A herbaceous plant community where invasive grasses comprise more than 30 

percent of the total plant composition and native grasses comprise less than 40 percent (NRCS 2009). 

COMPARISON OF ALTERNATIVES

The following tables briefly display the differences between the considered alternatives. Table 

2.10 summarizes the ability of the alternatives to meet the purpose and need. Table 2.11

summarizes the effects of the alternative by key issue. Table 2.12 summarizes the Authorized 

Use by alternative.

Table 2.10 — Summary of how the alternatives respond to the purpose and need

Purpose and 

Need Alternative 1 Alternative 2 Alternative 3*

Alternative 

3A*

Alternative 4*

Allow grazing 

and provide 

forage

No Yes Yes Yes Yes

Support ranching 

community No

Would 

continue to 

support 

existing 

ranching 

community. 

Would continue to 

support existing 

ranching community 

under initial actions. 

If reductions in 

Authorized Use were 

to occur as an 

adaptive action there 

is potential for a 

reduction in jobs and 

reduced income in 

the agricultural 

sector.

Same as 

Alternative 3.

Is projected to 

result in the loss 

of 1-4 jobs and a 

reduction in 

revenue in the 

agricultural sector.

Meet or move 

towards Desired 

Conditions for 

See Table 2.11 for a discussion specific to each key resource.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

C h a p t e r 2 | 63

Purpose and 

Need Alternative 1 Alternative 2 Alternative 3*

Alternative 

3A*

Alternative 4*

resources

Provide for 

management 

flexibility i.e., 

Adaptive 

Management

No No Yes Yes Yes

*Alternatives 3, 3A, and 4 are adaptive management alternatives. Responses in the table above are to initial actions proposed 

under each alternative to address resource concerns. The suite of additional management tools, under adaptive management, 

available to each alternative is the same. The difference among the three alternatives when considering the adaptive management 

portion of the alternatives is time. Alternative 4 initially takes more aggressive steps to address resource concerns than do

Alternatives 3 and 3A. If under Alternatives 3 or 3A monitoring reveals that more aggressive measures are required, being able to 

implement those measures and see significant results within the 10- to 15-year timeframe associated with this project becomes 

questionable.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

64 | C h a p t e r 2

Key issues and their indicator(s) by Alternative are shown in Table 2.11. Key issues were previously listed in Chapter 1.

Table 2.11 — Key issue comparison of the alternatives

Key Issue Indicator(s) Alternatives

1 2 3 3A 4

Riparian Existing stream 

condition and 

movement 

towards PFC 

based on riparian 

vegetation 

condition, 

sediment 

entrapment, and 

stabilization of 

stream banks and 

beds.

Removal of 

livestock would 

afford riparian 

vegetation 

recovery which 

would increase 

sediment trapping 

abilities and 

increase bank 

stabilization 

which, in turn,

would bring 

affected streams 

segments to PFC.

Stream segments 

adversely affected 

by the effects of 

road construction 

may continue to 

function below

PFC. 

This alternative would 

maintain the status 

quo in terms of the 

riparian vegetation 

condition and its

ability to trap 

sediment and 

stabilized stream

banks and beds. 

Percentages of PFC 

(51), FAR-U (4), 

FAR-NA (6), FAR-D 

(5), and NF (34) 

stream segments 

would remain the 

same. 

Initial actions would 

provide for riparian 

vegetation recovery, 

reduced bank disturbance,

and improved sediment 

capture. This would result 

in 23 of the 28 stream 

reaches identified as FAR 

or NF improving towards 

PFC. Eighteen of the 23 

reaches that would 

improve are rated as 

FAR-D or NF. Seven of 

these 18 reaches could 

improve but could take 

several decades to reach 

PFC.

Adaptive Management:

Implementation of 

different adaptive 

management tools would 

see the additional 

improvement of four 

stream segments not 

improved with initial 

actions.

There will be no 

improvement in allotment 

277 (Scairt Woman 

Draw). This is because 

the underlying cause of 

Same as 

Alternative 3. 

Initial actions would

provide for riparian 

vegetation recovery, 

reduced bank 

disturbance, and 

improved sediment 

capture. This would 

result in 27 of the 28 

stream reaches identified 

as FAR or NF improving 

towards PFC. Twenty 

seven of the FAR and 

NF reaches would 

improve although two of 

the 27 reaches are 

expected to take several 

decades to reach PFC

due to the existing 

condition.

Adaptive Management:

Implementation of 

different adaptive 

management tools could 

decrease the recovery 

time of the two reaches 

that are expected to take 

several decades to reach 

PFC.

There will be no 

improvement in 

allotment 277 (Scairt 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

C h a p t e r 2 | 65

Key Issue Indicator(s) Alternatives

1 2 3 3A 4

the functionality problem 

was not clearly due to the 

effects of livestock

grazing; therefore it was 

not clear that changes in 

grazing practices would

result in recovery during 

the time frame of this

project.

Woman Draw) for the 

same reason as identified 

under Alternative 3.

Woody draws Intensity, 

frequency, and 

season of 

disturbance on 

tree and shrub 

regeneration

relative to 

current levels of 

disturbance.

Removal of 

livestock would 

allow most At 

Risk and 

Unhealthy woody 

draws to recover 

to a Healthy 

condition rating. 

Some woody 

draws rated as 

Unhealthy are too 

heavily impacted 

and would 

eventually 

disappear from the 

landscape without

an investment in 

additional 

resources, such as 

planting of trees 

and shrubs. 

This alternative would 

maintain current 

Authorized Use 

numbers and grazing 

systems, range 

facilities, etc. 

Therefore the intensity 

and frequency of 

disturbance associated 

with livestock use 

would remain 

unchanged. Due to 

low sapling 

recruitment there is 

potential for some At 

Risk woody draws to 

shift to Unhealthy and 

for further reduction 

or loss of Unhealthy 

woody draws. The 

percentage of Healthy

woody draws would 

persist. 

Currently 51 percent 

of the woody draws 

are rated as Healthy, 

This alternative maintains 

Authorized Use at 

Preference and would 

implement other initial 

actions to address woody 

draw concerns. The initial 

actions would affect both 

the intensity and 

frequency of use 

providing an opportunity 

for some improvement in 

woody draw health. Of 

the 43 allotments in the 

project 5 have no woody 

draws and 6 are meeting 

objectives. Of the 

remaining allotments 12

are predicted to improve, 

14 would experience no 

change and 6 would 

decrease in condition.

Adaptive Management:

Adaptive management 

tools would improve 

impacted woody draws.

Under this 

alternative,

woody draw 

conditions 

would improve 

in 8 allotments, 

16 allotments 

would 

experience no 

change, and in 

8 allotments 

conditions 

would decrease.

Adaptive 

Management:

Same as 

Alternative 3.

This alternative would 

set Authorized Use at 

initial estimated carrying 

capacity. Except in three 

allotments this action 

would result in a 

decrease in both the 

intensity and frequency 

of disturbance associated 

with livestock use of 

woody draws. Of the 43 

allotments, 5 have no 

woody draws and 6 are 

meeting objectives. Of 

the remaining allotments

20 are predicted to 

improve, 9 would 

experience no change 

and 3 would decrease in 

condition..

Adaptive Management:

Adaptive management 

tools, if needed, are the 

same as Alternative 3 

and 3A. The difference 

between Alternatives 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

66 | C h a p t e r 2

Key Issue Indicator(s) Alternatives

1 2 3 3A 4

42 percent At Risk 

and 7 percent as rated 

Unhealthy.

3,3A, and 4, is the rate of 

expected change.

Because more aggressive 

initial actions are 

implemented under 

Alternative 4 the 

expected rate of change 

would be higher under 

Alternative 4.

Herbaceous 

structure

Trend of High 

structure.

Removal of 

livestock would 

see an increase in 

High structure and 

decrease in Low 

structure. 

Authorized Use would 

remain at current 

levels which in most 

of the allotments are 

above initial estimated 

carrying capacity. The 

8 allotments meeting

structure objectives 

would continue. The 

existing mosaic of 

structure on the 

remaining allotments 

would be maintained. 

This alternative would 

maintain Authorized Use 

at Preference and would

implement a series of 

different management 

actions. These actions 

would modify the existing 

structure mosaic but no 

increase in the amount of 

High structure is 

projected because the 

levels of Authorized Use, 

under initial actions 

remain at Preference.

Adaptive Management:

Adaptive management 

tools would move the 

existing structure mosaic 

towards structure 

objectives. 

Same as 

Alternative 3.

Establishing Authorized 

Use at initial estimated 

carrying capacity would 

change the structure 

proportions of the 

current structure mosaic. 

The amount of Low 

structure would 

decrease. Moderate and 

High structure would 

increase, but to what 

degree is unknown. 

Monitoring would 

document the amount of 

shift. 

Adaptive Management: 

Adaptive management 

tools, if needed, are the 

same as Alternative 3 

and 3A. The difference 

between Alternatives 

3,3A, and 4, is the rate of 

expected change.

Because more aggressive 

initial actions are 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

C h a p t e r 2 | 67

Key Issue Indicator(s) Alternatives

1 2 3 3A 4

implemented under 

Alternative 4 the 

excepted rate of change 

would be higher under 

Alternative 4.

Seral stages Trend of seral 

stages.

Removal of 

livestock grazing

would allow for a 

shift towards late 

seral stages and a 

decrease in early 

seral stages. 

Increasing 

invasive grasses 

would have the 

potential to 

impede 

development or 

maintenance of 

late seral native 

plant 

communities. 

Current management 

activities are not 

meeting early and late 

seral stage objectives.

The current level of 

grazing intensity and 

frequency of 

disturbance on native 

species would 

maintain the current 

seral stage mosaic.

However, current 

trends in invasive 

grasses have the 

potential to increase 

the proportion of 

invaded grass states. 

Under this alternative 

initial management 

actions would improve 

seral conditions in twenty 

percent of the allotments.

The remaining allotments 

would maintain their 

current seral condition, 

shift towards early seral 

stage, or experience an 

increase in invasive 

grasses.

Adaptive Management

Adaptive management 

tools would move 

towards desired seral 

objectives, however, 

invasive grasses may gain 

a greater foothold before 

adaptive tools are 

implemented under this 

alternative.

Same as 

Alternative 3.

Under this alternative 33 

percent of the allotments 

would have improved 

seral conditions through 

the implementation of 

initial management 

actions. Reducing 

Authorized Use to 

carrying capacity in 

native dominated 

communities would 

facilitate a shift towards 

late seral stage at a faster 

rate than Alternatives 3 

and 3A. However, 

communities with high 

proportions of invasive 

grasses may have the 

potential to transition to 

an Invaded Grass State. 

Adaptive 

ManagementAdaptive 

management actions 

would achieve seral 

objectives faster because 

there would be fewer 

allotments compared to 

Alternatives 3 and 3A to 

move towards seral 
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68 | C h a p t e r 2

Key Issue Indicator(s) Alternatives

1 2 3 3A 4

objectives. 

Economics A combination 

of jobs and 

income 

generated in the 

agricultural 

community.

Billings County 

economic 

analysis 

indicators are net 

margins and debt 

repayment 

capability. 

Loss of 20 to 39 

jobs and $359,497 

to $708,453 in 

annual income.

The Billings 

County economic 

analysis did not 

address this 

alternative.

Maintains 20 to 39

jobs. 

Annual income to the 

economic analysis 

area would range from 

$414,902 to $763,858.

The baseline 

assessment in the 

Billings County 

economic analysis 

showed that smaller 

operations (≤150 

head) have small net 

margins and little 

capacity to service 

debt. Larger 

operations (250-

350head) have larger 

margins and greater 

ability to service debt.

Maintains 20 to 39 jobs 

with potential for two 

additional jobs.

Annual income to the 

economic analysis area 

would range from 

$414,902 to $763,858 

The Billings County 

economic analysis did not 

specifically address this 

alternative. As 

Authorized Use is 

initially the same as 

Alternative 2 the 

economic effects are 

expected to be similar to 

Alternative 2.

Same as 

Alternative 3.

Billings County 

economic 

analysis 

identified that 

3A would not 

change their 

assessment as 

there is no 

initial change in 

Authorized 

Use. Therefore, 

economic 

effects are 

thought to be 

similar to 

Alternative 2.

Potential loss of 1 to 4 

jobs.

Annual income to the 

economic analysis area 

in year one would range 

from $382,404

to$699,814. At year five,

income would be 

$359,576 to $654,829.

Billings County 

economic analysis -

Reductions in 

Authorized Use would 

reduce net revenues / net 

margins and ability to 

service debt. Smaller 

operations (≤150 head) 

have less capacity to 

service debt and would 

be more quickly affected 

than larger 250- 350 

head operations.

Drought Precipitation No drought 

strategy needed.

No drought strategy in 

place. Would adapt 

DPG strategy when 

complete. 

Would use a modification 

of the McKenzie Ranger 

District strategy until the

DPG drought strategy is 

completed.

Same as 

Alternative 3.

Same as Alternative 3.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Chapter 2 | 69

In Allotment Management Planning analysis, a common question asked is how many cattle

would be permitted by alternative or what would the difference be in how many cattle are 

permitted by allotment, by alternative. This is normally expressed in how many Animal Months 

(AMs) or how many Animal Unit Months (AUMs) would potentially be permitted by each 

alternative. An AM is a month’s tenure upon the rangeland by one animal. An AUM is the 

amount of feed or forage required by an animal unit, a 1,000 pound cow with or without a calf up 

to 6 months of age, for 1 month. It’s important to understand that AMs and AUMs are not 

synonymous terms. Table 2.15 shows the AUMs by alternative, which specialists used as a way 

to compare between alternatives and their effects in Chapter 3. 

For comparison purposes in Table 2.12, the AMs authorized under Alternatives 2, 3, and 3A

were converted to AUMs by multiplying the Authorized Use AM number (Preference) by 1.15 

(see Grasslands Plan, Appendix I). This assumes that all of the animal units are larger cows 

within the range of 1,100 to1,300 pounds with an average of 1,200 pounds to get a conversion 

factor of 1.15 (the conversion factor is explained in detail in the Range section of Chapter 3). In 

some cases this will likely result in an over or under estimation, but, again, this is done for 

comparison purposes. 

Alternative 3, 3A, and 4 are adaptive-management-based alternatives. It is possible that the 

numbers in this table for those alternatives may change over time. If monitoring indicates that the 

initial actions are not successful in addressing resource concerns, adjusting the AMs/AUMs is 

one of the tools in the tool box that can be used (see Table 2.1 and other discussions on adaptive 

management).

Table 2.12 — Comparison of summer Authorized Use by alternative

NOTE DISCLAIMERS ABOVE

Allot # Alternative 1

AUMs

Alternatives 

2, 3, and 3A

AUMs

Alternative 4

AUMs

126/128 0 2708 2178

127 0 474 345

129 0 1150 1000

130 0 729 678

131 0 55 48

132A 0 202 202 

132H 0 370 353

133 0 313 198

133D5 0 56 35

134 0 292 220

135 0 1793 1559
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Allot # Alternative 1

AUMs

Alternatives 

2, 3, and 3A

AUMs

Alternative 4

AUMs

136/139 0 416 285

140 0 323 237

141 0 204 113

142 0 192 128

158 0 1801 1527

220 0 184 112

221 0 283 174

230 0 419 358

237 0 331 250

239 0 288 176

240 0 930 876

241 0 413 357

243 0 431 347

244 0 271 241

248 0 359 359

249 0 235 194

256 0 1830 1678

258 0 2382 1694

272 0 1694 1472

277 0 1298 1243

278 0 313 230

281 0 339 270

282 0 2441 2123

283 0 345 340

286 0 320 236

287 0 666 577

288 0 308 216

289 0 2057 1862

300 0 559 524

301 0 1916 1734

302 0 1201 1051

Total 0 32891 27801
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Chapter 2 | 71

Table 2.13 presents a summary of the different initial management actions and other information

associated with each of the alternatives.

Table 2.13 — Summary of initial actions by alternative

Proposed Action Alt 1 Alt 2 Alt 3 Alt 3A Alt 4

# of allotments with 

adjusted Authorized Use

0 0 0 0 41

# and (miles) of new fence 0 0 5 (6.2) 7 (6.4) 5 (6.4)

Total forage production in 

pounds 0 102,522,760 102,522,760 102,522,760 102,522,760

Total Authorized Use 0 29,125 AMs 29,125 AMs 29,125 AMs 28,340 AUMs

# and (acreage) of new 

riparian exclosures 0 0 1(3) 1(3) 7 (479)

# of new rangeland water 

wells 0 0 9 9 6

# of sites and (acreage) 

proposed for native tree & 

shrub planting

0 0 0 0 2 (129)

# of new water tanks and 

(approximate miles of new 

pipeline)

0 0 22 (17.9) 27 (23.2) 13 (11.6)

# of allotments with burning, 

mechanical, or chemical 

treatment of juniper or sage 

encroachment

0 0 2 2 2

# of dugouts, reservoirs, or 

springs reclaimed 0 0 12 2 6

# of springs or reservoirs 

fenced 0 0 8 9 9

# of new spring

developments 0 0 0 2 0

# of woody draws fenced 0 0 1 0 3

# of allotments with stream 

crossing hardening and 

stream control structures

0 0 1 1 1

# of waterlots constructed 0 0 1 2 1

Projected cost of proposed 

rangeland facilities 0 0 $597,750 $646,826 $486,375
FEIS Vol. I North Billings County Allotment Management Plan Revisions

72 | Chapter 2
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Chapter 3 | 73

Chapter 3 Part 1

Affected Environment and Environmental Consequences

INTRODUCTION

This chapter describes aspects of the environment affected by the proposed action and other 

alternatives. Also described are the environmental effects (direct, indirect, and cumulative) that 

would result from undertaking the proposed action or other alternatives. Together, these 

descriptions form the scientific and analytical basis for the comparison of the alternatives.

This chapter has been reformatted since the Draft Environmental Impact Statement (DEIS) was 

published. There are now two parts to this chapter. Part 1 provides an overview and summarizes 

the affected environment and environmental consequences for each resource. It also describes 

the methodology used in analyzing each resource. Part 2 provides specific information and effect 

analysis by allotment for each alternative and resource. This part was created to bring all the 

allotment-specific information together in one place. This remedies having to flip back and forth 

in the document to locate all the allotment-specific information. As a result of this reformatting,

the information in the DEIS Appendices A and C has been brought into Chapter 3, so those 

appendices have been dropped in the Supplemental Draft Environmental Impact Statement 

(SDEIS) and this Final Environmental Impact Statement.

PROJECT AREA

The project area contains 43 federal grazing allotments located in the northern third of Billings 

County, and a small portion of Golden Valley County, North Dakota. The allotments encompass 

all or portions of the following 11 townships: T142N, R101W and R102W; T143N, R99-103W; 

and T144N, R99-102W. The project area contains approximately 118,587 acres, of which 87,262 

are National Forest System (NFS) lands (Figure 1.1). The allotments in the project area are

intermingled with private and state lands. 

General Setting 

The project area is divided between the Rolling Prairie and Badlands Geographic Areas. The 

Rolling Prairie primarily occurs in the east half of the project area from 7 to 11 miles distance 

from the Little Missouri River. Topography of the Rolling Prairie is relatively gentle with broad 

ridgelines and plateaus divided by first and second order ephemeral or intermittent drainages that 

join perennial tributaries. The area is primarily drained by four intermittent creeks Magpie, 

Whitetail, Blacktail and Mike’s Creek, which flow west into the Little Missouri River, the only 

perennial stream in the project area. Elevation varies from 2,100 feet above mean sea level (msl)
FEIS Vol. I North Billings County Allotment Management Plan Revisions

74 | Chapter 3

along the Little Missouri River to 2,800 feet above msl on the plateau in Allotment 272, located 

on the eastern side of the project area (Figure 1.2).

The intermittent drainages support woody draw communities of green ash (Fraxinus 

pennsylvanica Marsh.), American elm (Ulmus americana L.), and chokecherry (Prunus 

virginiana L.). Major intermittent streams have downcut through level terraces or floodplains 

that support shrubs of silver sagebrush (Artemisia cana Pursh) and western snowberry

(Symphoricarpus occidentalis Hook.). Riparian vegetation along the streams tends to be 

dominated by various sedges and rushes, with scattered patches of sandbar willow (Salix exigua

Nutt.) and relatively decadent patches of plains cottonwood (Populus deltoides Marsh. subsp.

monilifera (Ait.) Eckenw.) and peachleaf willow (Salix amygdaloides Anderss.). Discontinuous 

bands of green ash/western snowberry communities are set back from the true riparian zone.

Relatively well-developed and productive soils constitute broad plateaus of the Rolling Prairie 

with the potential to support climax communities of western wheatgrass (Agropyron smithii

Rydb.) and needlegrass species. Areas of less developed or less fertile soil, such as those 

occurring on steep sideslopes and narrow ridgelines, have the potential to support climax 

communities of little bluestem (Schizachyrium scoparium (Michx.) Nash – Gould), prairie 

sandreed (Calamovilfa longifolia (Hook.) Scribn.), and needle-and-thread (Stipa comata Trin. & 

Rupr.).

Much of the projects area’s gentler terrain was plowed for agricultural production during the 

early 1900s before being purchased by the federal government after the Dust Bowl era of the 

1930s. These areas are referred to as broken land in this chapter. Broken lands were generally 

reseeded with crested wheatgrass or simply abandoned and allowed to naturally revegetate. Most 

of these lands are now composed of varying mixtures of crested wheatgrass (Agropyron 

cristatum (L.) Gaertn.) and other non-native and native grasses. The non-native grasses exhibit 

varying degrees of invasiveness that have facilitated their establishment in both broken and 

unbroken land.

The Badlands Geographic Area occurs on either side of the Little Missouri River and exhibits 

greater topographic relief and general ruggedness. Sharp topography of the Badlands was 

initiated when glaciers diverted the Little Missouri River eastward through southwest North 

Dakota (Bluemle, 1980). Increased gradients and relatively soft sedimentary strata along the new 

river path resulted in rapid downcutting of the river channel and adjacent tributary channels that 

resulted in the formation of diverse erosional features and exposed sedimentary formations of 

clay, shale, siltstone, fine-grained sandstone, and scoria. Relatively hard or erosion-resistant 

scoria and sandstone layers often occur as caprock formations on variously shaped buttes, knolls, 

and ridge shoulders. The overall landscape in the Badlands is characterized by a repeating 

pattern of relatively barren south aspect slopes, relatively narrow grass-dominated ridgelines, 

wooded north aspect slopes, and intervening intermittent/ephemeral drainages. Rocky Mountain 

juniper constitutes the dominant woodland on many north aspect slopes, with increasing 

prominence towards the Little Missouri River.
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Chapter 3 | 75

Extensive sedimentary exposures, particularly common on steep south aspect slopes and residual 

knolls and buttes, exhibit poor physical and chemical soil characteristics for the growth of most 

plant species. Total plant cover in these areas is low but the assemblage of species is relatively 

unique in comparison to the typical grassland communities. Common species on fine-grained 

and often alkaline substrates include grasses such as inland saltgrass (Distichlis spicata (L.) 

Greene var. stricta (Torr.)) and alkaligrass (Puccinellia nuttalliana (Schult.) A. Hitchc.), along 

with the more ubiquitous western wheatgrass, slender wheatgrass (Agropyron. Caninum (L.) 

Beauv. subsp. majus (Vasey) C. L. Hitchc.), and blue grama (Bouteloua gracilis (H.B.K.) Lag. 

ex. Griffiths) that occur at lower than typical rates. Coarser grained substrates derived from 

weathered sandstone and scoria are relatively non-alkaline and support a different suite of 

species that includes Indian ricegrass (Oryzopsis hymenoides (R. & S.)), bluebunch wheatgrass 

(Agropyron spicatum (Pursh) Scribn. & Sm.), little bluestem, sand bluestem (Andropogon hallii

(Hack.) and prairie sandreed.

Various ridgelines, plateaus, and relatively gentle slopes with increased soil development support 

grassland communities similar to but less extensive than the Rolling Prairie. Sideoats grama 

(Bouteloua curtipendula (Michx.)) often occurs with little bluestem along ridge shoulders with 

mat-forming shrubs of horizontal juniper (Juniperus horizontalis Moench). Lower slope 

positions and drainages support green ash woody draw communities that tend to exhibit 

increased prominence of Rocky Mountain juniper (Juniperus scopulorum Sarg.) compared to 

drainages in the Rolling Prairie. Floodplains and terraces of the Little Missouri River support 

gallery woodlands of plains cottonwood, green ash, and Rocky Mountain juniper, interspersed 

with shrub communities of silver sagebrush, willows, and western snowberry. 

The climate in the area is semi-arid continental with large seasonal and diurnal variations in 

temperature. Annual average temperatures are near 42 degrees Fahrenheit (F), with monthly 

averages ranging from 10 degrees F in January to 71 degrees F in July. Precipitation, in the form 

of rain and snow, averages around 15 inches per year; 75 percent of this precipitation falls in a 6-

month period between April and September. In contrast, November through February is a dry 

period with roughly one-half inch of precipitation monthly in the form of snow. Wind speeds 

average about 12 miles per hour, with the prevailing wind generally out of the west/northwest. 

Strongest winds occur during the winter and spring months, with speeds of 30 to 40 mph not 

uncommon. 

Intermingled private land is primarily used for livestock grazing, and lesser amounts of 

agricultural cultivation occur in both geographic areas. Livestock grazing and related 

infrastructure of fences, water developments, and two-track roads have occurred throughout the 

project area since the late 1800s. Currently, the Medora Grazing Association (MGA) holds a 10-

year grazing permit for the project area. Oil and gas were first discovered in the Williston basin 

of western North Dakota in 1950. Within the project area, oil and gas was developed in the 

1960s with exploration and development continuing to the present. The mid 1970s saw an oil 

boom on the LMNG, which lasted through about 1981. With the boom came extensive road 

development, oil pads, and pipeline and utility corridors, which resulted in visual, wildlife, air,

and water impacts. 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

76 | Chapter 3

The project area is accessed by National Forest System Roads (NFSR) #712 (Lower Magpie), 

#711 (Goats Pass), Forest Highway (FH) 2 (Blacktail), and #702A (Mike’s Creek), which serve

as the main collector roads for the project area. The area is also served by a host of primitive 

native surface roads known locally as “two-tracks.” The two-track road system is used primarily 

for administration of range allotments and various recreation activities. Most two-track roads are 

currently open to the public for their use and enjoyment. Under the January 2001, U.S. Forest 

Service Northern Region Off-Highway Vehicle Decision, motorized use is limited to existing 

roads and trails with exceptions for livestock permittees, oil and gas lessees, and administrative 

business (2002 Grasslands Plan ROD, p. 9). Some management areas located in the project area,

such as MA1.31 “Nonmotorized Backcountry Recreation,” are not open to motorized use. 

Currently travel management on the Little Missouri National Grassland (LMNG) is being 

reviewed and analyzed for updates.

There are four inventoried roadless areas (IRA) totally or partially located within the project area 

boundary: Scairt Woman, Magpie, Blacktail, and Bell Lake. The Two Top/Big Top Research 

Natural Area (RNA), a small portion of the Mikes Creek RNA, and the Ice Caves Special 

Interest Area (SIA) are also located within the project area.

PAST, PRESENT, AND REASONABLY FORESEEABLE ACTIONS

According to the Council of Environmental Quality (CEQ) NEPA regulations a, “Cumulative 

impact is the impact on the environment which results from the incremental impact of the action 

when added to other past, present, and reasonable foreseeable future actions...” (40 CFR

§1508.7). Cumulative effects are those effects from other actions that overlap in time and space 

with the proposed action as past actions are already included in the affected environment, the 

cumulative effects analysis builds upon this existing condition assessment by considering the 

incremental addition of the direct and indirect effects of the proposed action as well as ongoing 

and reasonably foreseeable future actions. 

An overview of past, present, and reasonably foreseeable actions are discussed below.

Past Actions

The environmental analysis required under NEPA is forward-looking in that it focuses on the 

potential impacts of the proposed action that an agency is considering. Thus, review of past 

actions is required to the extent that this review informs agency decision-making regarding the 

proposed action (36 CFR 220.4(f)). The past actions summary is not necessarily exhaustive, as 

records may not exist for all past activities. This is particularly true for those actions that predate 

the passage of the NEPA in 1970. Nonetheless, the effects of such past actions are accounted for 

in the assessment of the existing condition, as the current condition assessment necessarily 

reflects any relevant impacts of such action. Past actions that are relevant to this analysis are 

homesteading; drought, depression, and rehabilitation; range management; oil and gas 

development; and noxious weeds.
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HOMESTEADING

In 1862, President Abraham Lincoln signed the first Homestead Act, making it possible for 

citizens to acquire ownership of 160 acres of land. The Homestead Act and the completion of the 

Northern Pacific Railroad across North Dakota in 1881 had a significant effect on the settlement 

of western North Dakota. From 1878 to 1890, North Dakota’s population boomed, growing from 

16,000 to 191,000 people (Berger and Turck, 2003) and reaching a peak population in the late 

1920s, which also signaled the end of homesteading era. 

Euro-American settlement brought farming and ranching operations, fences, livestock water 

developments, and rudimentary roads. Woodlands were heavily utilized for fuel, building 

materials, fence posts, and livestock fodder. Farmers broke up the native prairies for crops, and 

ranchers replaced free-roaming bison with domestic cattle. 

Loss of the native beaver populations through trapping, construction of reservoirs and dugouts to 

supply water to livestock, overstocking the range, increased overland flow due to reduced upland 

vegetation, trampling of stream banks, and heavy utilization of woodlands affected the riparian 

systems of western North Dakota. The loss of beaver populations impacted groundwater storage 

systems and lowered water tables. Construction of reservoirs and dugouts interrupted runoff 

patterns by intercepting water that may have been necessary to maintain perennial streams. 

Heavily used rangelands allowed overland flows to increase, which when combined with 

impacted woodlands, resulted in accelerated down cutting of perennial and major intermittent 

streams. Changes in the water regime also affected associated riparian vegetation, resulting in 

loss or changes in the diversity and abundance of riparian species. 

Cattle have been grazed in western North Dakota since the 1870s. In the early days of open 

range, cattle stocking rates were often excessive. Overstocking, combined with the summer 

drought of 1886, reduced an already scanty supply of grass. That winter, one blizzard followed 

another, accompanied by terrible cold. These events resulted in the loss of about three-quarters of 

the range cattle (Berger and Turck, 2003). Theodore Roosevelt, a rancher along the Little 

Missouri River at the time, absorbed his losses and reentered politics and later spoke of the need 

for conservation and wise use of the range resources.

Euro-American settlement also resulted in early attempts to control fire on the landscape. With 

time, this has developed into firefighting organizations at the county, state, and federal levels. 

Controlling fire has resulted in both the expansion and decline of woodlands. The lack of fire has 

allowed ponderosa pine and Rocky Mountain juniper stands to expand. It has also allowed some 

green ash draws to expand, but existing green ash stands have lost the regenerative effects of fire. 

Existing green ash hardwood stands are deteriorating in part due to a lack of fire, which plays a 

role in maintaining this type of woodland. Native grasses, which evolved with fire, no longer 

benefit from the nutrient flush and regenerative effects associated with fire. 

Around the turn of the 20th century, Lincoln Lang, an early settler said this about the 

homesteading era: “This was the beginning of the end. Already two waves of commercial 

vandalism had overswept the region—the primary wave of criminally insensate game butchery 
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[and] the secondary wave of unintelligent grazing. Now, the third and final disastrous tidal wave 

of ill-advised settlement, was on its way and coming fast” (Lang 1926:335). 

Severson (Undated) observed that “the [Homestead] Act did not recognize the fragile nature of 

the prairie lands, the realities of the wet-dry cycles, and the unsuitability of much of the land for 

continual cropping. This was not common knowledge at the time, and the result was further 

habitat destruction induced by plowing of fragile soils and intensive livestock grazing on small 

acreages.”

DROUGHT, DEPRESSION, AND REHABILITATION

The effects of the Euro-American settlement era, combined with the drought and depression of 

the 1930s, affected both the landscape and populace of western North Dakota. The severe 

drought and past actions such as overgrazing and the cultivation of sub-marginal lands resulted 

in extensive loss of topsoil to wind erosion. The drought, coupled with the depression, saw the 

five counties which constitute the LMNG lose 16 percent of their population (USFS 2002). 

The government, through the Land Utilization Program (LUP) and other programs, purchased 

many farms during the 1930s, with a goal of stabilizing and reclaiming eroded lands and then 

returning the lands to their most suitable use. This job was given to the Soil Conservation 

Service (SCS), now the Natural Resources Conservation Service (NRCS). From 1938 to 1954 

the SCS provided technical and financial assistance for soil stabilization, stock pond 

construction, shelterbelt plantings, and other range improvements (USFS 2002). 

During this time, the SCS introduced the use of non-native species such as crested wheatgrass to

stabilize eroding lands. Crested wheatgrass successfully stabilized soils; however, because it 

breaks dormancy earlier than native species, it is able to out-compete them for water and 

nutrients. This in turn has prevented or slowed the process of native grasses re-establishing on 

disturbed lands. Because crested wheatgrass is palatable earlier in the grazing season, 

management tries to utilize it first. However, in pastures with mixed crested wheatgrass and 

native grasses, this can have a detrimental effect on the native species because they have not 

reached the three-and-a-half leaf development stage that signals their readiness for grazing. 

Other introduced non-natives, such as smooth brome (Bromus inermis Leyss. subsp. inermis), 

Japanese brome (Bromus japonicus Thunb. ex. Murr.), and Kentucky bluegrass (Poa pratensis

L.), have invaded native grass communities and have similar effects on native species as those 

caused by crested wheatgrass.

In 1954, the administration of the LUP lands that constitute the LMNG were transferred to the 

U.S. Department of Agriculture, Forest Service. As directed by Congress, administration under 

the Forest Service introduced the concept of multiple use land management to the LMNG. 

However, management remained focused on commodity production. The 2002 Dakota Prairie 

Land and Resource Management Plan sought to provide a more balanced approach between 

commodity and non-commodity uses.
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RANGE MANAGEMENT

During the late 1970s and 1980s, Forest Service objectives for rangelands included improving

the distribution of livestock to get better utilization of forage produced, reducing impacts on 

heavily used areas, and increasing red meat production, which was also in concert with the 

prevailing local opinion at the time (Jim Wickel, personal communication, 2010). The general 

approach to meeting these objectives was through increased development of range infrastructure,

including developing range water (water wells, reservoirs, dugouts, springs); adding stock tanks;

cross fencing allotments to create more but smaller pastures, etc. Because a higher level of 

financial range resources was available from the grazing fee during this time period, a significant 

amount of new range infrastructure was constructed (Jim Wickel, personal communication,

2010). The increase in range infrastructure affected grazing and utilization patterns, which in 

turn affected rotations, stocking levels, etc. Development of additional infrastructure provided 

opportunities to more effectively utilize forage, which affected the mosaic of herbaceous 

structure and associated wildlife. Opportunities to spread noxious weeds and invasive plants also 

increased with the development of new infrastructure, because of associated changes in livestock 

distribution and grazing patterns.

OIL AND GAS DEVELOPMENT

Oil and gas development in the project area was first initiated in the 1960s and continues to the 

present. Development is located primarily in the Badlands Geographic Area, with a few oil and 

gas wells having been developed on the Rolling Prairie. Much of the existing transportation 

system in the project area was constructed or reconstructed to supply year-around access to oil 

and gas wells. As oil and gas wells played out, their associated well pads and access roads were 

generally reclaimed.

Approximately 177 oil and gas wells have been developed in the project area since the 1960s. 

The wells have taken approximately 443 acres out of forage production and other uses. In terms 

of forage, about 129 animal unit months (AUMs) are temporarily lost due to the construction of 

the oil and gas pads. An AUM is the number of pounds of forage (913 air dry) required to 

maintain a 1,000 pound cow with or without calf for one month. However, over the years, 110 of 

the oil and gas pads have been reclaimed regaining approximately 81 AUMs. Disturbed area, 

associated with the 67 active oil and gas wells, is approximately 168 acres, with about 48 AUMs 

temporarily lost to the pads (Table 3.1). 

Approximately 54 miles of road have been constructed to provide access to the oil and gas wells. 

The roads have removed about 391 acres of land from forage production accounting for a 

temporary loss of 116 AUMs. Since the 1960s, about 13 miles of the total 54 miles of road have 

been reclaimed regaining 31 AUMs. There are currently about 297 acres occupied by active oil 

and gas roads in the project area, with roughly 85 AUMs temporarily lost to the roads (Table 

3.1). 
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Table 3.1 — Summary of acres and AUMs associated with active and reclaimed oil and gas 

pads and roads in the project area

Active Oil 

and Gas Wells

Reclaimed Oil 

and Gas Wells

Active Oil and 

Gas Roads

Reclaimed Oil 

and Gas Roads

# of wells or 

miles of road

67 110 41 13

Acres 168 275 297 94

AUMs regained 81 31

AUMs 

temporarily lost

48 85

In total, approximately 245 AUMs have been affected by oil and gas activities in the project area

since the 1960s. Reclamation of oil and gas pads and oil and gas access roads has resulted in a 

return of 112 AUMs. Continuing oil and gas activities have temporarily removed 133 AUMs 

from the project area.

Arguably, the largest impact of the oil boom was the development of an extensive system of 

roads. The new roads allowed year-round access into many areas that had formerly been 

accessible only during dry weather conditions, by foot, or horseback. They served as vectors for 

the introduction and/or spread of noxious weeds and non-native grasses and forbs. Stream 

crossings and road ditching adversely affected some intermittent streams. The new road system 

provided or improved access for livestock into areas formerly inaccessible or unattractive 

because of natural barriers or rough topography. In some cases, secondary range was likely 

converted to primary range. The roads also fragmented wildlife habitat, reduced security areas, 

and exposed wildlife to heavier hunting pressures. 

NOXIOUS WEEDS

Noxious weeds are a scourge to the prairie ecosystem. They displace and crowd out native

plants, modify wildlife habitat, reduce livestock forage, adversely impact watersheds and riparian 

areas, and are costly to control. To address this concern the DPG in 2007 completed the Noxious 

Weed Management Project Final Environmental Impact Statement (FEIS) and its accompanying 

ROD. The ROD approved the use of the integrated adaptive approach to continue to treat 

existing and future infestations of noxious weeds. 

Present and Reasonably Foreseeable Actions

Present actions are the same as past with the exception of farming and homesteading, which no 

longer occur on NFS lands in the project area. Agricultural practices do occur on intermingled 

private lands within the project area, which may affect resources on NFS lands. Reasonably 

foreseeable actions are those federal or non-federal activities not yet undertaken, for which there 

are existing decisions, funding, or identified proposals (36 CFR 220.3). Identified proposals for 

the Forest Service are those where the Forest Service has a goal and is actively preparing to 
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make a decision on one or more alternative means of accomplishing that goal and the effects can 

be meaningfully evaluated (36 CFR 220.(a)(1)). The present and reasonably foreseeable actions 

that are relevant to this analysis are travel management, wildfire, Elkhorn Ranchlands Grasslands 

Plan amendment, and oil and gas development. 

TRAVEL MANAGEMENT PLAN

The DPG is currently in the process of completing a travel management plan for the Little 

Missouri National Grassland, which contains the project area. In November 2005 the Travel 

Management; Designated Routes and Areas for Motor Vehicle Use (Travel Management Rule)

was published. The Travel Management Rule requires that NFS roads, trails, or areas open to 

motor vehicles be designated on a motor vehicle use map, which is available to the public.

Depending on the final decision associated with this action and if access to single use roads are 

blocked, it is possible that additional two-track roads could be created as livestock grazing 

permittees seek to administer their permits.

WILDFIRE

Wildfire is a continuing natural event that cannot be predicted. Past fires in the project area have 

included the Fantail, Magpie, and Mikes Creek fires, among others. All of these fires have 

occurred in the Badlands setting. The fires burned through areas of mixed grasses, juniper 

woodlands, and green ash woody draws. The general effect of fire in juniper woodlands has been 

the replacement of juniper with herbaceous plants communities. Varying degrees of tree and 

shrub mortality have resulted from wildfires, but surviving plants exhibit increased basal 

sprouting. Burned areas in Fantail Creek have responded with an increase in both grasses and tall 

shrubs such as serviceberry and chokecherry, which in turn are providing shelter for sapling 

trees. Noxious weeds such as Canada thistle and hounds tongue often pioneer burned areas but 

are generally replaced by native species over the course of a few years. 

ELKHORN RANCHLANDS GRASSLANDS PLAN AMENDMENT

In 2007 the Forest Service and partners purchased an area known as the Eberts Ranch, which is 

now known as the Elkhorn Ranchlands. As a condition of purchase the Forest Service was 

required to sell an amount of NFS lands on the Medora Ranger District equal to the amount of 

land gained from the purchase. As a result of this condition, in 2008 NFS lands in Allotments 

144, 218, 224, 228, 229, 285, and pasture 4 in Allotment 127 were conveyed to private 

ownership. Lands gained in the purchase were, with three exceptions, outside of the project area. 

Section 27, T143N, R101W (640 acres), the southwest quarter of the northwest quarter of 

Section 27, T144N, R102W (3 acres), and the west half of the west half of Section 35, T144N, 

R101W (140 acres) are the three outlying parcels of the purchase that are located in the project 

area of this analysis. 

Portions of Allotments 128, 135, 158, 256, and 287 were associated with the above-mentioned 

sections when they were privately held. The purchased lands are still part of the federal 

allotments; all that has changed is the land owner. Because the purchased lands are not covered 
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by the current Grasslands Plan, it has to be amended to bring them under its management 

direction. When completed, the amendment will identify the final decision regarding how all the 

purchased lands are to be managed. In the interim, the 783 acres associated with the above-noted 

allotments will be managed for livestock grazing in accordance with the allotment within which 

they are located, and consistent with the adjoining Management Area 3.65.

OIL AND GAS

The Forest Service has received five applications for permit to drill (APDs) on NFS lands in the 

project area. The APDs seek to drill oil and gas wells. The well pads associated with each well 

would be approximately 4 to 5 acres in size, encompassing about 22 acres total. Two wells

would reuse all or a portion of existing reclaimed well pad sites and the remaining pads would 

involve new construction. Approximately 4,250 feet of roads would be built to access the well 

sites, of which 2,900 feet would be located on old reclaimed road sites. 

General short-term effects associated with oil and gas development include sight, sound, and 

smell associated with heavy construction equipment. Drilling an oil and gas well, on average,

takes about 2-1/2 weeks. Disturbed areas except for the well pad are reseeded to native grass 

species, but disturbances tend to facilitate the establishment of invasive grasses. After production 

is established well pads are generally reduced in size to what is necessary to produce the well;

this action reduces the average well pad by 0.5 to 1 acre. Well pads are visited several times a 

week by a maintenance truck or daily if crude oil and saltwater, stored on site, need to be trucked 

to refineries or saltwater disposal sites. 

Summary of Past, Present, and Reasonably Foreseeable Actions

Table 3.2 lists past, present, and reasonably foreseeable actions considered in the cumulative 

effects analysis. All actions do not apply to each resource. Only those actions with relevant 

impacts to a specific resource were analyzed and discussed in the following resource sections.
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Table 3.2 — Summary of past, present, and reasonably foreseeable future actions 

considered in the cumulative effects analysis

Actions

Occurrence of 

Actions: Past 

(P), Present (C), 

and Reasonably 

Foreseeable (RF)

Location Effects

Livestock 

grazing P, C, RF Throughout the project area

Livestock grazing coupled with the development of 

supporting range infrastructure has changed the 

natural pattern of disturbance in the project area. This 

has altered the mosaic of herbaceous structure to 

where the desired structure mosaic, described by the 

Grasslands Plan, is not being met. Some intermittent 

stream reaches are no longer at PFC because of the 

effects of trampling, trailing, and loafing on stream 

banks in addition to the removal of too much riparian 

forage by livestock. Green ash woody draws are 

affected by livestock actions similar to those 

associated with riparian areas. Slightly more than half 

of the green ash woody draws are rated as Healthy.

Modification of grazing systems to take advantage of 

non-native grass species can adversely affect the 

native component intermingled in these plant 

communities.

Oil and gas 

development P, C, RF Throughout project area

Construction of roads, well pads, pipelines, and 

production facilities has removed some forage 

production. The construction of all-season roads for 

oil and gas activities opened up country that was 

historically accessible only by foot, horseback, or 

weather-dependent two-track road systems. The 

improved road system provides access for livestock 

into formerly inaccessible or poor access areas. The 

improved road network serves as a vector for noxious 

weeds and invasive grasses. Oil and gas roads have 

also affected some riparian areas by concentrating 

overland runoff into ditches, which is transported to 

streams. Concentrated runoff can affect sediment 

transport into the stream, accelerate stream 

downcutting, lower water tables, and reduce riparian 

vegetation diversity. The increase in new roads also 

fragmented wildlife and botanical habitats.

Noxious weeds

treatment P, C, RF Throughout project area

The 2007 DPG Noxious Weed Management Project 

FEIS and ROD provide criteria for treatment of 

noxious weed infestations. Weeds have been treated in 

the past, and will continue to be treated under the 

Noxious Weed ROD; therefore, noxious weeds are 

anticipated to remain stable or decrease in abundance.
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Actions

Occurrence of 

Actions: Past 

(P), Present (C), 

and Reasonably 

Foreseeable (RF)

Location Effects

Farming P, C

Primarily Rolling 

Prairie portion of 

project area

Farming no longer occurs in the project area on NFS 

lands. Reclamation of broken (cultivated) lands in the 

project area has introduced non-native invasive grass 

species. These species are displacing native grasses, 

thus affecting wildlife habitat and complicating 

livestock management. Agricultural practices do occur 

on intermingled private lands within the project area,

which may affect resources on NFS lands.

Wildfire P, C, RF Throughout the 

project area

Wildfire is aggressively fought when it occurs. This 

has allowed woodlands and woody plant communities 

to expand but has also adversely affected those 

woodlands that need fire to help maintain the health of 

different woodland components. Native vegetation 

that evolved with fire no longer benefits from the 

nutrient flush and regenerative effects associated with 

fire. Control of wildfires has also facilitated the 

accumulation of plant litter that can assist the 

establishment of several invasive grass species.

General vegetative response to wildfire in the 

badlands has been an increase in grasses and shrubs in 

juniper-dominated woodlands and riparian areas. 

Wildfires are often detrimental to woody draws 

because of their season of occurrence and intensity, 

but beneficial effects can also occur through increased 

basal sprouting or regeneration of trees and shrubs.

Travel 

Management RF Project area

The travel management plan is expected to have 

minimal effect on grazing permit holders unless single 

use roads are blocked from access by the permittees. 

If access were to be blocked then additional two-track 

roads could be created as permittees seek to 

administer their permits.

Elkhorn Ranch 

Grasslands Plan 

Amendment

RF

Located within 

project area 

boundary

Management action implemented under the decision 

for this analysis for those portions of the purchase 

contained in allotments 128, 135, 158, 256, and 287 

may change under the forthcoming Grasslands Plan 

amendment.

Drought P, C ,RF Throughout the 

project area

Drought is a normal cyclic event that occurs in 

western North Dakota. Drought limits moisture, so all 

fauna and flora to one degree or another are affected. 

This analysis has adopted a modification of the 2007

NE McKenzie FEIS drought strategy as interim 

direction until the DPG-wide strategy is completed.
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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

This section provides an overview and summarizes by resource the existing condition and 

environmental effects resulting from the different alternatives. It also describes the methodology 

used in analyzing each resource. Topics discussed in this section include range, riparian, woody 

draws, herbaceous structure, seral stages, sharp-tailed grouse, economics, climate change, and 

water quality.

RANGE

Introduction

The Grasslands Plan provides direction for livestock grazing; however, this section and Chapter 

3 Part 2 discuss more than just livestock grazing. They also discuss range administration; 

therefore, from this point forward the topic will be referred to as simply, Range.

The project area has been grazed by domestic livestock since the late 1880s. Over the decades,

the land has been heavily impacted by a combination of farming sub-marginal lands, poor

grazing practices, and drought. The environmental and economic devastation of the 1930s led to 

federal action to assist people and communities in the Great Plains. Through several acts, the 

federal government repurchased land and relocated families. This effort to purchase lands was 

called the Land Utilization Program (LUP). As part of the LUP in western North Dakota, 

cooperative grazing associations were formed to integrate management of the purchased lands 

with private ranch and farm operations. The Medora Grazing Association (MGA) was formed in 

December 1937. 

In the 1970s and 1980s, allotment management plans (AMPs) were developed for the grazing 

allotments on the LMNG. An AMP guides the management of an allotment based on the 

management direction contained in the overarching land and resource management plan. Prior to 

the development of AMPs, the majority of the allotments within the Badlands and some of the 

Rolling Prairie were managed as commons. Individual members were allocated livestock use in a 

particular common from May 1 to December 31. The individual member then wintered the 

livestock, January 1 to April 30, on a headquarters allotment. The commons and their names 

were generally associated with a watershed, such as Ash Coulee, Blacktail, Whitetail, and 

Magpie; however, a few individual commons extended beyond the watershed, such as Ash 

Coulee and the Lower Thirty. During the development of AMPs, many of the commons were 

cross-fenced, creating new allotments that were allocated to a specific permittee for their sole 

grazing use. There are now six commons in the project area.

By the 1990s, because of the age of the existing AMPs and new technology and research, many 

of the permittees requested a deviation from the rotations set forth within their AMPs. Changes 

were agreed upon based on the approval of the MGA and the Forest Service through an Annual 

Operation Plan, later changed to Annual Operating Instructions (AOI). All association members 

are required to fill out an AOI prior to livestock turn out.
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Spatial and Temporal Setting

The analysis area for range analysis is the NFS lands contained in the 43 allotments in the project 

area (Figure 1.2). Once the analysis is completed and an alternative selected by the district 

ranger, then AMPs will be created. The AMPs will be written based on the management 

information contained in the FEIS under the selected alternative. Once completed, the AMPs will 

cover a 10- to 15-year timeframe. 

Methodology

Information used in the range analysis was gathered from the sources identified below. Also 

covered in this section is the methodology used to calculate initial estimated carrying capacity, 

which was used to set Authorized Use levels under Alternative 4. 

The allotment folders for each allotment were reviewed to obtain historical information, existing 

AMPs, pasture rotations, and reference points and their documentation. Information—such as 

livestock distribution mapping and general observation notes—was obtained from allotment 

inspections conducted during the growing seasons of 2004 through 2007. Also, data were 

obtained through a cooperative monitoring agreement between the Forest Service, MGA, and 

North Dakota State University (NDSU).

CARRYING CAPACITY ANALYSIS

1. What is it?

Carrying capacity is defined as the average number of livestock and/or wildlife that may be 

sustained on a management unit compatible with management objectives for the unit. In addition 

to site characteristics, it is a function of management goals and management intensity (Society 

for Range Management 2005). 

2. What is it used for?

The carrying capacity analysis was used to determine a starting point for authorization levels. 

More specifically, carrying capacity was analyzed to help determine what forage allocation to 

authorize for each allotment while considering the Grasslands Plan goals and objectives and 

identified issues for each allotment in Alternative 4. An estimated livestock carrying capacity for 

the allotment is also one of the items described as a minimum to be included in an AMP 

(Grazing Agreement and Rules of Management between MGA and USDA FS, 2009–2/28/2019).

3. How was it calculated?

The following methodology was used to calculate the initial estimated carrying capacities within 

the project area. Soil survey data from Billings and Golden Valley Counties were downloaded 

from the NRCS Soil Data Mart website in 2005 (http://soildatamart.nrcs.usda.gov/). Dry-weight 

production values for each ecological site within Major Land Resource Areas (MLRA) 54 and 

58C were populated using data obtained from the NRCS State Rangeland Conservationist (Jeff
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Printz, personnel communication, 2007, 2009). Pivot tables in Microsoft Excel were then used to 

combine tables to display the map unit symbol and name, percentage of map unit, component 

name, ecological site, and production data. Forage production values for each mapping unit 

within the soil survey were calculated using a weighted average of the listed ecological sites 

within the mapping unit. This weighted average figure was based upon the ecological site 

reference plant community production, the representative value (RV), for each ecological site 

within the soil mapping unit (all soil series were weighted for 100 percent). Assumptions 

associated with the RV are based on normal growing conditions and reference plant community. 

In very general terms, the assumption of “normal” growing conditions could either under or over 

estimate production depending upon the given climatic conditions for the year. The assumption 

of the reference plant community could also under or over estimate production depending on the 

existing plant community on the ecological site. 

The above information was migrated into an attribute table in a GIS soils layer. Within ArcView 

(ArcView GIS 3.3, 2002), a coverage was created that intersected the analysis area by 

allotment/pasture, land ownership, potential vegetation, and soils. The attribute information was 

then updated to include calculations for total forage production by polygon. This was calculated 

by multiplying the weighted production by the number of acres for a given map unit polygon. 

Initial estimated carrying capacity was calculated by multiplying the total production for a given 

polygon by 0.25 (harvest efficiency) and then dividing by 913 (the number of pounds of forage, 

air dried, to maintain a 1000 pound cow with or without calf for one month). An assumption 

made in this calculation is seasonlong grazing, which could weight the formula towards a lighter 

carrying capacity. Data were then summarized into individual allotments/pastures by land 

ownership to provide an initial estimated carrying capacity (Project Record, Supporting 

Documentation, Range). 

Through discussions and reviews, some discrepancies of previous calculations of carrying 

capacity have been discovered. In the 1960s and 1970s, carrying capacity was figured by using 

50 percent of the total estimated forage production based on the assumption of take half/leave 

half (Forest Service Winter Range Meeting, 2009). No harvest efficiency factor was applied in 

the calculation. Harvest efficiency factors have varied through the years. In the past, 35 percent 

was used in the calculation of carrying capacity by North Dakota NRCS offices. Based on 

discussions with adjacent states, and to be consistent with those offices, North Dakota NRCS 

offices now use the 25 percent harvest efficiency factor (Jeff Printz, personal communication,

2008). This factor is also the recommended harvest efficiency number identified for rangeland in 

the 1997 NRCS National Range and Pasture Handbook. Another value in the carrying capacity 

calculation that was used in the past was 790 pounds instead of 913 (the amount of pounds of 

forage required to maintain a 1,000 pound cow with or without calf for 1 month). The previous 

value of 790 was an oven-dried forage value. The current value of 913 pounds (air dried) is used 

to be consistent with the production values reported in the NRCS ecological site descriptions, 

which are also air-dried values.

The carrying capacity equation expressed in AUMs is: (area in acres)(herbage production per 

acre)(0.25) / 913 pounds/AUM. Applying the equation to a hypothetical 100 acre pasture that 
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produces an average of 1,400 pounds of herbaceous forage per acre gives us: 100 acres x 1400 

pounds/acre = 140,000 pounds x 0 .25 = 35,000 pounds / 913 pounds/AUM = 38.3 AUMs.

4. Do others use it?

Carrying capacity calculation is a standard equation taught in range management textbooks such 

as Range Management Principles and Practices (Holechek, et al. 1989). It is also described in 

the NRCS’s Range and Pasture Handbook (1997) under calculating stocking rates. 

5. Peer review

To help assure that the carrying capacity analysis was calculated correctly, the Medora Ranger 

District range staff had the analysis, methodology, and calculations were reviewed by the 

USDA’s Agricultural Research Service (ARS). The ARS confirmed that the process used was 

correct (Project Record, Inter & Intra-agency Memos, Conversations and Agreements, I-7).

6. What other methodologies are out there, are they similar or not? Why didn’t we use 

them? Why was it reasonable to use the method we did?

NRCS methodologies—As described in the NRCS Range and Pasture Handbook (1997),

determining the grazing capacity of an area can be complex. Rates of stocking vary over time 

depending upon season of use, climate variations, site, and previous and current management 

goals. A safe starting point for stocking rates would be determined initially. Then adjustments 

throughout the year based on the current on-the-ground conditions would occur. Also, 

adjustments based on attainment of management goals should be considered. The handbook 

describes four methods for establishing initial stocking rates as follows: (1) based on trend, 

health, and utilization; (2) based on production data and growth curves; (3) based on the usable 

production method or the forage preference method; and (4) forage value rating method.

However, it should be noted that the NRCS does not set stocking rates; they make 

recommendations to private land owners based on the operators goals and objectives.

In the NRCS’s Prescribed Grazing conservation practice description (Conservation Practice 

Specification – 528 Appendix C) it further says that, “without the benefit of field collected 

production data, use Table 1 to establish an initial estimated stocking rate for each 

ecological/range site.” This table utilizes a conservative methodology since only half of the RV 

production value is incorporated into the equation as is footnoted under the above-referenced 

Table 1. The Forest Service’s analysis utilized the whole, updated RV production values for each 

ecological site in the analysis. Since Alternatives 3, 3A, and 4 are written adaptively, monitoring 

will show whether the initial actions proposed are aiding the allotment in meeting or moving 

towards Grasslands Plan goals and objectives, or whether further actions need to be taken in the 

management of the allotment.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

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a. SRT recommendations

The SRT recommended (Recommendation I-1, page 3, October 2006) the use of NRCS Order 2 

soil surveys for Billings and Golden Valley counties along with the associated ecological site 

information in the development, implementation, monitoring, and refinement of pasture or 

allotment-level management plans. The SRT also recommended that herbage production be 

estimated for all sites through the use of ecological sites associated with the soil survey maps. 

(Recommendation I-2, page 4, October 2006). These recommendations were used in the analysis 

as noted above. 

b. MGA suggestion

The MGA suggested that the Forest Service did not follow the preferred protocol of clipping and 

weighing key areas of the land base in order to assign carrying capacity, but did not express 

which protocol they preferred (Response to DEIS Comments, Comment K-64). However, the 

production information provided by the NRCS ecological site descriptions is based on various 

clipping information and personal experience from a wide range of personnel from the field of 

range management. The NRCS ecological site description production information was applied to 

a standard carrying capacity equation (noted above) that has been used for years and is taught in 

standard range management textbooks. This is not a theoretical exercise, as valid production 

information and a standard equation for calculating carrying capacity were used to determine a 

starting point for Authorized Use in Alternative 4 given the identified issues for an allotment. 

Production information that was collected through a cooperative monitoring effort and is sitespecific to the project area has been analyzed to determine if fine tuning of the carrying capacity 

analysis is necessary. A detailed discussion of this information is contained in the following 

Cooperative Monitoring Data section. Ultimately, monitoring of how each allotment is meeting 

Grasslands Plan goals and objectives will indicate whether or not additional management is 

necessary on an allotment.

After the completion of the DEIS, new production information was released by the NRCS soil 

survey. This new information updated the NRCS soil survey vegetation production information 

used in this analysis. This new information affected the carrying capacity analysis, which was reanalyzed using the new information. This resulted in changes in Authorized Use for about half of 

the allotments contained in the project. Tables and discussion have been updated in the SDEIS to 

show the results of the new information, and now this FEIS which to date are based on the best 

available information.

COOPERATIVE MONITORING DATA

In 2007, a cooperative monitoring effort between the MGA, North Dakota State University 

(NDSU), and the Forest Service was initiated, and data collection began in 2008. This 

cooperative effort includes gathering species composition, forage production, VOR, and the 17 

Indicators of Rangeland Health in upland sites; and species composition, forage production, 

VOR, and tree/shrub data in green ash woody draw sites. Under this effort, NDSU is collecting
FEIS Vol. I North Billings County Allotment Management Plan Revisions

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data representing each individual allotment beginning in northern Billings County, and 

eventually throughout the MGA. 

Monitoring data for 2008 and 2009 have recently been provided to the Forest Service. During 

these years data were collected in 34 of the allotments in this project. Data collection for the nine 

remaining allotments in the project will continue in 2010; however, it will not be available before 

this analysis is completed. Methodologies for this data collection effort have been supplied by 

NDSU and are included in the Supporting Documentation – Range section of the Project Record. 

The new data were reviewed by the IDT and are addressed in the analysis under the appropriate 

resource sections. 

Through this monitoring effort, biomass information was collected on upland plots in 32 of the 

allotments in the project area. The Forest Service range staff reviewed the biomass information 

to determine how it compared to that supplied by the NRCS in the ecological site descriptions. 

The biomass information is important in determining initial estimated carrying capacity.

Following is a summary of the detailed analysis information included in the Supporting 

Documentation – Range section of the Project Record.

To date, NDSU has collected raw biomass data on 115 upland sites. This represents 34 percent of 

the total upland sites (337 upland plots) that NDSU identified as necessary to represent the 

allotments within the project area. Of the 115 plots, 18 were dropped from the analysis because 

of missing biomass data or missing species information, because the species didn’t match the 

summary sheet, or because there were two different dates for a plot. The remaining 97 plots (29

percent of the total upland plots) contained a total of 644 clipped frames. Of the 644 frames, 378 

were in MLRA 54 – Rolling Soft Shale Plain, commonly referred to as Rolling Prairie; and 266 

frames were in MLRA 58C – Northern Rolling High Plains, commonly referred to as Badlands. 

MLRAs are broad geographic areas that are characterized by a particular pattern of soils, climate, 

water resources, vegetation, and land use (National Range and Pasture Handbook 1997). Each 

MLRA in which rangeland and forest land occur is further broken into ecological sites. An 

ecological site is a distinctive kind of land with specific physical characteristics that differs from 

other kinds of land in its ability to produce a distinctive kind and amount of vegetation (National 

Range and Pasture Handbook 1997). 

MLRA 58C makes up the majority (69 percent) of the project area. Currently, much of this 

MLRA in the project area has not been assigned an ecological site by the NRCS. However, for 

those areas in MLRA 58C that are classified in the project area, the dominant ecological sites by 

acreage are Thin Loamy and Loamy. The 2008 and 2009 data (42 plots) shows the two most 

sampled ecological sites to be Claypan and Thin Claypan. Because of the limited amount of 

samples taken from Thin Loamy and Loamy ecological sites to date, the data set is not 

representative of MLRA 58C located in the project area. Therefore, the current production 

information from this sample set is not representative of the dominant ecological sites in the 

project area and therefore was not used in the analysis of carrying capacity. 

According to the NRCS Soil Survey, by acreage MLRA 54 is dominated by Loamy and Claypan 

ecological sites in the project area. The 2008 and 2009 data (52 plots) shows that most of the 
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sampled plots occurred on the two dominant ecological sites. Overall, however, the data set is 

not currently complete enough to be representative of MLRA 54 and therefore was not used in 

the analysis of carrying capacity.

The primary concern at this point is that neither MLRA 54 nor 58C has a sufficient number of 

sampled plots needed to represent the project area. Plots sampled to date by ecological site are 

identified in Table 3.3. However, the monitoring project is continuing to collect plot information. 

As that information becomes available, it will be reviewed to determine if production 

information for the project area varies significantly from that provided by the NRCS soil survey.

Table 3.3 — Sampled plots in MLRA 54 and 58C

Ecological Sites

Loamy Claypan Sandy Clayey Thin

Claypan

Thin

Loamy

Shallow

Clayey

Shallow

Loamy

# of 

sampled 

plots in 

MLRA 54

20 11 6 6 4 3 1 1

# of 

sampled 

plots in 

MLRA 58C

8 12 3 5 9 5 NA NA

Although there are not currently enough sample plots to be representative of the project area, 

there are a sufficient number of samples to be representative of the following individual 

allotments: 132H, 221, 239, and 248. However, for allotments 132H and 221, the sample plots 

were not taken on the dominant ecological sites for these allotments, which means that 

production information would not be representative of the allotments. Allotment 239 has sample 

plots that represent only one of the two dominant ecological sites. The set for the second 

ecological site had a labeling discrepancy; therefore, this allotment is not fully represented either.

The sampling in Allotment 248 was consistent with the dominant ecological sites identified by 

the NRCS Soil Survey. On Claypan ecological sites, sample plots indicated that biomass 

production would contribute 0.06 AUM/acre more than the reference value, and on the Loamy 

ecological site the sample plot indicated that biomass production would contribute 0.24 

AUM/acre more than the reference value.

For Allotment 248 this is somewhat of a moot point as there are no reductions in Authorized Use 

proposed under any of the alternatives. Once all of the sample plots for the project area have 

been completed, a review of the data set would be conducted. If significant differences were 

found between the NRCS RV production value and the biomass data set, additional calculations 

of the carrying capacity analysis would occur incorporating the biomass data set into the 
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92 | Chapter 3

analysis. If adjustments in Authorized Use are necessary based on the carrying capacity analysis, 

they will still be driven by the need to work towards Grasslands Plan goals and objectives.

A detailed description of the Forest Service review of the 2008/2009 cooperative monitoring data 

is located in the Supporting Documentation – Range section of the Project Record.

LIVESTOCK WEIGHT ADJUSTMENT

One of the SRT recommendations (V-2) was to “Redefine the Animal Unit to reflect current cow 

size along with older, larger calves and recalculate the corresponding authorized livestock 

numbers on allotment.”

A discussion of cow size was held at the January 2007 MGA board meeting to address the SRT 

recommendation. Range staff from the Medora District reviewed how other Forest Service 

districts were addressing this issue; provided information from the Dickinson Research and 

Extension Center’s Cow Herd Appraisal Performance Software (CHAPS) program, which 

contains cow weights by area; and shared how this would be treated as a tool in the grazing 

management toolbox. Upon being asked what the MGA Board of Directors felt was the average 

cow size in their grazing association, a range of 1,100 to 1,300 pounds, with the median being 

1,200 pounds, was provided (Project Record, Correspondence Permittee). Appendix C of the 

Grasslands Plan provides three different calculations to address cow size in determining animal 

unit equivalents (AUE). After discussion of the different methods of calculation, the MGA Board 

of Directors chose method number 3, a metabolic weight formula, utilizing the 1,200-pound 

average size of a cow. The animal unit equivalency factor would equate to 1.15 AUEs as the 

median within the above stated weight range.

Because current Authorized Use is expressed in terms of animal months (AMs), a conversion 

factor was needed to convert AMs to AUMs so the alternatives could be compared in like units. 

This was accomplished by multiplying the number of authorized AMs by 1.15 AUEs to 

determine AUMs. This conversion assumes that all of the AMs are cow/calf units with an 

average weight of 1,200 pounds. This may result in an overestimation or underestimation of 

AUMs depending on what is actually being run and the true weight of the livestock, which can 

run on average as high as 1,600 pounds for cattle in western North Dakota.
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Affected Environment—Range

EXISTING CONDITION

This section provides a general description of range-related information for the project area. A 

detailed description of the existing condition of each allotment is provided in Chapter 3 Part 2.

Grazing Permits

The MGA currently holds a permit from the Forest Service through a grazing agreement, which 

includes grazing within the project area. Currently there are 29,125 federal AMs allocated to the 

43 grazing allotments covering approximately 87,262 acres of NFS lands (2006 MGA grazing 

permits). These AMs are permitted to the MGA, who in turn distributes them to grazing 

association members through issuance of annual grazing association grazing permits. 

As noted above, the Forest Service issues a grazing permit to the MGA, who serves as the Forest 

Service’s agent. Therefore, the MGA is a permittee of the Forest Service. The MGA in turn 

issues permits to its individual members. Technically these individuals would be MGA 

permittees. When referring to permittees in this document we are generally referring to the MGA

permittees, unless specified otherwise.

There are several different types of grazing association grazing permits issued by the MGA to its 

members. The most common are inventory, turn-in, private allocation inventory, and private 

allocation turn-in.

An inventory permit normally has 8 months of summer grazing (May 1 to December 31), and 2

months of winter grazing and 2 months of winter feeding within the time period of January 1 to 

April 30. Under this type of permit, livestock are located within the allotment 12 months out of 

the year. Typically there are intermingled land ownerships, and wintering on NFS lands may 

occur. If adjustments are made due to resource conditions, normally those adjustments are taken 

in the number of livestock grazing. With such a permit management decisions can be difficult to 

make, since the livestock are on the allotment 12 months out of the year.

A turn-in permit’s grazing season can be no longer than 8 months (May 1 to December 31), has 

no wintering on NFS lands, and the allotment typically consists solely of NFS lands, meaning 

that adjacent private lands are normally fenced out. Private and/or state lands may be included 

within the allotment if they are not conducive to fencing out or the permittee chooses not to 

fence them out. Turn-in permits allow for a certain number of AMs, which provides for some 

flexibility in management, such as an increased number of livestock for a shorter grazing season.

The term private allocation is normally added to the permit to identify that, at one point in time,

this allotment was part of a larger common, and that now that member has been allocated a 

portion of the common and is no longer part of the common. Several of the allotments within the 

North Billings County AMP Revision project area have the term “private allocation” included on

the permit.
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The annual grazing association grazing permit provides a Preference number, which is the 

maximum number of livestock for a given amount of time allocated to that allotment. In Forest 

Service terminology, this would be the Permitted Use for the allotment. The permit also lists the 

kind and class of livestock, the number of livestock, and the dates on and off of the allotment 

applied and approved for the grazing season. In Forest Service terminology, this would be the

Authorized Use for the allotment. Typically, the number of livestock authorized on an annual 

basis is equal to or less than the Preference number. 

Actual Use

Actual use describes the number of livestock, the grazing season (turn on, turn off dates), and 

rotation that a permittee actually grazed on an allotment in the past grazing season. The MGA 

has stated that actual use is provided in the grazing association grazing permits and 

AOIs/Allotment Worksheets. The AOIs/Allotment Worksheets are rotation plans developed by 

the individual permittees in January through March as a tentative plan for the upcoming grazing 

season, and are recognized as needing updates as the season progresses. The Forest Service is 

provided some updates to the AOIs/Allotment Worksheets in a very timely matter by some 

permittees, but not in all cases.

Between the DEIS and SDEIS, the Forest Service conducted a review of MGA files for actual 

use information. The review found the same AOI and permit information that was supplied by 

MGA and some additional information documenting changes to some of the AOIs. The review 

noted a general lack of documentation updating the AOIs as the grazing season progressed. 

There was no evidence that the grazing association requests actual use from their members at the 

end of the grazing season. 

It is possible to collect actual use data for the allotments in this EIS; however, that would take 3 

to 5 additional years during which time existing adverse resource impacts would not be 

addressed. To address this concern, mechanisms are currently in place that will require the MGA 

to provide actual use for the 2010 season and annually thereafter. A letter has been sent to the 

MGA detailing, as per the MGA Grazing Agreement, the required actual use information, and 

the need to complete year-end reviews with each permittee to verify or amend the AOIs to reflect 

what actually occurred for the past grazing season (Project Record, Correspondence Permittee).

Information regarding actual use would aid in the analysis of past effects of grazing systems and 

whether or not those effects would continue, based on the alternatives. This is also described in 

the NRCS National Range and Pasture Handbook (1997) as part of the method to establish an 

initial estimated stocking rate for an operating unit. In addition, actual use would aid in 

disclosing the potential effects of the alternatives to the permittee by comparing actual use to 

Preference and/or the use authorized under the alternatives.

In lieu of actual use, the interdisciplinary team used the 3-year (2005 through 2007) average 

MGA permitted use and/or AOIs as was provided by the grazing association to compare to the 

Authorized Use under the different alternatives. The 3-year average MGA permitted use is 

information taken from grazing association grazing permits, which are completed prior to turn 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

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out. The AOIs/Allotment worksheets were used to help describe how an allotment is managed

under current management, as far as rotation and type/class of livestock. As noted before, the 

AOIs and the information they contain are completed in the winter or early spring by the 

permittee before turn-out. They represent the permittees “best guess” at that point in time as to 

the number of animals they’ll run, rotations, etc., in the coming grazing season. In lieu of actual 

use, this is the best information available to use in the analysis. 

This information will be used in the analysis to evaluate the effects of past grazing systems and 

whether or not trends would likely increase, decrease, or stay the same based on the alternatives 

and the comparison to the 3-year average MGA permitted use from the grazing association 

grazing permits, as well as Preference. It is important to note that 1 of the 3 years in the average 

was a drought year in which mandatory grazing reductions were implemented. This information 

is provided strictly for comparison purposes to more sharply define differences between the 

alternatives.

Tables 3.4 and 3.5 provide comparisons of the Authorized Use, by alternative, to Preference; and 

the Authorized Use, by alternative, to the 3-year (2005 through 2007) average MGA permitted 

use. The 3-year average MGA permitted use was converted to AUMs by converting the lines on 

the grazing association grazing permit by animal unit equivalency (AUE); i.e., all cows were 

assumed to weigh 1,200 pounds and therefore had an AUE of 1.15; yearlings had an AUE of 

0.75; horses had an AUE of 1.5; and, due to language in the grazing agreement about breeding 

bulls, bulls were factored at 1.0 AUEs. Preference, which is authorized under Alternatives 2, 3, 

and 3A, was converted to AUMs using the same conversion factor identified above. This 

assumes that all of the animal units are larger cows within the range of 1,100 to 1,300 pounds,

with an average of 1,200 pounds to get a conversion factor of 1.15. In some cases this will likely 

result in an over estimate, but this is done for comparison purposes. This assumption is correct 

for those allotments running only cow/calf operations, but results in a higher estimate for others 

that run different classes of livestock, such as yearlings. As actual stocking numbers and average 

livestock weight information was unavailable, the above assumptions were made to allow a 

comparison to be made between existing Authorized Use of Alternatives 2, 3, and 3A, which 

have the same Authorized Use, and Alternative 4. 
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Table 3.4 — Comparison of alternatives to 3-year average MGA summer permitted use

NOTE DISCLAIMERS ABOVE

Allotment

3-year 

Avg.

AUMs

Alt. 2, 3,

& 3A 

AUMs

% 

Difference

between 

Alt. 2,3, 

&3A and 

3-year 

Avg.

Alt. 4 

AUMs

% 

Difference

between 

Alt. 4 and 

3-year 

Avg.

126/128 2516 2708 8 2178 -13

127 440 474 8 345 -22

129 1032 1150 11 1000 -3

130 647 729 13 678 5

131 26 55 109 48 81

132A 163 202 24 202 24

132H 349 370 6 353 1

133 280 313 12 198 -29

133D5 Hayed 56 Hayed 35 Hayed

134 275 292 6 220 -20

135 1647 1793 9 1559 -5

136/139 385 416 8 285 -26

140 429* 323 -25 237 -45

141 178 204 14 113 -36

142 96 192 100 128 34

158 1673 1801 8 1527 -9

220 151 184 21 112 -26

221 254 283 11 174 -31

230 401 419 4 358 -11

237 234 331 41 250 7

239 258 288 12 176 -32

240 855 930 9 876 2

241 379 413 9 357 -6

243 397 431 9 347 -13

244 254 271 7 241 -5
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Chapter 3 | 97

Allotment

3-year 

Avg.

AUMs

Alt. 2, 3,

& 3A 

AUMs

% 

Difference

between 

Alt. 2,3, 

&3A and 

3-year 

Avg.

Alt. 4 

AUMs

% 

Difference

between 

Alt. 4 and 

3-year 

Avg.

248 277 359 30 359 30

249 234 235 0 194 -17

256 1588 1830 15 1678 6

258 1735 2382 37 1694 -2

272 1566 1694 8 1472 -6

277 1158 1298 12 1243 7

278 276 313 13 230 -17

281 289 339 18 270 -7

282 2133 2441 14 2123 0

283 193 345 79 340 76

286 184 320 74 236 29

287 661 666 1 577 -13

288 238 308 30 216 -9

289 1880 2057 9 1862 -1

300 501 559 12 524 5

301 1772 1916 8 1734 -2

302 1108 1201 8 1051 -5

Total** 29112 32835 13 27767 -5

*Because the percent federal listed on the permit does not reflect the management described for this allotment, it 

appears that more AUMs are being utilized than Federal Preference. It is a case of additional private land being 

included on the rotation described by the permittees that is not included on the grazing association permit.

**Total does not include Allotment 133D5, since this allotment is hayed, not grazed.

The above comparison indicates that Authorized Use under Alternative 2 and initial actions 

under Alternatives 3 and 3A would result in Authorized Use ranging from 1 to 109 percent above 

the 3-year average, with the exception of Allotment 140 (see above footnote). When compared to 

the 3-year average, Alternative 4 would result in a reduction in Authorized Use on 27 allotments 

ranging from 1 to 45 percent; 13 allotments would see an increase in AUMs; one allotment 

would remain unchanged; and one allotment would be hayed. 
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Table 3.5 provides a comparison of Authorized Use by Alternative to Preference. For 

comparison purposes Authorized Use under Alternatives 2, 3, and 3A and Preference have been 

converted to AUMs in the same manner as discussed above Table 3.4, When compared to 

Preference, Alternative 2 and the initial actions under Alternatives 3 and 3A show the range in 

percent reduction in Authorized Use is zero for all allotments. Alternative 4 shows that all 

allotments, except for two that were meeting Grasslands Plan objectives, would see Authorized 

Use reductions ranging from 1 to 44 percent, when compared to Preference. Excluding the two 

allotments for which no reductions are proposed, the average reduction for allotments that would 

see a change is approximately 20 percent.

Table 3.5 — Comparison of alternatives to Preference

Allotment Preference 

in AUMs

Alt. 2, 3,

& 3A 

AUMs

% 

Difference

between 

Alt. 2,3, 

&3A and 

Preference

Alt. 4 

AUMs

% 

Difference

between 

Alt. 4 and 

Preference

126/128 2708 2708 0 2178 -20

127 474 474 0 345 -27

129 1254 1254 0 1090 -13

130 958 958 0 891 -7

131 314 314 0 273 -13

132A 202 202 0 202 0

132H 382 382 0 364 -5

133 313 313 0 198 -37

133D5*

56 56 0 35 -38

134 292 292 0 220 -25

135 1793 1793 0 1559 -13

136/139 416 416 0 285 -32

140 323 323 0 237 -27

141 204 204 0 113 -44

142 192 192 0 128 -33

158 1801 1801 0 1527 -15

220 184 184 0 112 -39

221 283 283 0 174 -38

230 419 419 0 358 -14
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Allotment Preference 

in AUMs

Alt. 2, 3,

& 3A 

AUMs

% 

Difference

between 

Alt. 2,3, 

&3A and 

Preference

Alt. 4 

AUMs

% 

Difference

between 

Alt. 4 and 

Preference

237 331 331 0 250 -24

239 288 288 0 176 -39

240 930 930 0 876 -6

241 413 413 0 357 -14

243 431 431 0 347 -20

244 271 271 0 241 -11

248 359 359 0 359 0

249 235 235 0 194 -17

256 1830 1830 0 1678 -8

258 2382 2382 0 1694 -29

272 1694 1694 0 1472 -13

277 1298 1298 0 1243 -4

278 313 313 0 230 -26

281 339 339 0 270 -20

282 2441 2441 0 2123 -13

283 345 345 0 340 -1

286 320 320 0 236 -26

287 666 666 0 577 -13

288 308 308 0 216 -30

289 2057 2057 0 1862 -9

300 559 559 0 524 -6

301 1916 1916 0 1734 -9

302 1201 1201 0 1051 -12

Total 33437 33437 0 28305 -15

*Allotment 133D5 is an 80-acre allotment that is partially hayed on an annual basis and is not grazed;

therefore, it is not included in the totals.
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Infrastructure

Water developments within the project area include springs, artesian wells, wells powered by 

electricity or windmills, water pipeline and stock tank systems, dugouts, and reservoirs. 

Reservoirs and dugouts depend on measurable snow pack and overland runoff to fill their basins. 

Without this runoff many of these reservoirs and dugouts are dry, or the quality of the water is 

poor for livestock use. Due to age, lack of maintenance, location, and sedimentation, many of the 

reservoirs and dugouts are only 2 to 4 feet in depth. This is a more common situation in the 

Badlands than in the Rolling Prairie because of the Badlands’ erosive nature. With evaporation, 

many of these reservoirs and dugouts only hold water for a couple of months within a grazing 

season, thereby limiting season of use changes in pasture rotations.

The spring developments in the project area have generally been in place for long periods of 

time, which has affected their flow rate. Insufficient ground water recharge can also affect the 

spring flow rates. Many of the spring developments in the project area produce only enough 

water to supply a small number of livestock. Others have been poorly maintained and are in need 

of repair to continue to function properly. The spring developments in the project area are 

normally located within woody draws or within riparian areas. These are sensitive areas that, in 

some cases, have been adversely affected by livestock use.

Artesian wells and windmills also provide livestock water in the area. These water sources can 

be unreliable due to falling head pressures, fluctuation in aquifer levels (North Dakota State 

Water Commission 2007), or lack of wind. As a result, it can be difficult to balance a grazing 

rotation for proper use and timing. Indirectly, this can cause livestock to hang out along riparian 

areas within the project area.

Fences to divide allotments into pastures, for exclosures, and for hay yards are common 

rangeland infrastructures, as are corrals. Both are found throughout the allotments in this project 

area. Existing range developments for each allotment are identified on the allotment maps 

located in Appendix B. 

DESIRED CONDITION

The Desired Condition for range is to annually provide forage for livestock on suitable 

rangelands within the sustainable capability of the rangeland ecosystem (Grasslands Plan, p. 1-

5). The Demonstration Project also identifies a goal of maintaining or improving on-the-ground 

conditions to maintain, to the maximum extent possible, a grazing program at current levels and 

provide sufficient habitat for grassland species (Grasslands Plan ROD 2006, p. 16).
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Environmental Consequences—Range

DIRECT AND INDIRECT EFFECTS

Alternative 1 

This alternative would result in no livestock grazing of NFS lands 2 years after permittees were 

notified of the selection of this alternative. There would be a 100 percent reduction in the 

existing federal AMs allocated on the NFS lands in the project area, which in 2008 equated to 

29,125 AMs. No grazing fees would be collected and, therefore, there would be no Conservation 

Practices (CP) completed. Most of the existing range infrastructure—such as fences, wells, tanks, 

developed springs, etc.—would be removed and reclaimed in the project area. Some structures 

may be kept for other resource reasons; however, those decisions would be made through other 

NEPA analysis. If the infrastructure were to not be removed, a maintenance plan would need to 

be developed, thereby adding an additional expense to the Forest Service. 

There is a potential for the spread of noxious weeds associated with reclamation of removed 

range infrastructure. The Forest Service would become solely responsible for noxious weed 

control on the allotments. The spread of some noxious weeds species may decrease owing to the 

removal of livestock as one vector source. 

This alternative would affect private lands intermingled with NFS lands within allotments. If 

private land owners wanted to graze their private land, fencing out that land would be their 

responsibility. New water sources would also need to be constructed on private lands to offset 

sources lost on NFS lands. 

Permittees seeking to maintain their current herd sizes would need to replace forage from NFS 

lands with additional rented pasture, land purchase, or by switching to a more focused 

management system, such as a feed lot operation. Those not able to implement these options may 

reduce herds numbers, focus more on farming in combined ranching /farming operations, seek an 

additional source of income, or pursue a different career.

This alternative would not meet the desired condition for livestock grazing.

Alternative 2

This alternative maintains the current grazing management on each allotment. There are no 

changes in infrastructure, grazing rotations, Authorized Use levels, etc. Grazing distribution and 

use patterns would remain the same. As there are no additional management actions proposed, 

resource problems resulting from the intensity, timing, or duration of livestock use would be 

maintained. 

Noxious weeds would continue to be cooperatively managed by the Forest Service, MGA, and 

county weed boards. Livestock and the associated permit management would continue to be 

vectors for the spread of noxious weeds. Continuing to control noxious weeds would help 

maintain or increase the amount of native forage available to livestock and wildlife.
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Under this alternative, Authorized Use would be set at Preference (Table 3.6), which is 

expressed as AMs. A cow/calf pair under this alternative would continue to be treated as one 

AM, regardless of the weight of the cow or its forage requirements. The number of AMs 

authorized would be similar to the currently permitted 29,125 AMs based on conditions. 

Table 3.6 — Authorized Use under Alternative 2

Allot #

Authorized 

Use 

(AMs)

Allot #

Authorized 

Use 

(AMs)

126/128 2355 240 809

127 412 241 359

129 1090 243 375

130 833 244 236

131 273 248 312

132A 176 249 204

132H 332 256 1591

133 272 258 2071

133D5 (hay) 49 272 1473

134 254 277 1129

135 1559 278 272

136/139 362 281 295

140 281 282 2123

141 177 283 300

142 167 286 278

158 1566 287 579

220 160 288 268

221 246 289 1789

230 364 300 486

237 288 301 1666

239 250 302 1044

As existing numbers, rotations, etc., would be maintained, the existing grazing patterns would 

remain the same, which means that areas that are receiving too much use would continue to 

receive the same level of use. 
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Periods of drought would have a direct effect on the available forage for the project area. When 

reduced precipitation occurs during the growing season (April through July), it has a major 

impact on the production of forage (Heitschmidt et al. 1995). Less available forage results in the 

utilization level of 50 percent to be reached earlier in the grazing season. The end result is a 

decrease in the annual AMs authorized for that year. To extend the grazing season, the number of 

animals can be reduced, the class of livestock can be changed, or calves can be weaned early. 

Alternative 3

This alternative uses a variety of different management actions—both structural and nonstructural—to move impacted resources towards desired conditions. There are no initial 

reductions in Authorized Use under this alternative. Authorized Use is the same as that identified 

in Table 3.6 under Alternative 2.

Livestock distribution can be altered by changes in both range structural and non-structural 

improvements. Distribution would be altered in 18 allotments where new range infrastructure is 

proposed. Grazing rotation changes would affect distribution in 9 allotments. However, not all 

rotational changes would result in a change in livestock distribution; this is due to the influences 

of topography and pasture size, and is the case for 19 allotments. The effect of this alternative on 

noxious weeds is the same as Alternative 2.

Under this alternative, a total of 48 range developments estimated at a value of $597,750 would 

be constructed. In addition to initial construction costs there will be future maintenance costs 

associated with these structures. 

This is an adaptive-management-based alternative and if monitoring shows that additional 

management actions are needed, then adjustments in Authorized Use may be required. Adjusting 

Authorized Use downward would result in fewer livestock numbers, fewer grazing days, or a 

combination of the two for a turn-in permit. For an inventory permit, adjusting Authorized Use 

downward would result solely in fewer livestock numbers. Adjusting Authorized Use, regardless 

of the type of permit, would not change the distribution of the livestock; however, the amount of 

forage harvested would be less than the existing forage harvested.

Alternative 3A

The effects of this alternative are the same as Alternative 3, except for the number of proposed 

range developments and their associated costs, which are 58 and $646,826 respectively.

Alternative 4

This alternative uses a variety of different management actions, both structural and nonstructural, to move impacted resources towards desired conditions. Authorized Use is set based 

on initial estimated carrying capacity for those allotments where Preference is greater than the 

initial estimated carrying capacity. For the four allotments where this was not the case, 

Authorized Use was set by adjusting Preference for cow size. Two allotments, 132A and 248, are 
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authorized Preference since they are meeting resource objectives. Authorized Use for this 

alternative is identified in Table 3.7.

Livestock distribution can be altered by changes in both structural and non-structural range 

improvements. Distribution will be altered in 19 allotments where new range infrastructure is 

proposed. Grazing rotation changes will affect distribution in 10 allotments. However, not all 

rotational changes will result in a change in livestock distribution; this is due to the influences of 

topography and pasture size and is the case for 20 allotments. The effect of this alternative on 

noxious weeds is the same as Alternative 2.

Under this alternative, a total of 45 range developments estimated at a value of $486,375 would 

be constructed. In addition to initial construction costs there will be future maintenance costs 

associated with these structures.

This is an adaptive management based alternative and if monitoring shows that additional 

management actions are needed, then additional adjustments in Authorized Use may be required. 

Adjusting Authorized Use downward would result in fewer livestock numbers, fewer grazing 

days, or a combination of the two for a turn in permit. For an inventory permit, adjusting

Authorized Use downward would result solely in fewer livestock numbers. Adjusting Authorized 

Use, regardless of the type of permit, would not change the distribution of the livestock; 

however, the amount of forage harvested would be less than the existing forage harvested.

Table 3.7 — Authorized Use under Alternative 4

Allot #

Authorized 

Use 

(AUMs)

Allot #

Authorized 

Use 

(AUMs)

126/128 2178 240 876

127 345 241 357

129* 1090 243 347

130 891 244 241

131* 273 248** 312 AMs 

132A** 176 AMs 249 194

132H 364 256 1678

133 198 258 1694

133D5 (Hay) 35 272 1472

134 220 277 1243

135* 1559 278 230

136/139 285 281 270

140 237 282* 2123

141 113 283 340
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Allot #

Authorized 

Use 

(AUMs)

Allot #

Authorized 

Use 

(AUMs)

142 128 286 236

158 1527 287 577

220 112 288 216

221 174 289 1862

230 358 300 524

237 250 301 1734

239 176 302 1051

*Allotments with Authorized Use set by adjusting Preference for cow size.

**Allotments where Authorized Use is maintained at Preference.

CUMULATIVE EFFECTS

Cumulative effects result from the combination of effects resulting from past, present, and 

reasonably foreseeable actions plus the direct and indirect effects of the alternatives. A 

discussion of past and present actions, reasonably foreseeable actions, and a summary of the 

cumulative effects by alternative follows.

Past and Present Actions 

The following past and present actions have contributed to the existing range management.

Livestock grazing has occupied what is now the LMNG since the late 1880s. During the early 

decades, livestock stocking rates were dictated more by how many cattle a person had than by 

what the range was capable of supporting. This led to overgrazing, which helped precipitate the 

dust bowl era of the 1930s. The development and application of grazing systems and stocking 

guidelines has reversed many of the effects associated with overgrazing. Fortunately, the range 

has since recovered. 

Past oil and gas development has resulted in the creation of a year-round road system, 

particularly in the Magpie, Blacktail, and Whitetail Creek watersheds. The road system has made 

it easier to transport livestock into areas that formerly required livestock to be moved in on 

horseback. The roads have also provided improved access for livestock into areas that, due to the 

difficulty of access, had previously been considered less desirable. 

Noxious Weeds/Invasive Grasses, It is unknown when noxious weeds first appeared in the 

project area. In the past and today noxious weed management has been a cooperative effort 

between the counties, grazing associations, and the Forest Service. Noxious weeds displace 

native forage species and can/do affect available forage for livestock and wildlife. 

Wildfires have been actively suppressed on the LMNG and adjacent private and state lands for 

about a century. The result has been an increase in some tree communities, such as Rocky 
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Mountain juniper and ponderosa pine, and a reduction or loss of vigor in plant communities 

where fire plays a role in maintaining the health of those systems. Ponderosa pine does not occur 

in the project area, however, Rocky Mountain juniper does. The juniper has expanded into 

rangeland due to a lack of fire and is beginning to affect available forage. 

Drought is a recurring natural event in western North Dakota. When reduced precipitation occurs 

during the growing season (April through July), it has a major impact on the production of forage 

(Heitschmidt et al. 1995). Less available forage results in the utilization level of 50 percent to be 

reached earlier in the grazing season. The end result is a decrease in the annual AMs authorized 

for that year.

Reasonably Foreseeable Actions

Elkhorn Ranchlands. The recently purchased Elkhorn Ranchlands require that the Grasslands 

Plan be amended to establish management direction for the newly acquired lands. Approximately 

800 acres of the 5,200 acre Elkhorn purchase are directly associated with five of the allotments 

in the North Billings project area. Under the proposed amendment these lands would be managed 

in accordance with the adjacent management area, which is MA 3.65 Rangelands with Diverse 

Natural Appearing Landscapes. In the interim, as directed by 36 CFR 254.3(f)(2008), this 

portion of the purchase is being managed in accordance with the adjacent MA 3.65. If the 

proposed action is selected and implemented there would be no change from the current 

situation. 

The proposed Grasslands Plan amendment also includes establishing a special interest area (SIA) 

for the remaining 4,400 acres of the purchase, and approximately 17,160 acres contained in 

grazing allotments 279 and 280, which were associated with the Elkhorn Ranchlands when they 

were privately owned. If implemented, the SIA would establish a forage reserve on those acres. 

The reserve would provide a place where livestock could be moved in the event an allotment is 

burned out or if management actions, such as a prescribed fire or additional rest, were needed to 

help restore an allotment. 

Travel Management Plan. An environmental assessment (EA) for travel management on the 

LMNG was released for comment in 2010. The proposed action for this EA would close all 

single use oil and gas roads, unauthorized roads (i.e., two tracks), and an additional 18 miles of 

system roads in the project area. The travel management plan is expected to have minimal effects

on grazing permit holders unless single-use roads are blocked from access. If access should be 

blocked, then additional two-track roads could be created as permittees can travel cross county to 

administer their permits. Depending on the location of the new roads, this may lead to the spread 

or establishment of noxious weeds.

Oil and Gas Development. The Forest Service has received five applications for permit to drill 

(APDs) on NFS lands in the project area. The APDs seek to drill oil and gas wells. The well pads 

associated with each well would be approximately 4 to 5 acres in size encompassing about 22 

acres total. Two wells would reuse all or a portion of existing reclaimed well pad sites and the 

remaining pads would involve new construction. Approximately 4,250 feet of roads would be 
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built to access the well sites, of which 2,900 feet would be located on old reclaimed road sites. 

The wells are located in Allotments 127, 135, and 287. These sites would affect fewer than 2 

AUMs of forage in Allotment 127, 4 AUMs in Allotment 135, and 3 AUMs in Allotment 287 for

the life of the oil and gas wells and roads.

Cumulative Effects by Alternative 

This section summarizes direct and indirect effects of the alternatives and the effects of 

reasonably foreseeable actions on range. These effects in combination with past and present 

effects combine to create cumulative effects.

Alternative 1 would result in the removal of livestock and all or most of the range infrastructure, 

the removal of a noxious weed vector, possible spread of noxious weeds associated with 

reclamation activities, potential development of new water sources and fences on private 

property, and the locating of new forage to replace that lost on NFS lands. Oil and gas 

development and the LMNG Travel Management analysis would not have any additive effects 

under this alternative, as they do not affect Authorized Use. The Elkhorn Ranchlands Grasslands 

Plan amendment may offer forage for a limited amount of livestock for a temporary time, but 

would offer no long-term opportunity for the permittees in the project area. 

Alternative 2 maintains the existing Authorized Use levels, rotations, noxious weed control 

actions, etc. The distribution of livestock would remain unchanged. Oil and gas development 

would result in the temporary loss of about 22 acres associated with the oil and gas well pads, 

and roughly 5.5 acres associated with the access roads. The temporary loss of forage associated 

with oil and gas development would not result in an adjustment in Authorized Use for the 

affected allotments. The Elkhorn amendment would offer alternate forage opportunities if 

wildfire or proposed management actions resulted in a temporary loss of forage. 

Alternative 3 and 3A, initial actions utilize an array of structural and non-structural actions to 

address improving resource concerns. These would change livestock distribution in some 

allotments, but not all, as topography and pasture size also affect cattle distribution. Authorized 

Use would initially remain at Preference. The additive effects of reasonably foreseeable actions 

are the same as those identified under Alternative 2.

Alternative 4, initial actions utilize a combination of structural and non-structural actions plus set 

Authorized Use at the initial estimated carrying capacity or at Preference adjusted for livestock 

size, depending on the allotment. Livestock distribution would be affected in some allotments 

and not in others for the same reasons identified under Alternatives 3 and 3A above. An 

adjustment in Authorized Use would not affect how livestock are distributed. The additive 

effects of oil and gas exploration and the Elkhorn Plan amendment are the same as in Alternative 

2. 

Adaptive Management. Alternatives 3, 3A, and 4 are all adaptive-management-based 

alternatives. If monitoring shows that initial actions are not making acceptable progress towards 

desired conditions, management adjustments would be needed. Determining the cumulative 

effects of an array of different adaptive management actions on Authorized Use, livestock 
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distribution, and costs is not possible at this point because the application of the different 

management tools would be allotment specific.

Consistency with Grasslands Plan—Range

The following are the primary range-related standards and guidelines associated with this 

project. For a complete listing see the Grasslands Plan Standard and Guide Consistency Table 

located in the Supporting Documentation – Grasslands Plan Documents and Misc. section of the 

Project Record.

Modify livestock grazing practices as needed to reduce adverse impacts of drought to food and 

cover for prairie grouse and other wildlife. Guideline

This guideline would be addressed under Alternatives 3, 3A, and 4 through the interim drought 

strategy identified in Chapter 2 of this FEIS. Alternative 1 would remove grazing, so no 

modification of grazing practices would be needed. Alternative 2 does not encompass a formal

drought strategy. However, drought is informally addressed through adjustments in timing, 

number of livestock, or a combination thereof when drought conditions exist.

Manage livestock grazing to maintain or improve riparian/woody draw areas. Implement the 

following practices. 

 Avoid grazing activities, such as feeding, which concentrate livestock in riparian/woody 

draw areas.

 Control the timing, duration, and intensity of grazing in riparian areas to promote 

establishment and development of riparian species. Guideline

Alternative 1 would remove livestock grazing, so this guideline is not applicable. Under 

Alternative 2, areas affected by livestock concentrations would continue except in those 

situations where the Forest Service becomes aware of adverse impacts associated with livestock 

concentrations in riparian and woody draw areas. Alternatives 3, 3A, and 4 address the 

guideline to differing degrees. Actions such as moving stock water, creating riparian pastures

and riparian exclosures, moving supplements, etc., would avoid concentrating livestock in 

riparian/woody draws and promote establishment and development of riparian species. Field 

reviews and AOIs would continue to address the issue where found. 

Meet rest objectives based on, but not limited to, the following desired conditions: 

 Where high structure is required for plant and animal communities and reproductive 

success for Management Indicator Species (see Geographic Area direction).

 Where increased fuel loads are desired for prescribed burning.

 Where ungrazed areas are desired for monitoring vegetation structure or for research 

needs. Where ungrazed areas are desired for biological diversity. Guideline

Alternative 1 would exceed the rest objective. The rest objective of 5 percent would be met 

through grazing rotations under Alternatives 2, 3, 3A, and 4.
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When allotment management plans are revised, adjust stocking levels to account for the 

variations in liveweight of livestock if needed to meet desired vegetative conditions (see 

Appendix C). Guideline

This guideline does not apply to Alternative 1 because all livestock would be removed under that 

alternative. Alternative 2 would maintain the existing condition, which does not adjust for 

livestock weight; therefore, this guideline would not be implemented under this alternative. 

Alternatives 3 and 3A under initial actions would not address livestock weight. If monitoring 

indicated that adjustments for livestock weight were needed, this would be accomplished as an 

adaptive action. Alternative 4 would account for livestock weight in the determination of the 

Authorized Use. If monitoring indicated that additional adjustments for livestock weight were

needed, this would be accomplished as an adaptive action.

Prioritize and remove fences or water developments that are not contributing to achievement of 

desired conditions. Guideline

Alternative 1 would remove many of the existing fences because, with the cessation of livestock 

grazing, they would no longer be needed. Alternative 2 would maintain the current system of 

fencing. Alternatives 3, 3A, and 4 propose, to differing degrees, the removal of fences or water 

developments see Chapter 3 Part 2 for additional detail. 

Manage grazing units that are composed of at least 70% crested wheatgrass (Agropyron 

cristatum) as crested wheatgrass units. Manage other pastures not meeting this definition as 

native grass units. Guideline

Alternative 1 would remove livestock grazing, therefore this guideline would not apply. Under 

Alternative 2 some, but not all, of the crested wheatgrass pastures would be managed as such,

providing deferment to native pastures. Under Alternatives 3, 3A, and 4, crested wheatgrass 

pastures, to the extent possible, would be managed as early season pastures to defer use on 

native pastures as identified in the design criteria located in Chapter 2.

Design and implement range management strategies for meeting desired vegetation objectives 

using existing monitoring information and stocking rate guidelines for livestock grazing (see 

Appendix I). Guideline

Alternative 1 would remove livestock from the landscape, so this guideline is not applicable. 

Alternative 2 would not incorporate any changes to livestock grazing to meet desired vegetation 

objectives. The analysis (existing monitoring information) shows a need to change some range 

management practices in order to trend towards desired condition. Alternatives 3 and 3A would

apply a variety of different range management strategies to address vegetation objectives. These 

alternatives would not initially modify Authorized Use; however, Authorized Use may be 

adjusted if monitoring indicates the initial actions do not trend the allotment towards desired 

conditions using the process described below, or other available methods. Alternative 4 would 
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also apply a variety of range management strategies to trend towards desired vegetation 

objectives and would use the process described below to adjust Authorized Use.

The analysis followed SRT recommendations utilizing a standardized methodology in place of 

Appendix I to set Authorized Use. This approach was taken because the SRT reported that 

erroneous assumptions were made in estimating livestock carrying capacities by equating 

grazing/harvest efficiency to high, medium, and low structure without considering the production 

potential of the ecological site (Report of the Scientific Review Team, May 2005, p. 20). The SRT 

also recommended Order 2 soil surveys in estimating livestock carrying capacities. Due to the 

two SRT recommendations, the Forest Service decided to estimate livestock carrying capacities 

by using available NRCS Order 2 soil surveys and a standard carrying capacity formula in order 

to establish Authorized Use under Alternative 4 to meet or move towards vegetation objectives. 

This is in addition to the variety of different range management strategies (Chapter3 Part 2) 

initially identified to help address meeting desired vegetation objectives.

Allow haying only where noxious weeds are not present or are pre-treated to prevent seed set 

unless haying is needed as a method of noxious weed control. If used as such a control, ensure 

proper disposal of hay. Guideline

One allotment, 133D5, is hayed. There are currently no identified noxious weeds associated with 

this allotment.

Allow haying and mowing only when grazing or prescribed fires are not viable methods to 

accomplish desired objectives. Guideline

Haying is allowed in Allotment 133D5 because there is no available livestock water source.

Control the timing, duration, and intensity of grazing on grass-dominated ridge tops and valley 

bottoms to prevent overuse and to promote the desired structure and species composition. 

Guideline

Since Alternative 1 removes livestock grazing altogether, overuse would be prevented. In the 

short term, this guideline would be met; however, in the long term desired structure and species 

composition objectives would not be met. Alternative 2 would not meet this guideline because it 

would maintain the current conditions, which do not meet Grasslands Plan structure and species 

compositions objectives and guidelines. Alternatives 3 and 3A would utilize a variety of different 

initial management actions, such as change in season of use, grazing rotation changes, fencing, 

and water development, to address this guideline. Alternative 4 is similar to Alternative 3 and 3A 

except that it would establish Authorized Use at carrying capacity, which may affect the intensity 

of use. 

Use livestock grazing strategies that maintain or improve the vegetative composition and 

structure associated with the scenic qualities of the area. Guideline
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This guideline is associated MA 4.22 “River and Travel Corridor.” Approximately 1,030 acres 

of this MA is associated with the Little Missouri River in the project area. A field review of the 

riparian vegetation did not reveal any vegetative composition or structure concerns.

Design grazing practices to provide landscape diversity for plant composition and structure. 

Guideline

Alternative 1 would remove livestock grazing which in the short term would move towards 

landscape diversity of plant composition and structure. However, in the long term it is expected 

that landscape diversity for plant composition and structure would decrease with livestock 

grazing removal. Currently, the desired mosaic of structure and composition is not being 

achieved under Alternative 2 management actions. Alternatives 3, 3A, and 4 are designed to 

provide diversity for plant composition and structure; however they differ in how quickly and in

the degree to which plant composition and structure would change. 

Initial actions under Alternatives 3 and 3A would shift the structure mosaic by moving some of 

the Low structure into Moderate structure. The initial actions would also improve the diversity of 

plant composition in some of the allotments. Alternative 4 would modify the structure mosaic by 

shifting more areas from low to moderate and moderate into high structure than Alternatives 3 

and 3A. In addition, Alternative 4 would improve the diversity of plant composition in more 

allotments than Alternatives 3 and 3A. Also, these alternatives include adaptive actions that 

would be applied if monitoring shows the initial actions are not meeting the objectives.

RIPARIAN

Introduction

Soil and water are among the most valuable natural resources. They sustain life, distribute 

nutrients, provide energy, and shape the landscape. In addition, water develops transportation 

corridors and provides diverse recreational opportunities. One of the primary reasons for the 

creation of the Forest Service was to protect soil and water resources. In the semiarid badlands of 

western North Dakota, water is especially important, as it is a limiting factor for wildlife and

livestock. Water also greatly influences distribution of livestock in NFS allotments.

Commonly, the first signs of ecosystem failures appear in riparian areas where wildlife and 

livestock concentrate. The creation and maintenance of properly functioning riparian areas is 

imperative in maintaining healthy watersheds which are critical for economic, ecological, and 

social reasons. 

Information provided in this section is taken from the Revision of Allotment Management Plans, 

North Billings County Watershed Report (SDEIS revision), which is located in the Project 

Record. 
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Spatial and Temporal Setting

The analysis area for the riparian issue is the same as the project area. This is a sufficient 

analysis area because riparian exclosure fences and allotment fences across streams in the project 

area demonstrate that pasture-specific management actions have localized effects on riparian 

functionality. For example, upstream reaches with impaired riparian areas can show complete 

recovery within tens of meters of entering an allotment with a properly managed riparian area 

(Figure 3.1). Conversely, upstream reaches that are properly functioning can change within tens 

of meters to nonfunctional upon entry into poorly managed riparian areas. The following streams 

and their associated riparian areas are the focus of the riparian analysis: Ash Coulee, Betsy 

Creek, Blacktail Creek, Fantail Creek, Green River, Magpie Creek, Mikes Creek, North Creek, 

Scairt Woman Draw, Spring Creek, and Whitetail Creek (see Figure 3.2). The temporal setting 

for the riparian analysis is 10 to 15 years.

Figure 3.1 shows the rapid transition from a reach of Magpie Creek with a riparian functionality 

rating of Functional-At Risk-Downward Trend (FAR-D) to the left (upstream) of the fence to 

one with a rating of Proper Functioning Condition (PFC) on the right (downstream) side of the 

fence. Note that upstream of the fence there is no riparian vegetation, and sediment-transport 

rates are high. In contrast, abundant riparian vegetation has trapped and ponded sediment-laden 

water within 10 meters of the fence. Beyond 10 meters, the riparian vegetation is dense, 

vigorous, diverse, and shows no evidence of excess sedimentation.
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Figure 3.1 — Fenceline contrast displaying rapid transition in riparian functionality rating.

Photo by Mark Gonzalez, July 2006.

Methodology 

The condition of riparian areas in the project area was assessed using the Proper Functioning 

Condition Protocol (Prichard et al. 1993, 1994, 1998, 1999 (revised 2003)); a copy of the 

protocol is located in the Supporting Documentation – Watershed section of the Project Record.

Results of earlier riparian surveys (1997-1998) were summarized by Kurt Hansen and others 

(USDA Forest Service 1998) and were used to indicate a trend in riparian conditions. PFC data

were collected by interdisciplinary teams, including that of Brooks (2005, p. ix), and Forest 

Service personnel in the summers of 2004, 2006, 2007, and 2008 (Project Record, Supporting 

Documentation – Watershed, L-26). The PFC data provided a context for determining if the 

ecological function of a particular stream reach has been improving, declining, or holding steady.

The Proper Functioning Condition Protocol is an interdisciplinary method to evaluate the 

existing condition of riparian areas, to examine the ecological functions of riparian areas, and to 

identify potential causes of riparian problems. Members of the IDT walk the entire length, or a 

representative set of reaches, of a riparian area and complete a checklist to determine the overall 

ecological function of the riparian area. Separate checklists are used to evaluate riparian areas 

that border lotic systems (those with running water, such as streams) and those that border lentic 

systems (areas where there is primarily standing water, such as ponds, fens, bogs, etc.). 

Individual riparian reach breaks are designated based on observable differences in landform, 

geology, geomorphology, fluvial processes, major soil and/or vegetation changes, and hydrologic 

changes (Prichard et al. 1998). The IDT assigns one of five possible functionality ratings to each 

riparian reach based on field observations, team discussions, and checklist data: Proper 

Functioning Condition (PFC); Functional-At Risk-Upward Trend (FAR-U), Functional-At Risk-
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Trend Not Apparent (FAR-NA); Functional-At Risk-Downward Trend (FAR-D); and 

Nonfunctional (NF). An explanation of ratings is provided in Table 3.8.

Table 3.8 — PFC functionality ratings and definitions 

PFC Stream is in balance with the landscape, erosion and deposition are not excessive,

vegetative cover indicates high soil-moisture (wetland) conditions and has high 

vigor, channel is sinuous with little or no bank erosion.

FAR-U May indicate past problems that are healing through better vegetative cover, 

decreased erosion, better sinuosity, and better soil-moisture retention.

FAR-NA Some deposition and erosion are occurring, vegetative vigor is moderate, some 

stream banks are drying, riparian elements are still in place for recovery without 

large inputs, and the functionality trend could go either way depending on 

disturbances.

FAR-D Plant communities are dominated by more upland species rather than wetland 

species, erosion is happening at large rates, channel is beginning to straighten with 

increased velocity from lack of stream bank cover, and floodplain storage is 

reduced.

NF Stream channel and banks characterized by little or no vegetative cover; stream 

channel is less defined, water not stored in banks due to lack of plant cover and 

continual erosion/deposition. Stream bank storage of high flows is short lived due to 

lack of plant cover to slow evaporation rates, channel has little sinuosity, upland 

plant species are present where they typically are not found, and large expenses 

required to bring back into a functioning condition.

Source: Modified from Prichard et al. 1998.

The PFC protocol has been developed to assess the ecological functionality of riparian areas

along perennial and intermittent streams as well as riparian habitat at springs and seeps. The 

basis of evaluation is local site potential and capability. 

A comment was received on the DEIS that this project hadn’t addressed SRT Recommendation 

VI-3 of determining the applicability of PFC to North Dakota. The IDT reviewed the SRT 

recommendation (Final Response to the SRT Reports, p. 19) and confirmed that PFC is 

applicable to North Dakota. The PFC methodology is a widely accepted, interagency protocol 

used to assess riparian conditions. It was developed in the American West by federal landmanagement agencies and has been used extensively for more than a decade. The DPG's 

climatic, geologic, and fluvial conditions are highly representative of many watersheds where the 

PFC methodology was developed and refined. Wayne Elmore, a former director of the National 

Riparian Service Team (NRST), visited the Little Missouri National Grassland in 1999 and 

found the methodology well-suited for use in North Dakota. Elmore and three other members of 

the NRST visited the nearby Sioux Ranger District of the Custer National Forest in South Dakota 

in 2005 and again concluded the methodology was well suited for the region. The methodology 

is universally applicable because all assessments are made with respect to potential condition.
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Affected Environment—Riparian 

This section provides a general description of riparian related information for the project area. A 

detailed description of the existing condition of riparian areas in each allotment is provided in 

Chapter 3 Part 2.

EXISTING CONDITION

The combination of topography, vegetation patterns, and herding practices has had negative 

impacts on many riparian areas in the Badlands Geographic Area (GA) of this project area. Many 

riparian areas in the Badlands GA have low to moderate ecological functionality. In contrast, 

most riparian areas in the Rolling Prairie GA have high ecological functionality.

PFC surveys were conducted on 56.4 miles of intermittent stream reaches occurring on NFS 

lands in the project area. Intermittent streams flow only at certain times of the year when they 

receive water from surface sources such as snow melt, storm runoff, or from ground water 

discharge. The surveyed riparian areas were located along the following streams: Ash Coulee, 

Betsy Creek, Blacktail Creek, Fantail Creek, Green River, Magpie Creek, Mikes Creek, North 

Creek, Scairt Woman Draw, Spring Creek, unnamed tributary to Blacktail Creek, and Whitetail 

Creek (see Figure 3.2). The Little Missouri River (LMR) is the only perennial stream (a stream 

that flows year-round) located in the project area. A small portion of the river flows through the 

western portion of the project area. A 2010 field review of the four allotments bordered by the 

LMR, by the Medora District hydrologist, did not identify any riparian concerns.

Ephemeral streams were not evaluated because these areas generally hold water for so short a 

period that livestock rarely concentrate there. Ephemeral streams flow in direct response to 

rainfall or snowmelt events. They have no base flow and do not support riparian habitat.

Allotments 127, 131, 132A, 132H, 133D5, 136/139, 140, 142, 158, 220, 221, 239, 241, 243, 248, 

249, 272, 281, and 288 contain only ephemeral streams and were not evaluated. 

Table 3.9 provides a summary of riparian functionality ratings for the surveyed stream reaches in 

the project area. Figure 3.2 identifies the surveyed streams and functionality rating by stream 

reach. The definition of the functionality ratings is located in Chapter 1 in the Key Issues section.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

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Table 3.9 — Riparian functionality ratings (miles and percent miles of channel) for 

intermittent streams in the North Billings project area

Stream

Riparian Functionality Rating* (miles)

Total

PFC FAR-U FAR-NA FAR-D NF

Ash Coulee 2.01 1.13 0.45 3.59

Betsy Creek 0.72 0.43 1.15

Blacktail Creek 2.88 0.7 3.59 7.17

Unnamed Trib. to 

Blacktail 0.75 1.1 1.85

Fantail Creek 2.51 2.51

Green River 1.26 1.26

Magpie Creek 10.18 0.84 5.86 16.88

Mikes Creek 6.51 6.51

North Creek 3.14 3.14

Scairt Woman Draw 2.13 0.77 2.9

Spring Creek 0.76 0.76

Whitetail Creek 6.25 1.58 0.86 8.69

Total (miles) 28.61 2.51 3.3 2.87 19.12 56.41

Percent (%) 50.7 4.4 5.9 5.1 33.9 100.0

*PFC= Proper Functioning Condition; FAR-U = Functional-At Risk-Upward Trend; FAR-NA = Functional-At

Risk-Trend Not Apparent; FAR-D = Functional-At Risk-Downward Trend; NF = Nonfunctional.

The data in Table 3.9 show that slightly more than one-half (50.7 percent) of the intermittent 

stream reaches (measured by length) were at PFC; and slightly more than one-third (33.9 

percent) of reaches were NF. Functional-At R streams constituted the remaining 15.4 percent of 

riparian areas.
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Figure 3.2 — Surveys streams and functionality ratings.
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Detailed existing condition information for surveyed stream reaches by allotment and pasture is 

presented in Part 2 of this Chapter. Table 3.10 provides riparian functionality ratings for each 

surveyed stream segment by allotment and pasture.

Table 3.10 — Riparian functionality ratings for intermittent streams in the N. Billings

project area

Allotment/Pa

sture # Stream (Reach #)

Miles of Stream in each Functionality Rating* Group

PFC FAR-U FAR-NA FAR-D NF Total

126-05 Whitetail (5) 0.11 0.11

126-06 Whitetail (5) 1.61 1.61

128-01 Whitetail (6) 1.07 1.07

128-01 Whitetail (7) 0.19 0.19

129-01 Magpie (4) 0.66 0.66

129-02 Magpie (4) 1.81 1.81

129-01 Magpie (5) 0.58 1.55 2.13

130-01 Whitetail (4) 1.84 1.84

130-02 Whitetail (4) 0.27 0.27

133-01 Blacktail (1) 0.41 0.41

134-01 Whitetail (2) 0.76 0.76

134-03 Whitetail (1) 0.73 0.73

135-08 Mikes (2) 2.79 2.79

135-09 Mikes (2) 1.98 1.98

135-10 Mikes (1) 1.74 1.74

140-01 Blacktail (2) 0.07 0.07

141-01 Green (1) 0.44 0.44

141-03 Green (1) 0.82 0.82

230-03 Blacktail (1) 0.91 0.91

237-01 Blacktail (2) 1.4 1.4

240-03 North (1) 1.28 1.28

240-04 Spring (1) 0.76 0.76

244-02 Whitetail (2) 0.26 0.26

244-02 Whitetail (3) 0.51 0.51

256-02 Blacktail (3) 0.09 0.09

256-02 Blacktail (4) 1.76 1.76

256-02 Unnamed Trib to 

Blacktail (9) 0.45 0.45

256-02 Unnamed Trib to 

Blacktail (10) 0.75 0.75

256-03 Blacktail (4) 1.83 1.83
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Allotment/Pa

sture # Stream (Reach #)

Miles of Stream in each Functionality Rating* Group

PFC FAR-U FAR-NA FAR-D NF Total

256-03 Blacktail (5) 0.7 0.7

258-01 Ash Coulee (1) 0.06 0.06

258-01 Ash Coulee (2) 0.32 0.32

258-02 Ash Coulee (0) 1.13 1.13

258-02 Ash Coulee (1) 1.15 1.15

258-02 Ash Coulee (2) 0.13 0.13

258-02 Ash Coulee (3) 0.8 0.8

277-02 North (2) 1.53 1.53

277-02 Scairt Woman Draw 

(2) 0.55 0.55

277-05 Magpie (1a) 2.45 2.45

278-01 Whitetail (1) 0.1 0.1

282-03 Fantail (1) 0.4 0.4

282-04 Whitetail (11) 0.22 0.67 0.89

282-05 Fantail (1) 2.11 2.11

282-06 Magpie (6) 0.47 0.47

282-06 Magpie (7) 3.84 3.84

283-01 Whitetail (5a) 0.35 0.35

286-01 Betsy (1) 0.43 0.43

286-01 Betsy (2) 0.13 0.13

286-03 Betsy (2) 0.59 0.59

287-03 Unnamed Trib to 

Blacktail (9) 0.65 0.65

289-02 North (2) 0.33 0.33

289-03 Scairt Woman Draw 

(1) 2.13 2.13

289-03 Scairt Woman Draw 

(2) 0.22 0.22

300-01 Magpie (1b) 0.12 0.12

301-01 Magpie (2) 1.87 0.14 2.01

301-04 Magpie (3) 2.04 2.04

302-01 Magpie (1c) 0.28 0.28

302-01 Magpie (2) 0.22 0.22

FS Magpie (4) 0.85 0.85

Total (miles): 28.61 2.51 3.3 2.87 19.12 56.41

Percent (%) 50.7 4.4 5.9 5.1 33.9 100.0

*PFC= Proper Functioning Condition; FAR-U = Functional-At Risk-Upward Trend; FAR-NA = Functional-At 

Risk-Trend Not Apparent; FAR-D = Functional-At Risk-Downward Trend; NF = Nonfunctional.
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DESIRED CONDITION

The overall Desired Condition for riparian resources is identified under Goal 1a. of the 

Grasslands Plan: “Improve and protect watershed conditions to provide the water quality and 

quantity and soil productivity necessary to support ecological functions and intended beneficial 

water uses.” The Badlands and Rolling Prairie GA section of the Grasslands Plan further defines 

the desired condition for riparian areas with direction to maintain streams at PFC or improve 

them to an upward trend. 

Capability

Comment received on the DEIS indicated that the Grasslands Plan needed to be amended prior to 

undertaking this project because the Grasslands Plans direction was unattainable. This would 

include desired conditions for riparian. PFC surveys and field observations on the existing 

riparian exclosure on Ash Coulee Creek demonstrate that stream reaches heavily impacted by 

livestock use are capable of significant recovery when grazing activities are removed. The 

exclosure was built in 2000 in response to livestock impacts on the stream. The stream reach 

located within the exclosure recovered to PFC within several years of construction of the 

exclosure. Additionally, a riparian pasture constructed upstream of the above exclosure in 1996 

is also at PFC. The creation of this pasture combined with light grazing has allowed the stream to 

recover to PFC. The above information shows that the riparian systems in the project area are 

capable of meeting PFC. 

Environmental Consequences—Riparian

DIRECT AND INDIRECT EFFECTS 

As noted previously, no riparian surveys were conducted in allotments that contained only 

ephemeral streams. Furthermore, there were also a number of riparian areas in the allotments that

are currently meeting riparian objectives. Those allotments (130, 133, 134, 141, 230, 237, 240, 

283, 289, 302) are not addressed in this analysis. Instead this analysis focuses on FAR and NF 

stream reaches.

Alternative 1

The cessation of grazing would have an immediate positive effect on FAR and NF riparian areas. 

Riparian plant communities would begin to expand in areas where plant density is light, sparse, 

or absent. Stream bank impacts resulting from trampling and trailing would cease, which, along 

with recovering riparian vegetation, would result in the stabilization of stream banks and beds. 

Improving riparian vegetation would also result in improved sediment entrapment, building 

banks, and narrowing the width to depth ratio. 
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Alternative 2

Alternative 2 calls for no change in livestock management. Livestock grazing would continue in 

the future as it has for the past decade or more, with no new range improvements, no increase or 

decrease in livestock numbers except in response to annual operating instructions that evaluate 

climatic conditions and seasonal forage production, and no changes in grazing systems.

The net effect of no change in current management is that areas that are currently at desired 

condition are likely to remain so, and areas that have resource concerns or management problems 

are likely to show continued or additional impairment. Impacted riparian areas are unlikely to 

heal until the underlying cause is addressed. Specifically, under current management, bank 

erosion, channel incision, and livestock trailing are likely to remain. Deficiencies in riparian 

vegetation, including lack of diversity, lack of cover, problems with composition, invasion of 

non-native species and noxious weeds, and the lack of regeneration will persist under current 

management. Rates of channel erosion and sedimentation will remain high in impaired reaches.

Elevated sediment loads will impair the ability of desired riparian vegetation to colonize and 

flourish.

Currently, slightly more than half (approximately 51 percent) of the riparian areas in the project 

area are at desired condition (Tables 3.4 and 3.5). Under Alternative 2, all impaired reaches 

(those rated as FAR-NA, FAR-D, and NF) would continue in impaired condition.

Alternatives 3, 3A and 4

Alternatives 3, 3A, and 4 use an array of different initial actions including range improvements, 

establishment of riparian pastures, riparian exclosures, implementation of different rotational 

grazing systems, Authorized Use adjustments, etc., to move impaired stream reaches towards 

PFC. Specific actions associated with each allotment are identified in Part 2 of this chapter.

Table 3.11 identifies the number of reaches by allotment that would improve under initial and 

adaptive actions by alternative.

Table 3.11 — Number of stream reaches that would improve by action alternative

Allot 

#

Creek

# of 

Stream 

Reaches 

rated 

FAR-U

or NA

# of 

Stream 

Reaches 

rated 

FAR-D

or NF

Alternatives 3 & 3A Alternative 4

FARU or NAFAR-D 

or NF

FARU or NAFAR-D or 

NF

Initial

Adaptive

Initial

Adaptive

Initial

Adaptive

Initial

Adaptive

128 Whitetail - 2 - - 2 - - - 2 -

129 Magpie - 2 - - 2 - - - 2 -

135 Mikes - 2 - - 2* - - - 2 -

244 Whitetail - 1 - - 1 - - - 1 -
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Allot 

#

Creek

# of 

Stream 

Reaches 

rated 

FAR-U

or NA

# of 

Stream 

Reaches 

rated 

FAR-D

or NF

Alternatives 3 & 3A Alternative 4

FARU or NAFAR-D 

or NF

FARU or NAFAR-D or 

NF

Initial

Adaptive

Initial

Adaptive

Initial

Adaptive

Initial

Adaptive

256

Blacktail,

Unnamed 

Trib1

2 3 1 1 2 1 2 - 3 -

258 Ash Coulee 1 2 - 1 1 1 1 - 2 -

2772Scairt Woman - 1 - - - - - - - -

282

Whitetail/

Magpie/

Fantail

2 3 2 - 3* - 2 -

2

1* -

286 Betsy 2 1 2* - 1* - 2* - 1* -

287 Unnamed Trib - 1 - - 1* - - - 1 -

289 Scairt Woman - 1 - - 1 - - - 1 -

300 Magpie - 1 - - 1 - - - 1 -

301 Magpie - 1 - - 1 - - - 1 -

Total 7 21 5 2 18 2 7 0 20 0

1Unnamed tributary of Blacktail Creek 2Unable to determine the cause of NF condition for Scairt Woman Draw; will 

continue to monitor. *PFC achieved over several decades.

As identified in Table 3.11, Alternatives 3 and 3A’s initial proposed actions would improve five 

of the stream reaches rated as FAR-U and FAR-NA. While all five reaches would improve, it is 

predicted that two of the reaches located in allotment 286 on Betsy Creek would take several 

decades to reach PFC because of channel incision and the lack of riparian vegetation. Adaptive 

actions are predicted to improve the two remaining reaches in allotments 256 and 258 on 

Blacktail and Ash Coulee Creeks.

Of the stream reaches rated as FAR-D or NF, a total of 19 would improve through the 

implementation of initial actions. However, seven of the reaches located in allotments 135, 282, 

286, and 287 would take several decades to reach PFC due to channel incision, loss of water 

table, and the lack of riparian vegetation. 

Under Alternative 4, initial proposed actions would improve all seven of the stream reaches rated 

as FAR-U and FAR-NA. While all seven reaches would improve, it is predicted that two of the 

reaches located in allotment 286 on Betsy Creek would take several decades to reach PFC due to 

channel incision and the lack of riparian vegetation. 

Of the stream reaches rated as FAR-D or NF, a total of 20 would improve through the 

implementation of initial actions. However, three of the reaches located in allotments 282, 286, 
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and 287 would take several decades to reach PFC due to channel incision, loss of water table, 

and the lack of riparian vegetation. 

Under all of the alternatives it is unknown if the management actions proposed would improve 

the NF status of a stream reach located on Scairt Woman Draw in Allotment 277. This is because 

the underlying cause of the functionality problem was not clearly due to the effects of livestock 

grazing, therefore it was not clear that changes in grazing practices would result in recovery 

during the time frame of this project.

Table 3.12 provides a comparison of the MGA 3-year average permitted use to the range of 

alternatives. As explained under the range section of this chapter, the 3-year average is used for 

comparison purposes and to more sharply define the differences between the alternatives.

A comparison of the Authorized Use (Preference) under Alternatives 2, 3, and 3A with the MGA 

3-year permitted average shows an increase in AUMs ranging from 4 to 74 percent if permittees 

utilized their full Authorized Use, i.e., Preference. With regard to riparian conditions, it is not 

necessarily the number of cattle that is the issue, but the location. Alternatives 3 and 3A use a 

variety of actions, including fencing, to control access to water, creation of riparian pastures and 

exclosures, stock tank water management, etc., to move cattle away from riparian areas or 

control access. Therefore, even if numbers are higher, riparian conditions are still anticipated to 

improve. Allotment 258 would increase by 37 percent; however, a proposed riparian exclosure 

would mitigate an increase in Authorized Use. Oil and gas development has also adversely 

affected the reach associated with this allotment. The 74 percent increase in AUMs in Allotment 

286, however, would likely cause increased impacts to the two affected stream reaches in the 

allotment.
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Table 3.12 — Comparison of alternatives to MGA 3-year average summer permitted use

for allotments with streams reaches rated as FAR-NA, FAR-D, or NF Allotment Number MGA 3 yr. Average Permitted Use (AMs) MGA 3 yr. Permitted Use 

Converted to (AUMs)

Alts

1 2, 3, 3A

Authorized Use 

Converted to AUMs

Alts

1 2, 3, 3A compared 

to MGA 3 yr. average

Permitted Use

(%)

Alt 4 Authorized Use

AUMs

Alt 4 compared to MGA

3 yr. average permitted 

use AUMs

(%)

Alt 4 compared to 

Alt 2, 

3, and 3

A (Preference)

(%)

126/

128 2188 2516 2708 +8 2178 -13 -20

129 897 1032 1254 +22 1090 +6 -13

134 239 275 292 +6 220 -20 -25

135 1432 1647 1793 +8 1559 -5 -13

256 1381 1588 1830 +15 1509 -5 -8

258 1510 1735 2382 +37 1529 -12 -29

277 1007 1158 1298 +12 1129 -3 -4 

282 1855 2133 2441 +15 2859 +34 -13

286 160 184 320 +74 236 +28 -26

300 436 501 559 +4 486 -3 -6

301 1541 1772 1916 +8 1509 -15 -9

1 Authorized Use for Alternatives 2, 3, and 3A is the same as Preference.

Comparing the MGA 3-year permitted average to Authorized Use under Alternative 4 shows a 

range of potential increases and decreases in Authorized Use. Allotments 129, 282, and 286

could see an increase in Authorized Use of 6, 34, and 29 percent, respectively. The remaining 

allotments could see decreases in Authorized Use ranging between 3 and 20 percent. Due to a 

proposed riparian exclosure which would be constructed along Magpie Creek where the 

impacted stream reach is located, the 3 percent increase in Allotment 129 would not affect 

current PFC ratings. Allotment 282 shows a 32 percent increase, associated with a reach located

Magpie Creek and one on Whitetail. Because of a proposed riparian exclosure that would be 

constructed on this reach, the reach on Magpie Creek would not be affected by an increase in 

Authorized Use. The reach located on Whitetail Creek has been affected by accelerated runoff 

attributable to oil and gas development and roads directly above the watershed, so an increase in 

Authorized Use should not have much effect. Allotment 286 could see a 28 percent increase 

Authorized Use, which could cause additional impacts to the two affected stream reaches. 

CUMULATIVE EFFECTS

Cumulative effects result from the combination of effects resulting from past, present, and 

reasonably foreseeable actions plus the direct and indirect effects of the alternatives. A 

discussion of past and present actions, reasonably foreseeable actions, and a summary of the 

cumulative effects by alternative follows.
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Chapter 3 | 125

Past and Present Actions 

The following past and present actions have contributed to the existing NF and FAR stream 

reaches.

Livestock grazing has affected, and continues to affect, riparian areas in the project area. In the 

past, the effects of livestock grazing in combination with poor farming practices and drought 

resulted in loss of vegetation. This accelerated down cutting in streams such as Mikes and 

Blacktail Creeks, which resulted in loss of water tables, unstable banks, etc. Some of those 

effects have continued to the present. Livestock continue to graze riparian areas and utilize 

streams for watering. The use of riparian vegetation on some stream reaches in the project area 

has been high, which, in combination with mechanical effects such as trampling and trailing, has 

decreased some stream reaches' abilities to trap sediment and maintain stable banks and beds. 

Livestock actions have contributed to the poor riparian conditions of the 28 stream reaches rated 

at FAR and NF in the project area. 

Past oil and gas development has resulted in the creation of an all-weather road system. Roads 

can alter hydrologic patterns by concentrating runoff in ditches, directing water through culverts, 

depriving some down slope segments of moisture from natural runoff, and inducing incision of 

channels and erosion of drainage ways due to the increased volume and velocity of runoff. This 

has primarily occurred in the Magpie, Blacktail, and Whitetail Creek watersheds. 

Where channel incision and gully formation has occurred, it has generated excessive amounts of

sediment that overwhelms the transport capacity of downstream reaches. Deposition ensues 

downstream with adverse effects on riparian vegetation. 

Currently, oil and gas activity is primarily focused around maintenance of existing oil and gas 

facilities and maintenance of oil and gas roads. These activities still offer the opportunity to put 

sediment into the streams and concentrate runoff. Oil and gas activity will continue; however, 

road construction techniques have improved. Past actions adversely affecting streams are being 

corrected, such as the future replacement of a low-water ford with a bridge on Blacktail Creek. 

The implementation of BMPs will help mitigate the effects of roads associated with the streams 

in the project area.

Noxious Weeds/Invasive Grasses. It is unknown when noxious weeds and invasive grasses first 

appeared in the project area. Some invasive species appeared sometime in the 1930s, such as 

crested wheatgrass, which was successfully used in the reclamation of sub-marginal lands. The 

primary past, current, and future effect of these groups of plants is that they alter or replace 

native plant communities, which in turn affects the functionality of riparian areas by altering the 

diversity of bank-forming vegetation thus increasing the potential for eroded banks and stream 

bars. 

Wildfires have been actively fought on the LMNG and adjacent private and state lands since 

Euro-American settlement began. The result has been an increase in some tree and shrub 

communities and a reduction or loss of vigor in plant communities where fire plays a role in 

maintaining the health of those systems. Wildfire may alter upland vegetation, which may 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

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increase overland flow in heavily utilized areas and indirectly affect stream functionality;

however, these effects are generally temporary in nature. Riparian areas tend to be more resilient 

to fire due to the presence of moisture, which tends to alter fire behavior. The presence of 

moisture also helps burned riparian areas recover more quickly, as evidenced by the recovery of 

Fantail Creek which burned in 1988. 

Drought is a recurring natural event in western North Dakota. Approximately 51 percent of

stream reaches rated as PFC would generally be the least or last to be impacted by drought. 

However, the remaining 49 percent of stream reaches rated as FAR or NF have a reduced ability 

to withstand the effects of drought due to the loss of or lowered water tables, increased 

evaporation due to the loss shading vegetation, etc. 

Farming of sub marginal lands in the 1930s in combination with several other factors resulted in 

massive erosion, sediment delivery, and accelerated stream down cutting in some cases. The 

cultivation of crops is no longer conducted on the LMNG; however, it does occur on the 

intermingled private lands in and adjacent to the project area. This activity might be contributing 

sediment to the streams of the area, but it is uncertain if this is occurring and, if so, to what 

degree this activity may be impacting streams.

Reasonably Foreseeable Actions

Elkhorn Ranchlands. The recently purchased Elkhorn Ranchlands require that the Grasslands 

Plan be amended to establish management direction for the newly acquired lands. Approximately 

800 acres of the 5,200-acre Elkhorn purchase are directly associated with five of the allotments 

in the North Billings project. Under the proposed amendment, these lands would be managed in 

accordance with the adjacent management area — MA 3.65 Rangelands with Diverse Natural 

Appearing Landscapes. In the interim, as directed by 36 CFR 254.3(f)(2008), this portion of the 

purchase is being managed in accordance with the adjacent MA 3.65. If the proposed action is 

selected and implemented there would be no change over the current situation. 

The proposed Plan amendment also includes the establishment of a special interest area (SIA) for 

the remaining 4,400 acres of the purchase and the approximately 17,160 acres contained in 

grazing allotments 279 and 280 that were associated with the Elkhorn Ranchlands when they 

were privately owned. If implemented, the SIA would establish a forage reserve on those acres. 

The reserve would provide a place to move livestock to in the event an allotment is burned out or 

if management actions such as a prescribed fire or additional rest were needed to help restore an 

allotment. 

Travel Management Plan. An environmental assessment (EA) for travel management on the 

LMNG was released for comment in 2010. The proposed action for this EA would close all 

single use oil and gas roads, unauthorized roads i.e. two tracks, and an additional 18 miles of 

system roads in the project area. The travel management plan is expected to have minimal effects

on grazing permit holders unless single-use roads are blocked from access. If access were to be 

blocked, then additional two-track roads could be created as permittees can travel cross county to 

administer their permits. Depending on the location of the new roads, this may lead to increased 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

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erosion, increased sediment transport to streams, adverse effects on wildlife, and possible 

impacts to woody draws. 

Oil and Gas Development. The Forest Service has received five applications for permit to drill 

(APDs) on NFS lands in the project area. The APDs seek to drill oil and gas wells. The well pads 

associated with each well would be approximately 4 to 5 acres in size encompassing about 22 

acres total. Two wells would reuse all or a portion of existing reclaimed well pad sites and the 

remaining pads would involve new construction. Approximately 4,250 feet of roads would be 

built to access the well sites, of which 2,900 feet of would be located on old reclaimed road sites. 

The wells are located in Allotments 127, 135, 287. Three of these wells are not located near any 

riparian areas; however, two of the proposed wells are located 400 feet or greater from Mikes 

Creek. These wells would be evaluated by the Forest Service district hydrologist during the 

NEPA process for these wells.

Cumulative Effects by Alternative 

This section summarizes direct and indirect effects of the alternatives and the effects of 

reasonably foreseeable actions on streams and riparian areas. These effects in combination with 

past and present effects combine to create cumulative effects.

Alternative 1, in combination with reasonably foreseeable travel management, provides the best 

opportunity of all the alternatives for the most rapid recovery of all NF and FAR stream reaches

to PFC due primarily to the removal of disturbance associated with livestock, which affords the 

best opportunity for riparian vegetation recovery and stream bank stabilization. Implementation 

of the travel management plan offers the potential to improve FAR and NF stream reaches by 

closing or reducing traffic on roads that may be contributing sediment to streams. Two 

foreseeable oil and gas wells are located 400 feet or greater from Mikes Creek. Before 

development, these wells would be reviewed by the Forest Service district hydrologist and 

mitigation measures would be implemented, if needed, to prevent potential adverse impacts to

Mikes Creek.

Alternative 2 may see some improvement to FAR and NF rated stream reaches because of the 

potential beneficial effects of the Elkhorn Ranchlands Grasslands Plan amendment. The forage 

reserve portion of the proposed amendment offers opportunities to potentially hasten the rate of 

recovery of some stream reaches by offering an alternate source of forage, thereby providing 

additional recovery time for FAR and NF stream reaches. The potential effects associated with 

the travel management plan and oil and gas development are the same as identified under 

Alternative 1. However, because this alternative maintains the existing Authorized Use levels, 

rotations, etc., the opportunity to achieve a cumulatively positive effect in FAR and NF stream 

reaches is the least likely of all the alternatives. 

Alternative 3, initial actions would improve riparian conditions in 18 of the 21 stream reaches 

identified as FAR-D or NF. Seven of the 18 reaches are rated as NF, and, though improvement is 

expected during the next 10 to 15 years, it is predicted to take several decades to achieve PFC in 

these reaches. Five FAR-U and FAR-NA stream reaches would also improve, however, two of 
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these five reaches are expected to take several decades to accomplish PFC. The potential effects 

associated with the travel management plan, oil and gas development, and the Elkhorn 

Ranchlands Grasslands Plan amendment are the same as those identified under Alternatives 1 

and 2, respectively.

Alternative 3A would not affect any of the FAR or NF stream reaches differently than 

Alternative 3 so the cumulative effect of these two alternatives is the same.

Alternative 4, initial actions would improve 20 of the 21 FAR-D and NF stream reaches;

however, two of the reaches located in Allotments 282 and 286 would take several decades to 

reach PFC. Seven FAR-U and FAR-NA stream reaches would also improve. However, two of 

the seven reaches are expected to take several decades to accomplish PFC. The potential effects 

associated with the travel management plan, oil and gas development, and the Elkhorn 

Ranchlands Grasslands Plan amendment are the same as those identified under Alternatives 1 

and 2, respectively.

Under all of the alternatives it is unknown if their management actions will improve the NF 

status of a stream reach located on Scairt Woman Draw in Allotment 277. This is because the 

underlying cause of the functionality problem was not clearly due to the effects of livestock 

grazing, therefore it was not clear that changes in grazing practices would result in recovery.

Adaptive Management. Implementation of adaptive management options under Alternatives 3, 

3A, and 4, including actions identified in the tool box, would improve FAR and NF stream 

reaches not addressed by the initial actions. In terms of adaptive management, the greatest 

difference between these alternatives is the rate of change. 

In most cases, alternatives 3 and 3A initiate more indirect actions to deal with riparian concerns, 

such as rotation changes, water management, etc. Determining whether these actions are 

effective requires time, generally 3 to 5 years, so this time is lost if the actions are determined to 

be ineffective. Alternative 4 implements a higher number of direct riparian actions such as 

riparian pastures, exclosures, etc., which directly improve riparian areas in a shorter time frame,

as shown by riparian enclosures and pasture on Ash Coulee Creek.

Consistency with Grasslands Plan—Riparian

The following are the primary range-related standards and guidelines associated with this 

project. For a complete listing see the Grasslands Plan Standard and Guide Consistency Table 

located in the Supporting Documentation – Grasslands Plan Documents & Misc. section of the 

Project Record.

Manage land treatments to conserve site moisture and to protect long-term stream, wetland, and 

riparian area health from damage by increased runoff. Standard

All of the alternatives except Alternative 2 implement actions to improve the mosaic of 

herbaceous structure towards Grasslands Plan Objectives. This would reduce any excess 

overland flow that may be occurring; however, there is no evidence that excessive runoff is 

occurring other than in localized situations in response to sudden short-term, high-intensity 
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downpours. Implementation of different actions under Alternatives 3, 3A, and 4—such as the 

creation of riparian pastures and exclosures, changes in rotations, and/or adjustments of 

Authorized Use—would improve riparian vegetation on impacted stream reaches and improve 

stream health.

Design activities to protect and manage the riparian ecosystem. Maintain the integrity of the 

ecosystem, including quantity and quality of surface and ground water. Standard

Activities such as drilling rangeland wells, construction of rangeland pipelines, placement of 

stock tanks, etc., would be carried out under Forest Service construction specifications and 

applicable BMPs. These facilities would not be placed in riparian areas and are often used with 

a goal of pulling livestock away from riparian areas in order to minimize impacts resulting from 

livestock. 

Maintain and protect the hydrologic regime that supplies ground water to the wetlands in order to 

support species and habitats that depend on the existing water table and its natural variations.

Standard

Wetlands in the project area are mostly narrow intermittent green bands located directly 

adjacent to intermittent streams. The primary factor that may affect the ground water regime is 

rangeland water wells. Several wells are proposed under Alternatives 3, 3A, and 4; however, the 

Forest Service district hydrologist has determined that the rate of withdrawal of these wells 

would not affect ground water supplies to the point at which there would be an adverse effect to 

wetlands in the project area.

Allow only those actions next to perennial and intermittent streams, seeps, springs, lakes, and 

wetlands that maintain or improve long-term proper functioning of riparian ecosystem 

conditions. Standard

See the response to the next standard.

Maintain long-term ground cover, soil structure, water budgets, and flow patterns of wetlands to 

sustain their ecological function and meet regulations found in Section 404(b)(1) of the Clean 

Water Act. The 404 regulations were established by the Environmental Protection Agency and 

constitute the substantive environmental criteria used in evaluating activities. Standard

o Maintain enough water in perennial streams and ground water tables to sustain or 

improve function.

o Manage water-use facilities to prevent gully erosion on slopes, sediment discharge, 

and bank damage to streams.

o Design projects to minimize sediment discharge into streams, lakes, and wetlands.

o Protect seeps, springs, wetlands, and riparian ecosystems.

Projects proposed under Alternatives 3, 3A, and 4 include such elements as fencing springs and 

reservoirs, developing rangeland water wells, placing stock tanks, and constructing rangeland 

pipelines (see Table 2.11). Fencing of springs and reservoirs would provide additional 

protection to water sources. Rangeland water wells, pipelines, and placement of stock tanks 
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would not be located near riparian areas and would be constructed in accordance with Forest 

Service specifications and guidelines. Implementation of these actions would include BMPs to 

further assure that these types of projects would not adversely affect long term ground cover, soil 

structure, water budgets or flow patterns associated with wetlands. 

WOODY DRAWS

Introduction

Euro-American settlement of the Northern Great Plains (NGP) during the late 1800s brought 

large and often excessive livestock numbers (Holechek et al 2004) that likely had adverse effects 

on many woody draw systems. Trees from woody draws were harvested for fuel and 

construction needs, and springs along drainages were developed for human and livestock 

consumption. Ponds or reservoirs were eventually constructed to store ephemeral flow along 

drainages, and these ensured high livestock concentrations along woody draws. Rangeland fires 

that likely controlled the encroachment of woody species into grassland habitat occurred at 

moderate to high frequency prior to European settlement, both from natural lightning strikes and 

as set by indigenous tribes (Grant and Murphy 2005, Higgins 1984, Higgins et al 1989, Sieg 

1997). Upon Euro-American settlement, intensive control of wildfires was conducted as a 

necessity for protecting property, livestock, and agricultural assets, and increased the potential 

spread of woody draws and several other woody communities (Bailey 1976, Grant and Murphy 

2005, Lura 2009, Higgins et al. 1989). It is also possible that high levels of livestock grazing 

disturbances assisted the expansion of woody species by decreasing the vigor, density, and 

structure of grassland communities, thus increasing their susceptibility to woody invasion (Butler 

1983). However, comparison of aerial photographs from 1939 and 1953 with 2009 indicate that 

woody draw expansion has been minor in the project area. These comparisons are contained in 

the Botany Report (Project Record, Specialist Reports and Notes).

Woody draw habitats in the project area tend to occur as linear stringers along various ephemeral 

and intermittent drainages and adjacent slopes with moderately increased amounts of available 

moisture. These habitats constitute less than 10 percent of the LMNG, which increases their 

attractiveness for many wildlife species and a variety of human-related uses. Structural and 

ecological diversity provided by woody draws within the semi-arid grassland-dominated 

landscape attracts a disproportionately high number and diversity of wildlife species seeking 

forage, cover, and nesting habitat (Rumble and Gobeille 1998; Hodorff et al. 1988; Sieg et al. 

1984; Hopkins 1983a,b; Grosz et al. 1981; Seabloom et al. 1978; Stewart 1975). Combined with 

low or sheltered topographic positions, woody draw structure provides the primary source of 

shade in the summer and thermal cover in the winter. Woody draws trap, store, and release 

limited moisture, sediment, and nutrients, thus influencing downstream riparian systems.

Livestock also seek the amenities of woody draws that attract wildlife. Shade and cooler 

temperatures reduce heat stress and the torment of horn flies (Haematobia spp) and other insect 

pests. The increased moisture and shaded understory of woody draws result in lengthened green 

periods of herbaceous growth that along with several shrub species and tree saplings can attract
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livestock. Developed water sources involving springs and reservoirs have been constructed along 

many woody draw drainages, and result in heavy livestock concentrations. The terrain along 

woody draw drainages is often gentler than the surrounding topography, so these sites often 

serve as travel corridors for daily livestock movements to and from water developments and 

forage areas.

As disturbance from livestock increases, successful tree and shrub regeneration decreases and 

mature or decadent trees begin to dominate the population. Structure of the shrub layer similarly 

decreases, often with an increased dominance of low-statured western snowberry. Kentucky 

bluegrass begins to dominate the herbaceous layer and can form a dense sod that can impede the 

reproductive success of woody species by inhibiting seed germination and increasing 

competition with developing seedlings. Relatively static or decreasing populations of the tree and 

shrub components are indicators of poor ecologic conditions and a trend towards the woody draw

community being replaced by shrub and grass communities (Bjugstad and Girard 1984; Boldt et 

al. 1978; Butler 1983; Butler and Goetz 1984; Girard et al. 1987; Hansen et al. 1984a, 1995;

Hopkins and Ryan unpublished; Jensen 1991; Lesica 1989; Lesica and Atthowe 2001; Nelson 

1960; Severson and Boldt 1978; Uresk et al. 2009).

Woody draws also attract recreation users for a variety of uses including hiking, bird watching, 

hunting, trapping, and firewood harvest. Hunting, trapping, and firewood harvest associated with 

woody draws in the region of western North and South Dakota, eastern Montana, and eastern 

Wyoming, have been estimated to contribute 38 million dollars per year to local economies when 

combined with related costs of fuel, lodging, and incidental expenses (Bjugstad and Sorg 1985).

There are a variety of woodlands located on the LMNG; however, there are primarily two types 

of woodlands located in the project area, Rocky Mountain juniper and green ash. The Rocky 

Mountain juniper stands are located primarily in the Badlands geographic area and are 

expanding, likely due to the lack of fire on the landscape. As described in the Botany Report 

(Project Record, Specialist Reports and Notes), the expansion of Rocky Mountain juniper into 

grassland habitat is especially evident in the Badlands geographic area, but is also occurring in 

the Rolling Prairie, and is beginning to constitute greater amounts of woody draw tree cover 

within both of these settings. 

Green ash woodlands are generally composed of a variety of hardwoods, with green ash being 

the dominant tree and American elm the most frequent codominant. Other tree species found in 

this type of woodland include box elder (Acer negundo L.), quaking aspen (Populus tremuloides

Michx.), plains cottonwood, and peachleaf willow. These species generally occur as inclusions in 

proximity to springs or other sites of increased moisture. Dominant shrubs of the understory 

usually include chokecherry, serviceberry (Amelanchier alnifolia Nutt.), and western snowberry , 

but other common species include northern hawthorn (Crataegus rotundifolia Moench), 

American plum (Prunus americana Marsh.), gooseberry (Ribes spp.), aromatic sumac (Rhus 

aromatica Ait.), buffaloberry (Shepherdia argentea (Pursh) Nutt.), and wild rose (Rosa woodsii

Lindl.). 
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Under light or relatively undisturbed conditions, green ash woody draws exhibit a range of tree 

age classes or population structure that include prominent amounts of seedlings and saplings, 

young to middle-aged trees, and a mature overstory that create a moderately dense canopy.

Dense shrub layers of varying diversity and height add to the structural complexity. A mosaic of 

sedge and native grasses mixed among leaf litter and mineral soil characterize the ground layer. 

This analysis focused on the condition of green ash woodlands, hereafter referred to as woody 

draws, because previous analyses have suggested declining conditions of this habitat on the 

LMNG (FS 2002, Duxbury 2009, and others).

Spatial and Temporal Setting

The area for the woody draw analysis consists of the NFS lands located within the project area 

boundary, because management decisions within this area will have an effect primarily on 

woody draws within, not outside of, the project area. The temporal scope of the analysis is 10 to 

15 years. 

Methodology

Four data sources were used to assess woody draw conditions and included:

1) A long-term cooperative study between the North Dakota Game and Fish Department 

(NDGF) and the Forest Service;

2) Woody draw surveys conducted by the Medora Ranger District during 1998, and 2005

through 2007;

3) Sampling conducted by North Dakota State University (NDSU) during 2008 and 2009 as part 

of a cooperative agreement between the Forest Service, MGA, and NDSU; and

4) Use of aerial photography to determine the change in the extent of woody draws. 

The four sets of data differed in methodology and years of sampling and are briefly described 

below.

COOPERATIVE NDGF-FOREST SERVICE STUDY

A cooperative woody draw study between the Forest Service and NDGF was initiated in 1987.

The study included 17 randomly located, permanent sites within the project area. These sites 

have been sampled every 5 years since 1987. Within the selected woody draws, 30x75 foot 

macroplots were established. Within each macroplot, the number and species of all trees over 1 

inch dbh (diameter at breast height) were measured with a diameter tape and tallied into 1-inch 

dbh classes (8 to 9 inches, 9 to 10 inches, etc.). The density of tree saplings (≥2.5 feet tall and <1 

inch dbh) and seedlings (<2.5 feet tall) were measured along two 1.5-x75-foot belt transects 

extending the length of the macroplot. Saplings were also counted along five 1.5-x6-foot belt 

transects placed along the 30-foot baseline of the macroplot. The 1.5-x6-foot belt transects were 

also used to count the density of shrub stems by species. The percent canopy cover of 
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chokecherry and western snowberry were measured from twenty-five 20-x50-centimeter

Daubenmire plot frames spaced at 3-foot intervals along the two 75-foot belt transects. 

Woodland class structure codes were recorded for each macroplot beginning with the third 

measurement period in 1997.

Long-term monitoring of the NDGF-Forest Service woody draw sites was assessed to evaluate 

any trends in tree density and shrub cover over 20 years of sampling. Although there were 17

potential sites for this analysis, 1 site was excluded because of a wildfire and 3 sites were 

excluded because of non-measurement during one or more of the sample years.

FOREST SERVICE SURVEY 1998

Landscape level assessments of woody draw communities were conducted in 1997-1998 for 

preparation of the LMNG Rangeland Assessment (USDA Forest Service 2002). Eighty-one 

randomly selected sample sites occurred in the project area and were included in the present 

assessment of existing conditions.

Sampling involved a traverse of woody draw communities at least 5 acres in size while 

conducting ocular estimates of the percentage of canopy cover for tree, shrub, and herbaceous 

species. Complexes of distinct communities based on the dominant woody species were 

identified, apportioned as a percentage of the total woody community, and assigned a Woodland 

Structure Code (WSC). Ocular estimates of canopy cover for different age classes of tree and 

shrub species were recorded. Representative segments of each site were photographed. Seral 

stages of woody draw communities were determined from a previously developed model that 

utilized values of tree basal area and canopy cover of chokecherry and western snowberry 

(Uresk, unpublished). Condition classes of Healthy, At Risk, and Unhealthy were assigned to 

each sample site based on the WSC, the degree of woody species regeneration, estimates of seral 

stage, the presence of noxious weeds, and supplemental observations such as erosion, trailing, 

livestock and wildlife browsing, the extent of plant diseases and pests such as Dutch Elm, leaf 

blight, and tent caterpillars, and the degree of dead or dying trees.

The 1998 surveys’ condition parameters that identify the effects of livestock use on woody draws 

were separated from other less relevant survey information and are used in this analysis. Adverse 

impacts, such as Dutch Elm or other diseases, invasive/noxious weeds, and beaver-cut trees not 

directly linked to excessive livestock use, were not used to assign At Risk or Unhealthy 

condition ratings. In order to focus on adverse livestock related impacts and maintain consistent 

rating criteria, the original condition ratings for some of the 1998 Forest Service sample sites 

were adjusted based on a review of the previously collected data and site revisits during 2005

through 2007. The majority of rating adjustments involved an increase in condition class.

FOREST SERVICE 2005-2007 SURVEY

To supplement existing data, woody draw surveys were conducted at 187 sites during 2005

through 2007. Potential sample sites were selected from aerial photographs to characterize 

existing conditions and variability within pastures and allotments. Approximately 41 of the 1998 
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Forest Service sites were revisited to ensure that the previous condition ratings were based on the 

same criteria as the 2005 through 2007 ratings. The sampling methods for 2005 through 2007 

surveys followed the Forest Service 1998 methodology, except that there was no minimum 

acreage for a sample site and complexes or inclusions identified by a change in the dominant tree 

and/or shrub species were not delineated. Ocular estimates of the percentage of canopy cover 

were recorded for the most prominent tree and shrub species and each surveyed site was assigned 

an average WSC. Canopy cover by tree species was recorded among size classes of saplings, 

pole-sized trees, medium-sized trees, and large trees. Tree densities by 1-inch dbh classes were 

recorded from circular plots located to represent average conditions of the woodland. These plots 

were generally established with a 50-foot radius, but sometimes reduced to a 30-foot radius when 

tree sapling and shrub layers were dense enough to make access and counting difficult.

Supplemental observations were recorded similarly to the 1998 samples and representative 

segments of most sites were photographed.

NDSU 2008-2009 SURVEYS

Twenty-nine randomly selected sites were sampled by NDSU. The sample protocol is located in 

the Supporting Documentation – Range section of the Project Record, but, in summary, a 328-

foot plot centerline was established parallel with the long axis of the woody draw drainage and 

two transects were established 49 feet on either side of the centerline. The density of mature trees 

(≥3.1 inches dbh) and saplings (<3.1 inches dbh and > 8.2 feet tall) were recorded from four 49-x

49-foot squared (ft

2

) plots equally spaced along the centerline and between the two outer transect 

lines. Herbaceous or ground layer measurements included plant basal cover, canopy cover, 

percent frequency, and biomass production. Basal cover and canopy cover were measured with a 

total of 30 ten-pin point frames spaced along each of the two outer transects. Grass species 

frequency and forb and shrub density were measured with a total of 30 plot frames measuring 1.3 

ft2spaced along each of the two outer transects. Biomass clippings were collected from four 

1.92-foot

2 circular plots.

AERIAL PHOTO ASSESSMENT OF HISTORICAL CHANGE IN WOODY DRAW EXTENT

To evaluate potential changes in woody draw extent, 8- inch to the mile (1:7920) historical aerial 

photographs from 1939 and 1951 were obtained from the Soil Conservation District office in

Dickinson, ND for comparison with a 2009 digital photo layer (USDA FSA 2009). Historical

photo coverage was not complete for the entire project area for the years of 1939 and 1951. The 

historical photos covered primarily the Rolling Prairie geographic area and a smaller amount of 

the Badlands geographic area. A partial set of 1939 Forest Service 4-inch to the mile 

photographs (1:15840) were used to fill in gaps across the project area.

Portions of the historical aerial photographs were digitally scanned and saved as bitmap files for 

comparison with the 2009 digital layer. The picture files for each site and year were resized to 

similar scales for comparison and to estimate changes in woody draw acreage or canopy density. 
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Affected Environment—Woody Draws 

This section provides a general description of woody-draw-related information for the project 

area. A detailed description of the existing condition of woody draws in each allotment is 

provided in Chapter 3 Part 2.

EXISTING CONDITION

Of the 43 allotments in the project area, five (132A 133D5, 141, 220 and 248) contained no 

green ash woody draws. Six allotments (127, 135, 249,258, 282, and 283) met woody draw 

objectives. The remaining allotments exhibited varying percentages of Healthy, At Risk and 

Unhealthy woody draws. The definition of woody ratings is located in Chapter 1 in the Key 

Issues section.

Of 275 woody draws surveyed by the Forest Service and NDGF, 51 percent were rated Healthy, 

42 percent were rated as At Risk, and 7 percent were Unhealthy. Table 3.13 identifies by 

allotment the proportion of woody draws that were rated as Healthy, At Risk, or Unhealthy. 

Table 3.13 — Percentage of sampled woody draws rated as Healthy, Unhealthy, or At Risk

by allotment

Existing Condition Existing Condition

Allot #

Percent

Allot #

Percent

Healthy At Risk Unhealthy Healthy At Risk Unhealthy

126 31 69 241 17 83

127 80 20 243 67 33

128 63 32 5 244 75 25

129 56 44 249 100

130 27 67 6 256 50 50

131 56 44 258 86 14

132H 100 272 50 50

133 33 67 277 50 42 8

134 71 15 14 278 50 50

135 100 281 20 60 20

136/139 40 40 20 282 81 19

140 100 283 100

142 40 60 286 100

158 69 23 8 287 33 50 17

221 100 288 100

230 67 33 289 45 33 22

237 60 40 300 50 50

239 100 301 47 35 18

240 30 70 302 50 40 10
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Healthy woody draws (see Figure 3.3, a and b) exhibited the greatest average tree (339/acre) and 

sapling density (359/acre) and shrub canopy cover. Tree saplings were common among the tall 

shrub (chokecherry, serviceberry) layer that was generally dense enough to inhibit access.

Although the herbaceous layer of Healthy communities often contained areas of Kentucky 

bluegrass, longbeak sedge (Carex sprengelii Dew. ex Spreng.) and native grasses were usually 

prominent, as were bare mineral soil and woody leaf litter.

a) b)

Figure 3.3 — Healthy woody draw conditions.

Photos a) and b) show Healthy woody draw conditions; note the mixed tree age classes and 

dense shrub layers of desirable species, i.e., green ash, serviceberry, chokecherry, etc.

About 42 percent of the surveyed woody draws were rated At Risk due to a scarcity of tree 

saplings (<85 /acre) and poorly represented tall shrub layers (<11 percent canopy cover) and/or a 

dominance of short shrub layers, i.e., western snowberry (see Figure 3.4, a and b). Woody draws 

in At Risk condition consistently exhibited evidence of high livestock use including browsing 

and mechanical damage to trees and shrubs, trampling, and damage caused by livestock lounging 

within the shaded understory. Livestock trails observed in woody draws tended to involve 

multiple intertwining paths that were usually barren and exhibited dense and deep hoof prints 

that compact the soil. 

At Risk conditions in photo a) shows some mixed tree ages but no sapling/shrub layer is present 

and the herbaceous layer is dominated by Kentucky bluegrass sod and dandelion (Taraxacum 

officinale Weber). Photo b) is dominated by old and middle-aged trees with no saplings. A low 

shrub layer of western snowberry is present but the desired mid and tall shrub layers are absent. 
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a) b)

Figure 3.4 — At Risk woody draw conditions.

About 7 percent of the sites were rated as Unhealthy and exhibited the same livestock impacts 

described under the At Risk discussion above (Figure 3.5, a and b). Unhealthy conditions in 

photos a and b show remnant tree populations with only a few shrubs and younger trees confined 

to scattered patches.

a b

Figure 3.5 — Unhealthy woody draw conditions.

Basal sprouting from mature or decadent trees was common and constituted the majority of 

saplings among several of these sites, but heavy browsing of the basal sprouts and independently 

establishing saplings was typical (Figure 3.6). Low densities of tree sapling (<61/acre) and 

smaller 1- to 4-inch dbh classes (<44/acre) indicated that minimal successful recruitment was 

occurring. Kentucky bluegrass and other invasive grasses usually dominated the herbaceous 

layer with or without western snowberry shrubs. When bare ground was present among 

Unhealthy sites, it was generally trampled, compacted, and rilled, decreasing the ability of the

drainage to trap or slow the movement of sediment and moisture. Although tall shrubs were 

usually present, they tended to be confined to scattered patches along the least accessible slopes

of a woody draw and constituted less than 6 percent of the shrub canopy. Some of the Unhealthy 

woody draws are likely to revert to grass or western snowberry/grass communities due to a lack 

of tree regeneration and loss of all or most of the tall shrub layers.
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As identified above, the proportion of tree and shrub canopy cover and tree numbers vary with 

the condition of a woody draw. Tables 3.14 and 3.15 summarize tree and shrub cover and tree 

density by condition class for the surveyed woody draws.

Figure 3.6 — Decadent box elder tree with more than 100 basal sprouts that have been 

regularly browsed.

Table 3.14 — Characteristics of tree and shrub canopy cover among Healthy, At Risk, and 

Unhealthy sites

Proportion Of 

Sites with >39 

Percent Tree 

Canopy Cover

Proportion Of 

Sites with >34 

Percent Canopy 

Cover of Tall 

Shrub Layer

Average 

Chokecherry 

Canopy Cover

Average 

Western 

Snowberry 

Canopy 

Cover

Proportion of 

Sites 

Dominated by 

Grass Below 

2.5 Feet

Healthy 51 59 24 13 18

At Risk 25 7 11 21 65

Unhealthy 5 0 6 14 82

Fifty-one percent of Healthy woody draws exhibited more than 39 percent mature tree canopy 

cover, compared to 25 and 5 percent for At Risk and Unhealthy woody draws. The table shows 

that average tree canopy cover increased with increasing woody draw condition ratings. A 

similar relationship was observed among the tall shrub layer, with 59 percent of the Healthy 

woody draws exhibiting more than 34 percent canopy cover for the tall shrub layer compared to 

7 percent for At Risk and none for Unhealthy woody draws. At Risk sites exhibited the greatest 

cover of western snowberry, while Unhealthy sites contained the least amount of any shrub 

structure and the greatest degree of grass dominance in the ground layer.

As shown in Table 3.15, the average sapling density was more than four times greater among 

Healthy than At Risk or Unhealthy woody draws. Tree densities among size classes up to 5

inches dbh were at least twice as great among Healthy compared to At Risk and Unhealthy 

woody draws. Tree density among the 5- to 10- and greater than 10-inch dbh classes were 
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slightly to moderately greater among Unhealthy sites compared to Healthy and At Risk sites, but 

total tree density among Healthy sites was more than twice as great as Unhealthy and At Risk 

sites. As identified in Chapter 2 the number of saplings is key to a healthy woody draw. Without 

saplings there would be no recruitment of trees into the different tree size classes found in a 

healthy woody draw, which would eventually result in the loss of the woody draw. 

Table 3.15 — Tree density per acre by size classes among Healthy, At Risk, and Unhealthy 

sites

Tree DBH

Size Class 

(Inches)

Saplings

0-1 1-2 2-3 3-4 4-5 5-10 >10 total

Healthy

N=31 359 59 40 51 45 108 36 698

At Risk

N=44 85 12 9 14 13 77 37 247

Unhealthy

(N=10) 61 8 14 22 21 119 56 301

Topographic influences on woody draw conditions were evident, as Healthy sites were most 

frequently located along relatively inaccessible drainages with steep side slopes. At Risk and 

Unhealthy woody draws were most commonly found in relatively open drainages with low 

topographic relief. The influences of topography were also evident within individual woody 

draws that contained a relatively flat accessible drainage bottom and steep side slopes. This type 

of woody draw exhibited high livestock use and poor conditions on the flat bottomed portion of 

the woody draw, while the steep side slopes of exhibited less livestock use and better conditions.

Several drainages among all condition classes supported ephemeral or intermittent pools, fens, 

developed and undeveloped springs, dugout ponds, and beaver ponds. These water sources and 

associated woody draws tended to be heavily disturbed by livestock trampling (Figures 3.7 and 

3.8).

Figure 3.7 — (Left) Ephemeral water sources with typical livestock trampling.

Figure 3.8 — (Right) Intermittent water sources with typical livestock trampling.
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Headcuts were moderately common along several drainages, but, with few exceptions, these 

were partially vegetated and not particularly active. Wide or deep narrow headcuts, which 

hampered livestock access, were often sites of increased green ash regeneration (Figure 3.9).

Figure 3.9 — Young green ash establishing immediately downstream of a 10- to 15-foot 

headcut and the terminus of the existing woody draw.

There was evidence of poor woody draw conditions occurring among pastures with high 

proportions of invasive grasses in the uplands. This may be the result of greater use of the 

woodlands for browse and green herbaceous species when palatability of the upland grasses 

decreases. 

It was observed during field surveys that there was a general correlation between the number of 

woody draws in a pasture and their condition. As the number of woody draws increased, so did 

their condition. This is likely due to livestock effects being spread across a larger acreage and 

number of locations compared to a small number of woody draws, which tends to concentrate 

livestock use and effects.

Cooperative Monitoring Results

Of the 29 NDSU woody draw surveys conducted in 2008 and 2009, 23 were within green ash 

woody draws. Six sites were dominated by Rocky Mountain juniper and were not evaluated for 

condition classes. Based on comparisons with average measurements from the NDGF-Forest 

Service data sets and tree and shrub densities reported from other researchers (Project Record, 

Specialist Reports and Notes, Botany Report), the proportion of Healthy, At Risk, and Unhealthy 

sites among the NDSU sample sites was about 22, 65, and 13 percent, respectively. However, the 

lower proportion of Healthy woody draws among the NDSU sites is largely attributed to 

differences in sample methodology. For instance, sampling of the NDSU plots was concentrated 

along portions of the drainage bottoms where livestock disturbances are greatest. Although the 

17 long-term Forest Service/North Dakota Game & Fish (FS/NDGS) monitoring plots were also 

concentrated along the drainage bottoms, greater familiarity with the sites and/or additional 

sampling by other Forest Service surveys provided information to evaluate average conditions 

across the entire woody draw area. Thus, Healthy conditions in portions of the site had the 
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potential to compensate for At Risk or Unhealthy conditions in other portions of the site such as 

the drainage bottom. Of seven sites sampled by both the Forest Service and NDSU, three sites 

rated Healthy based on Forest Service surveys were rated At Risk when comparing the NDSU 

data with average tree density measurements from the FS/NDGF data. One site rated At Risk by 

the FS/NDGF surveys was Unhealthy based on the NDSU data. Three of the seven overlapping 

sample sites were consistently rated in both data sets.

NDSU sampling provided quantitative measurements of the herbaceous understory composition, 

and indicated that invasive grasses and primarily Kentucky bluegrass were the dominant species 

in all but three of the 23 sample sites.

Woody Draw Trend

The trend in woody draws was analyzed by reviewing average tree density and shrub canopy 

cover information and through comparison of historic and current aerial photographs. Tree-size 

class and shrub canopy cover information was obtained from 13 permanent FS/NDGF woody 

draw sample sites measured every 5 years between 1993 and 2008. Aerial photography from the 

1930s and 1953 was compared to 2009 photography to determine if woody draws had expanded 

in size.

From 1993 to 2008 the average density of all trees greater than one inch dbh decreased by about 

five percent, from 322 to 308 trees/acre. This decrease has occurred mostly in the 4-9-inch dbh 

class, while smaller and larger size classes showed slight to moderate increases in density 

(Figure 3.10). This suggests that the 4-9-inch dbh trees are progressing to larger size classes but 

are not being fully replaced by the progression of smaller diameter trees into larger size dbh 

classes. 

Duxbury (2009) found a 25 percent decrease in the density of trees greater than 1 inch dbh 

between 1988 to 2003 among sample plots across the LMNG that were situated along the 

drainage bottoms (Project Record, Specialist Reports and Notes, Botany Report). Jensen (1991) 

concluded from the 1988 data that 62 percent of the green ash woody draws were trending away 

from the potential climax community.
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Figure 3.10 — Tree density by size class among Healthy, At Risk and Unhealthy woody 

draws.

Saplings less than 1 inch dbh exhibited a decreasing trend from 826 to 305 saplings/acre between 

1993 and 2008 (Figure 3.11). Some of the decrease in the number of saplings can be accounted 

for by the progression of saplings to the next size class. The sharpest decline in sapling density 

occurred between 2003 and 2008.

Figure 3.11 — Average sapling densities between 1993 and 2008.

Canopy cover and the proportion of chokecherry and western snowberry have remained 

relatively level, with chokecherry cover ranging from about 4 to 7 percent, and western 

snowberry cover from 17 to 25 percent (Figure 3.12). 

0

5

10

15

20

25

30

35

40

45

50

1-2 2-3 3-4 4-5 5-6 6-7 7-8 8-9 9-10 10-11 11-12 12-13 13-14 14-15 15-16 16-17 17-18

Density per acre

dbh size class in inches

1993

1998

2003

2008

1993

1998

2003

2008

0

100

200

300

400

500

600

700

800

900

deciduous tree sapling

density per acre
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Figure 3.12 — Average percentage canopy cover of chokecherry and western snowberry 

between 1993 and 2008.

The SRT recommended using black-and-white aerial photographs to document historical woody 

draw trends for a variety of woody communities (SRT Recommendation VI-1). 

As previously mentioned, green ash woody draws were of greatest concern for this analysis. A 

comparison of aerial photographs from the late 1930s and 1953 with those of 2009 showed an 

estimated expansion of less than 5 percent for green ash woody draws across the project area.

There appeared to be a slight increase in canopy extent among some woody draws, while a 

smaller number of draws exhibited a decreased extent. Although field observations indicated that 

a few green ash trees were establishing within satellite shrub patches situated away from the 

primary woody draw community, there was a lack of photographic evidence of this occurrence, 

likely due to the small size of these patches. There was no evidence of woody draw expansion 

into previously unoccupied drainages. Field observations suggested greater expansion of western 

snowberry and several other shrub species compared to woody draw communities, but this 

occurrence is not readily observable from the aerial photographs. The expansion of Rocky 

Mountain juniper is apparent in photographs of some allotments, and analysis initiated by 

Bismarck State College during late 2010 to assess trends of this species should be available 

during 2011.

Although the various monitoring data are not adequate to identify a definitive trend in woody 

draw conditions within the project area, the existing data suggests two things. First there appears 

to be a downward trend in saplings, which threatens tree recruitment into the larger dbh classes. 

If this continues, the overstories of the affected woody draws would eventually thin and could

ultimately be replaced with a shrub and grass community. Second, based on aerial photography,

there appears to be minor expansion (<5 percent) in the extent of woody draw communities. 

0.0

5.0

10.0

15.0

20.0

25.0

30.0

1993 1998 2003 2008

percent canopy cover

PRVI

SYOC
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Factors Affecting Existing Condition of Woody Draws

LIVESTOCK IMPACTS

Repeated browsing and mechanical damage (trampling) of tree and shrub saplings decreases 

their vigor and inhibits advancement to later growth stages. Overstory canopy cover decreases 

when an insufficient number of young trees are available to fill canopy openings resulting from 

the death of mature trees. As the woodland structure becomes more open, livestock access 

becomes easier, thus perpetuating poor woody draw conditions. The degree of adverse livestock 

effects on woody draw conditions is a function of the frequency and intensity of disturbance. 

Several woody draw surveys and ecological assessments have been conducted in southwest 

North Dakota and adjacent regions. These surveys and assessments indicated that excessive 

livestock disturbances were the most obvious causal factor of poor woody draw conditions 

(Bjugstad and Girard 1984; Boldt et al. 1978; Butler 1983; Butler and Goetz 1984; Girard et al.

1987; Hansen et al. 1984a, 1995; Hopkins and Ryan unpublished; Jensen 1991; Lesica 1989; 

Lesica and Atthowe 2001; Nelson 1960; Severson and Boldt 1978; Uresk et al. 2009). 

Research of woody draws and riparian woodlands, as well as broader range management 

investigations of livestock distribution/utilization patterns, has consistently noted an affinity of 

livestock for woodland habitats that is disproportionate to their relatively small area across the 

landscape (Project Record, Specialist Reports and Notes, Botany Report).

Similar to observations of other studies (Butler et al. 1986, Hodorff et al. 1988, Nelson 1960, 

USDA Forest Service 2002), topography influences the level of livestock use. Adverse impacts 

from livestock in the project area were most apparent along relatively open or flat drainage 

bottoms. Thus, areas with the greatest concentration of livestock use exhibited the greatest 

departure from potential conditions compared to areas with less livestock use, providing further 

evidence of livestock induced impacts.

FIRES

Fire can have both positive and negative effects on woody draws, and it is possible that 

successful wildfire suppression for more than 100 years has allowed some woody draw 

expansion, while also contributing to the eventual stagnation or deterioration of other woody 

draws. Fire can invigorate woody species regeneration through removal of accumulated litter 

layers and improvement of seedbed conditions; promotion of vegetative sprouting from burned 

woody plants; increased nutrient availability that promotes a flush of new growth; and disruption 

of pest, parasite, and disease cycles (Clark 2006, Fitzpatrick 2003, Sieg and Wright 1996,

Zimmerman 1981). The population age structure of some woody draws in the project area 

suggests an episodic occurrence of stand establishment, such as would occur from a flush of 

regeneration after fire or other severe disturbance followed by a period of low disturbance that 

allowed seedlings and saplings to become established.

Conversely, historical wildfire frequencies are generally believed to have inhibited development 

of woodland communities on the grassland landscapes (Baily 1976, Grant and Murphy 2005,

Higgins et al. 1989, Towne and Owensby 1984). There is evidence that several types of woody 
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communities have been increasing on the LMNG where intensive wildfire suppression efforts 

have occurred ever since Euro-American settlement. Lesica (2001b) concluded that the overall 

affect of late summer wildfires on woody draws in eastern Montana was negative. Although 

many burned shrubs and trees resprouted, the total woody population was decreased by the 

complete death of a large number of mature trees that did not resprout. Wildfire control on the 

LMNG has likely led to an increase in the extent of Rocky Mountain juniper in the project area;

however, a comparison of historical and current aerial photography indicates that expansion of 

green ash woody draw communities in the project area has been less than 5 percent. 

DISEASE AND INSECTS

Several different fungi infest green ash trees and hasten the death of older trees when they are 

less resistant or capable of withstanding infections (Lesica 2001a, Lesica and Anthowe 2001).

Many of the sampled stands had mature green ash trees infected by fungus, in particular heart-rot 

(Fomes fraxinophilus), which is evidenced by white fruiting bodies on the outside of the tree. 

This fungus weakens the tree, making it susceptible to breakage, and hastens mortality. 

A common codominant tree in the green ash draws is the American elm. The presence of Dutch 

elm and other diseases is having an adverse effect on elm trees on the LMNG. Currently diseases 

have severely impacted the mature American elm in the green ash woody draws on the LMNG. 

However, as American elm is usually a subordinate species and is often absent from woody 

draws occurring at the drier end of the habitat range, the effect of potentially extirpated 

American elm would be less severe than the loss of green ash. 

A potential future threat to the green ash draws is an exotic beetle known as the emerald ash 

borer (Agrilus planipennis). The emerald ash borer (EAB) is native to Asia and may have arrived 

in the United States via wood packing material. Since its discovery in southeastern Michigan in 

2002, the borer has spread in all cardinal directions. Its westward expansion currently includes 

Wisconsin, Minnesota, Missouri, and Iowa. The EMB is a threat to all ash tree species but seems 

to favor green ash trees. The larvae bore into the tree, where they chew the inner bark and 

phloem, creating winding galleries as they feed. This cuts off the flow of water and nutrients in 

the tree, causing dieback and death. There is currently no effective large-scale treatment to 

control the EAB. Insecticides are being used in municipalities, by property managers, and by 

homeowners. 

CLIMATIC EFFECTS

Severe winters, late spring and early summer frosts, and extended drought can adversely affect 

trees and shrubs. Overnight temperatures of 24 degrees have been observed in mid June on the 

Medora Ranger District after recent leaf emergence of green ash, which is one of the last tree 

species to initiate new growth in the spring. The majority of emerged leaves died in this 

situation; however, they were replaced by new leaves, and growth was sustained during the 

remainder of the summer. Extended drought can increase the mortality of woody species. Tree 

mortality as high as 50 percent was measured toward the end of severe drought during the 1930s

(Albertson and Weaver 1945). Both late-season frosts and drought are frequent in the northern 

Great Plains (HPRCC 2009), and the presence of woody draws attests to adaptation of these 
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146 | Chapter 3

communities to the climate. While these climatic factors do affect woody draws, there is no 

indication that the current condition of the woody draws has been significantly affected by 

drought or early season frosts. 

WILDLIFE

A comment received on the DEIS indicated that the effects of wildlife on woody draws had not 

been addressed. Although information was provided in the DEIS, additional detailed information 

has been added to the SDEIS and finally the FEIS in response to this comment.

The 2008 NDGF surveys from Magpie Creek cite mule deer densities of approximately 8.5 

deer/square mile during 2007 and 2008, and about 4.1 deer/square mile from 1991 to 2007 

(Project Record, Specialist Reports and Notes, Botany Report). A good portion of the Magpie 

Creek drainage is located in the project area. In terms of forage utilization, approximately five 

mule deer are equivalent to one mature cow in the amount of forage consumed (NRCS 1997). 

Gubanyi, et al. (2008) found whitetail deer densities of about 70 deer/ square mile caused 

adverse impacts to vegetation structure and species composition of woodland communities in 

southeast Nebraska. Deer populations in the project area are well below those densities. A 12-

year study (Irby et al. 2000) conducted in nearby Theodore Roosevelt National Park (TRNP)

indicated that browsing by deer and elk had minimal impact on chokecherry, serviceberry, and 

green ash populations, which are major components of green ash woody draws. 

Deer trails observed in woody draws in the project area indicate that they were relatively narrow 

(<12 inches) and partially vegetated. These trails were most frequent in high condition woody 

draws that provided the greatest structure. Bedding sites in the woody draws tended to be small 

in size, with flattened vegetation. In contrast, livestock trails observed in the project area tended 

to involve multiple intertwining paths of compacted bare ground with dense and deep hoof 

prints. Down cutting often occurred along the livestock trails. Communal livestock lounging 

areas were evidenced by damage to woody and herbaceous vegetation or by large areas of bare 

ground caused by trampling.

The late 1880s saw the extirpation of elk in the badlands. In March 1985, 47 elk were released 

into the South Unit of TRNP. This release is the foundation of the current badlands elk 

population.

In 2003 and 2004, TRNP tracked 70 radio-collared elk to determine their movement patterns. 

The research noted that 59 and 71 percent, respectively, of the tracked elk left TRNP annually. 

Of the elk that left TRNP, most (90 percent) remained within 12 to 16 miles of the South Unit of 

TRNP in the Grassy Butte and Kendley Plateau areas (2010 TRNP Elk Management Plan FEIS, 

p.139). Both of these areas are outside of the project area. The FEIS also notes that 50 percent of 

the elk were located on federal and state lands and 50 percent on private lands in the above areas. 

TRNP estimates that approximately 1000 +/- 250 elk currently reside in the South Unit of TRNP 

(2010 Elk Management Plan FEIS, Attachment 1). Applying the higher of the 2003 and 2004 

percentages (71 percent) to the estimated elk population would mean that 533 to 888 elk leave 

TRNP, typically from April to November, and that 480 to 799 (90 percent) of those elk stay in 
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the Grassy Butte and Kendley Plateau areas. This means that approximately 53 to 89 elk may be 

utilizing the project area from April to October/November. The project area is approximately 136 

square miles (87,262 acres) in size, which equates to one elk per 1.5 to 2.6 square miles of NFS 

lands. There may be additional elk utilizing NFS lands year-round; however, there is no 

information available concerning that possibility. 

Another big game animal found in the project area is bighorn sheep, which occur in the 

northwestern portion of the project area (Wiedmann, personal communication, 2007). The 

bighorn sheep population in the project area is estimated by the NDGF at approximately 40 

animals. 

It is acknowledged that big game (deer, elk, bighorn sheep) do utilize the project area, including 

the woody draws; however, their use appears to be light. This is supported by the above 

population information, studies, and observations of woody draws in the project area. This,

compared to livestock numbers of approximately 200-300 head of livestock per square mile for 

periods ranging from 1 to 8 months, indicates that a majority of impacts (such as trampling, 

browsing, loafing, trailing, etc.) to the green ash woody draws are the result of livestock actions.

Beaver can also adversely affect woodland communities of certain species, but this was usually 

confined to inclusions of quaking aspen at a few sites in the project area. Quaking aspen readily 

resprout after being cut by beaver and their regrowth is a favored browse for many wildlife 

species. 

It is important to note that adverse impacts, such as Dutch elm and other diseases,

invasive/noxious weeds, and beaver-cut trees were not used in evaluating the condition of woody 

draws or in assigning condition ratings.

SUMMARY

About 51 percent of the sampled woody draws were rated Healthy, while 42 percent were rated 

At Risk and 7 percent were rated Unhealthy. Healthy communities exhibited a diverse range of 

tree-size classes and tall shrub layers. Shrub species were generally diverse with multiple or, at 

least, tall height classes and densities that tended to impair movement through the community. At

Risk and Unhealthy woody draws exhibited a lack of successful tree regeneration as indicated by 

the relative absence of saplings and young trees in the lower size (dbh) classes. Shrub layers 

among these communities tended to be patchy and/or dominated by low statured western 

snowberry. A dense grass layer, usually dominated by Kentucky bluegrass, occurred throughout

most At Risk and Unhealthy woody draws. Without an extensive investment in resources, such 

as fencing, planting, etc., many of the Unhealthy rated communities will continue deteriorating 

and will eventually be replaced by low shrub/grass communities with scattered patches of 

desirable shrubs and trees on poorly accessible microsites. Because of easy access by livestock, 

At Risk communities located on relatively gentle terrain along drainages have a similar potential 

to be replaced by shrub/grass communities. The steeper slopes in At Risk woody draws are less 

impacted because livestock generally favor gentler slopes. 
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DESIRED CONDITION

The desired condition for woody draw communities in this project area is to maintain or develop 

a multi-layer and multi-age class of herbaceous plants, shrubs, and trees, moving At Risk and 

Unhealthy woody draws towards self-perpetuating plant communities that exhibit thick brushy 

shrub understories and a multi-story, multi-age structure of the tree canopy, according to site 

capability.

Capability

A comment received on the DEIS indicated that the Grasslands Plan needed to be amended prior 

to undertaking this project because the Grasslands Plans direction was unattainable. This would 

include desired conditions for woody draws. Woody draw surveys and field observations do not 

support this comment.

Although specific site characteristics can influence the species composition and production of a 

woody draw community, as well as its resistance and resiliency to disturbance, there is ample 

evidence that environmental conditions are capable of supporting desired woody draw 

communities with sufficiently decreased levels of disturbance. For example, steep slopes of 

many woody draw sites are in a Healthy condition, while the bottom of the drainage with 

increased livestock trailing and lounging are At Risk. Although the slope aspects contribute to 

decreased temperatures and evaporation demand that can assist the establishment of woody 

species, the bottom of the drainages also experience a degree of shading, contain greater soil 

depths, and receive greater moisture and nutrient inputs from the adjacent slopes. Therefore, tree 

and shrub growth and general conditions should be greatest along the drainage bottoms rather 

than the slopes, and the relative degree of livestock use in these two habitats is the likely source 

of differing conditions.

Other evidences of the capability of woody draws to attain desired conditions include the fact 

that 51 percent of the surveyed woody draws in the project area are rated as Healthy. 

Additionally, two woody draw exclosures located in Allotment 240, and one located 

approximately 5 miles south of the project area near Franks Creek, as well as fenceline contrasts 

with different levels of livestock use, show that the Desired Condition for woody draws 

identified by the Grasslands Plan is attainable (Project Record, Specialist Reports and Notes, 

Botany Report). 

Environmental Consequences—Woody Draws

DIRECT AND INDIRECT EFFECTS 

ALTERNATIVE 1

All grazing would be limited to native wildlife under the no-grazing alternative. In many 

respects, the termination of livestock grazing would contribute to improved ecological conditions 
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of many woody draws through decreased browsing and trampling. Reproductive success, 

density, and canopy cover of desirable woody species would increase, with the greatest increases 

likely to occur along relatively broad and level drainage bottoms where livestock concentrations 

have exerted the greatest negative effect.

Invasive Kentucky bluegrass and lesser amounts of smooth brome are well-established within 

most woody draws and have a high potential to continue spreading without livestock 

disturbances. The removal of livestock grazing could have negative consequences, in that nonharvest of the herbaceous layer would result in increased litter accumulation, which can assist 

invasive grass establishment and impair the establishment of woody species seedlings. In time, 

the dynamics of both the woody and herbaceous layers could stagnate within many woody 

communities without periodic disturbance. 

The termination of livestock grazing would result in improved woody draw conditions as 

expressed through increased woody plant regeneration and density over the time frame of this 

analysis. With continued non-use, woody draw dynamics would possibly decrease unless natural 

ecosystem processes of fire, erosion, flooding, and ungulate grazing occur at sufficient intensity 

and frequency to facilitate dynamics of the system. Invasive grasses and accumulated litter may 

hamper the recovery of woody draws improvement. 

ALTERNATIVE 2

Amenities of shade, thermal cover, extended herbaceous green periods, woody browse species, 

and water developments are strong attractants for livestock, and a level of adverse impact 

resulting from their congregation within woody draws should be expected (Bailey 2004, Porath 

et al. 2002). The severity of impact is correlated with the intensity and frequency of livestock use 

that is influenced by stocking levels, the length and season of grazing, the amount or proportion 

of woody draws occurring in a pasture, and production and composition of the adjacent 

rangeland.

The low amount of tree regeneration and sparse or absent shrub layers resulting from observed 

livestock trampling, trailing, browsing, lounging, etc., would continue in At Risk and Unhealthy 

woody draws because the current intensity, duration, and timing of livestock use would be 

maintained. In the At Risk and Unhealthy woody draws, existing Authorized Use levels would 

continue to contribute to excessive use of woody draw communities. Annual use of every 

pasture, often at the same or similar times of the year, is also a factor contributing to poor 

conditions among many sites.

Some adverse impacts to woody draws occur from wildlife, climate extremes, and disease;

however, as noted previously, these are not the primary factors influencing the conditions of the 

woody draws. 

For the above reasons, the 49 percent of sampled woody draws rated as At Risk or Unhealthy 

would continue in these conditions. 
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150 | Chapter 3

ALTERNATIVE 3

Under this alternative, a series of different livestock management techniques are utilized to 

address concerns with At Risk and some Unhealthy woody draws. Proposed actions include 

relocating water tanks out of woody draws where feasible, fencing or controlling access of some 

water structures to manage livestock distribution, creating new water sources located to pull 

livestock away from woody draws, fencing individual woody draws to limit livestock access, and 

implementing or changing existing rotations to affect the amount of time or season of use that 

livestock have access to woody draws. This alternative is adaptive-management-based. 

A summary of the effects of initial actions by allotment is presented in Table 3.16. Also provided 

is a short synopsis of the reasoning for the effects determination. A detailed discussion of each 

allotment is contained in Part 2 of this chapter. 

Table 3.16 — Summary of effects rationale by allotment for woody draws, Alternative 3

Allotment

Number

Woody Draw 

Conditions 

Met

Initial Actions

Effect Rationale

126 No Slightly 

positive

Fence springs and/or add new water sources. 

Separating pastures 5 and 6 could decrease the use 

of some draws. AU 30% < CC and > reported use, 

but additional winter use.

127 Yes Neutral Delay turn-in 2 weeks but same management and 

effects. AU 37% > CC and 15-42% > reported use. 

128 No Neutral

Management of some water tanks to control 

distribution, stabilize Whitetail Creek. AU 56% > 

CC and 17-58% > reported use. 

129 No Neutral

Create riparian pasture. Exchange pastures with 

A131 increases proportion of Healthy draws but 

increased summer use/disturbances. AU 17% < CC 

and 7-31% > reported use including winter use. 

130 No Negative

Increased summer use of P1 and P7 with increased 

woody draw disturbances. Adverse effects of hay 

feeding introduced to P6. AU 8% >CC and < to > 

reported use.

131 No Slightly 

negative

Exchanging pastures with A129 decreases 

proportion of Healthy draws and new hay feeding 

pasture. Reclamation of one reservoir with adverse

effects to riparian trees. AU 41% < CC, but 

recently reported use 27-54% > AU not including 

additional winter use.

132H No Neutral

Increased deferred rotation with new water tank –

decresed period of access to woody draw but 

increased livestock density. AU 5% > CC, 15% < 

to 24% > reported use.

133 No Neutral

More consistent 2-pasture deferred rotation but 

increased livestock density and AU similar to 

reported use that is 58% > CC. 

134 No Neutral Similar management & AU usually 19-26% > 

reported use.
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Chapter 3 | 151

Allotment

Number

Woody Draw 

Conditions 

Met

Initial Actions

Effect Rationale

135 Yes Neutral

Positive and negative effects of burning juniper, 

otherwise no appreciable change in management. 

AU > to < reported use and additional winter use. 

136/139 No Neutral Shorter early season use of 136-1, but increased use 

of 136-2. AU 46% > CC and 9-36% > reported use.

140 No Negative Increase of mid and late summer use, AU 36% 

>CC and 0-39% > reported use.

142 No Neutral No appreciable change in woody draw pasture, 

AU 50% > CC and 17-92% > reported use. 

158 No Neutral

No appreciable change in management. AU 18% > 

CC and much > reported use but additional winter 

use. 

221 No Neutral Earlier turn-off of affected pastures, but AU 63% > 

CC and about 5% > reported use. 

230 No Neutral

Shortened season of P1 but increased livestock 

density, halt winter use in P3 but potential for 

increased disturbances with summer grazing 

season. AU 17% > CC and 30-60% > reported use

not including winter use. 

237 No Negative

Increased disturbance in P1 with additional water 

tank, and in P2 with deferred rotation, AU 32% > 

CC and 40-55% > reported use. 

239 No Neutral

Decreased period of woody draw access but 

increased livestock density with smaller pastures. 

Low invasive grass palatability in uplands. AU

64% > CC and 32-85% > reported use. 

240 No Slightly 

positive

Potential reclamation of two reservoirs w/adjacent 

woody draws. Reported use 2-32% > AU not 

including winter use.

241 No Neutral

No appreciable change in management. AU 16% > 

CC and much > reported use but additional winter 

use.

243 No Negative

New water tank would increase use of draws, same 

grazing system and reported use slightly > AU that 

is 24% > CC.

244 No Neutral

Some increased woody draw disturbance in new 

pasture but unchanged use in other pastures.

Reported use slightly >AU that is 12% > CC.

249 Yes Neutral Staggered season would minimally affect woody 

draw use and Reported use = AU that is 21% > CC.

256 No Slightly 

positive

Fence reservoir and draw in P2. Create riparian 

pasture in P2 but increased livestock density in 

remainder of pasture. Same grazing system in P1 & 

P3. AU 9% > CC and usually > reported use. 

258 Yes Neutral

No appreciable change in grazing system, 3-acre 

riparian exclosure in P1. AU 41% > CC and at least 

45% > reported use.

272 No Positive

Fence woody draw in P2, reclaim reservoir and 

construct new tank further from draws. AU & 

reported use 15% > CC.
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152 | Chapter 3

Allotment

Number

Woody Draw 

Conditions 

Met

Initial Actions

Effect Rationale

277 No Slightly 

positive

Fence one reservoir w/adjacent small woody draw 

patches. AU and reported use including winter use

close to CC.

278 No Slightly 

positive

Increased early season use and cease twice-over 

use, but only two draws and near water. AU 36% > 

CC and 10-27% > reported use. 

281 No Slightly 

positive

New water source outside of draw in P1 but only 1-

2 draws present in any pasture. AU 26% > CC.

282 Yes Neutral

No appreciable change in management but 

relocating pasture fenceline would increase 

disturbances in portion of one pasture. AU 15% < 

CC and 24-44% > reported summer use, and 10-

30% > total annual use including winter use. 

283 Yes Slightly 

positive

New water tank would decrease use of seeps along 

woody draws. AU approximately = CC. 

286 No Slightly 

positive

Deferred rotation with decreased access to the only 

woody draw but increased livestock density. AU 

36% > CC and usually much > reported use.

287 No Neutral

Greater deferment of two main pastures but tank 

control unlikely to change livestock distribution.

AU 15% > CC and 17-25% > typically reported 

use.

288 No Slightly 

positive

Compressed season and deferred rotation but 

increased livestock density. Tank management 

could improve surrounding draws. AU 43% > CC 

and 23-29 > recently reported use.

289 No Negative

Two new tanks with potential to decrease 

conditions. Creating new pasture likely to decrease

conditions in two pastures. AU 10% > CC, reported 

use often > AU and additional winter use. 

300 No Slightly 

positive

Decreased disturbance in one woody draw after 

fencing developed spring and constructing upland 

well and water tank. AU 7% > CC and 4-15% > 

reported use.

301 No Neutral

Reconstructing two spring developments would 

control livestock distribution but several other 

water sources would remain uncontrolled. Creation 

of 4th pasture would increase woody draw 

disturbance in secondary range. AU 10% > CC, 0-

20% > recent use. 

302 No Slightly 

positive

Fencing 3 reservoirs would increase control of 

livestock distribution. AU 14% > CC and 0-66% > 

reported use. 

A=Allotment, P=Pasture, AU=Authorized Use, CC=initial estimated carrying capacity,

> = greater than, < = less than.

Collective initial actions under Alternative 3 would result in improved woody draw conditions in 

11 of the 32 allotments that contained woody draws not meeting desired conditions. Of the 11

allotments, 11 are projected to show slight improvement and one would show marked 
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improvement. Slightly positive improvements would have a low potential to shift a large portion 

of woody draws from At Risk to Healthy condition. Of the remaining 21 allotments, six would 

experience decreased woody draw conditions and 15 would maintain their conditions. 

The most commonly identified tools for improving woody draw conditions include removing or 

decreasing livestock disturbances through fencing, decreasing the length of time that livestock 

have access to draws by shortening the grazing period, changing the grazing season to periods of 

cooler temperatures and increased forage palatability, managing stock tanks to affect livestock 

distribution, and replacing water sources along woody draws with upland tank sites. Fencing of 

woody draws or riparian exclosures has beneficial and adverse effects. It removes disturbance 

associated with livestock and provides the opportunity for rapid recovery of shrub and tree 

regeneration. However, potential adverse effects include increased spreading and dominance of 

existing invasive grasses and associated litter that can impede the regeneration of desired woody 

species. Fencing may also result in increased use of adjacent woody draws. The option for 

removing fences and and/or halting fence projects exists if desired results are not obtained.

Initial actions resulting in neutral effects to woody draw conditions would occur in 14 allotments 

that do not currently meet desired conditions for woody draws. Six allotments would experience 

a decline in the health of woody draws.

Initial actions in five of six allotments that meet desired conditions would have a neutral effect 

and one allotment would experience a slightly positive effect.

The most frequent adaptive management options that would contribute to improved woody draw 

conditions include the use of fencing and adjustments (decreases) in Authorized Use. Changes in 

grazing rotations, creation of riparian pastures, development of new water sources, water 

management, and prescribed burning also have the potential to improve woody draw conditions. 

These actions can be used singularly or in combination to address woody draw concerns.

Implementation of the above actions singularly or in combination would improve the condition 

of impacted woody draws. The key is when these actions are initiated. If these actions are not 

implemented until the middle of the timeframe (10 to 15 years) associated with this project due 

to monitoring timeframes, the opportunity to bring At Risk woody draws to a Healthy condition 

in the remaining time is reduced as is the ability to improve the health of Unhealthy woody 

draws.

ALTERNATIVE 3A

Alternative 3A is the same as Alternative 3 with several exceptions, which are identified in the 

description of Alternative 3A in Chapter 2. Table 3.17 identifies 14 allotments where initial or 

adaptive action(s) were changed to create this alternative. Of the 14 allotments, three are meeting 

desired condition and initial actions would have a neutral effect. Of the remaining 11, initial 

actions would have a neutral effect on woody draws within five of the allotments and a negative 

effect on conditions in four allotments. Two allotments would experience slightly positive effects 

that are unlikely to shift conditions from At Risk to Healthy. Because Alternative 3A would 

improve fewer woody draws than Alternative 3, it would decrease the overall percentage of 
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Healthy woody draws in the project area compared to Alternative 3. The detailed effects for each 

allotment are identified in Part 2 of this chapter. 
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Table 3.17 — Summary of effects rationale by allotment for woody draws, Alternative 3A

Allotment 

Number

Woody 

Draw 

Conditions 

Met

Initial Actions

Effect Rationale

126 No Slightly 

positive

Adding two new water sources without 

fencing developed springs would not 

appreciably change effects.

127 Yes Neutral

Create waterlot for access from both 

pastures but steep slopes limit use of 

draw, same grazing system and AU.

129 No Slightly 

negative

Create riparian pasture but adding 2nd 

tank in P2 (now part of A131) would 

increase disturbance in small woody draw 

patches. Exchanging pastures with A131 

increases proportion of Healthy draws but 

increased summer use/disturbance. AU 

17% < CC and 7-31% > reported use 

including winter use. 

135 Yes Neutral

Adding water tank in P10 would not 

affect woody draws. Positive and negative 

effects of burning juniper. AU 16% < CC 

and 27% > to 16% < reported use not 

including winter use.

142 No Neutral

Shorter duration but increased livestock 

density in woody draw pastures, AU 50% 

> CC and 17-92% > reported use.

240 No Neutral

New water tank but two reservoirs near 

woody draws would not be reclaimed. AU 

6% > CC, reported use 2-32% > AU not 

including additional winter use.

243 No Negative

Spring development with no effect on 

woody draws, but other new water tank 

would increase disturbance in draws. 

Reported use slightly > AU that is 24% > 

CC.

244 No Neutral

No appreciable change in management.

Reported use slightly > AU that is 12% > 

CC.
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Allotment 

Number

Woody 

Draw 

Conditions 

Met

Initial Actions

Effect Rationale

258 Yes Neutral

May rather than June turn-in would have 

minimal effect on woody draws. 3-acre 

riparian exclosure, but new water tank.

AU 41% > CC and at least 45% > 

reported use.

272 No Negative

Develop spring at north end of Unhealthy 

woody draw would contribute to 

additional impacts. Not fencing any 

draws. AU and reported use 15% > CC.

278 No Slightly 

positive

Increased early season use and cease 

twice-over rotation. Not reclaiming 

reservoir would minimally affect woody 

draw due to another adjacent water 

source. AU 36% > CC and 10-27%> 

reported use.

287 No Slightly 

negative

Increased disturbance around new water 

tank in secondary range. Greater 

deferment of two main pastures but tank 

management unlikely to decrease current 

disturbances. AU 15% >CC and 17-25% 

> typically reported use.

300 No Neutral

Continued unmanaged access to a 

developed spring in an At Risk woody 

draw would be only slightly reduced by a 

new well and upland water tank. AU 7% 

> CC and 5-15% > reported use.

301 No Neutral

Access to reconstructed springs would 

remain unmanaged with persisting woody 

draw disturbances. AU 10% > CC and 1% 

> to 20% < recently reported use.

A=Allotment, P=Pasture, AU=Authorized Use, CC=initial estimated carrying capacity,

> = greater than, < = less than.

Actions contributing to adverse effects on woody draw conditions include relocating several 

spring-fed water tanks without reconstructing the plumbing system to maintain flow at the spring 

when the tank is full. This would result in decreased conditions of the wetland habitat and 

minimize potential improvement of adjacent woody draws because it would not be possible to 

manage water flow to control livestock distribution and limit the degree of woody draw 

disturbances. Initial actions that include the construction of additional water sources, including 

the development of one spring, would adversely affect woody draw conditions in other 
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allotments by increasing the level of disturbances. Not fencing woody draws, as proposed under 

Alternative 3, would decrease the number of allotments with positive effects from the initial 

actions.

The effects of adaptive management are the same as those identified under Alternative 3.

ALTERNATIVE 4

Alternative 4 is similar to Alternative 3 in the use of management tools such as implementation 

or changes in rotations, but it does not utilize range infrastructure to the extent of Alternative 3. 

In addition to these actions, Alternative 4 includes adjustments in Authorized Use based on 

carrying capacity and an adjustment for livestock weight. This alternative is also adaptive 

management based.

A summary of the effects of initial actions by allotment is presented in Table 3.18. Also provided 

is a short synopsis of the reasoning for the effects determination. A detailed discussion of each 

allotment is contained in Part 2 of this chapter. 

Table 3.18 — Summary of effects rationale by allotment for woody draws, Alternative 4

Allotment 

Number

Woody Draw 

Conditions 

Met

Initial Actions

Effect Rationale

126 No Negative

AU increased 42%. 36-107% > reported use not 

including additional winter use. Greater pasture 

deferment and once rather than multiple pasture 

rotations, but increased livestock density with 

combined herds, more consistent use of some 

pastures.

127 Yes Neutral AU decreased 27%, 3% > to 16% < than 

reported use.

128 No Positive

AU decreased 36%, 0-25% < reported use.

Greater pasture deferment with one rather than 

multiple rotations, but increased livestock 

density with tank management to control 

distribution.

129 No Neutral

Construct two riparian pastures. AU decreased 

13%, 7% < to 14% > reported use including 

winter use. New water tank would increase 

disturbances.

130 No Neutral

New rotation in P8 & P9 with decreased 

disturbance, but increased summer use and 

disturbance in P1 and P7. AU decreased 7%, < 

reported use including winter use. Adverse 

effects of hay feeding introduced to P6.

131 No Neutral

AU decreased 13% but reported use has been 

27-54% > current AU not including additional 

winter use. Hay feeding introduced to new 

pasture. Pasture exchange with A129 decreases 

proportion of Healthy draws.
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Allotment 

Number

Woody Draw 

Conditions 

Met

Initial Actions

Effect Rationale

132H No Neutral

AU decreased 5%, 19% < to 18% > reported 

use. No appreciable change in current 

management and only one draw present.

133 No Positive AU decreased 37%. More consistent deferred 

rotation.

134 No Slightly 

positive

AU decreased 25%, 5-11% < reported use,

topography main influence on woody draw 

condition.

135 Yes Positive

AU decreased 13%, 10% > to 27% < reported 

use not including winter use. Switch to 5-

pasture deferred rotation with combined herd. 

Riparian exclosures. Positive and negative 

effects of juniper control. 

136/139 No Slightly 

positive

AU decreased 32%, 7-25% < reported use.

New rotation with positive effects in one 

pasture and negative in another.

140 No Slightly 

positive

AU decreased 27%, 0-28% < reported use.

Increased mid to late summer use with 

increased disturbance potential.

142 No Neutral

AU decreased 33%, 22% < to 28% > reported 

use. Switch to deferred rotation but similar 

woody draw effects.

158 No Neutral AU decreased 15%, 21-65%> reported use with 

additional winter use.

221 No Slightly 

positive

AU decreased 38%, about 35% < reported use, 

but increased late season use of invasive grass / 

woody draw pastures, scarce draws.

230 No Neutral 

AU decreased 14% but 11% > typically 

reported use not including winter use. Halt 

winter use but potential of increased woody 

draw disturbances. Shortened season of P1 but 

increased livestock density. 

237 No Slightly 

negative

AU decreased 24%, 6-17% > reported use.

Deferred rotation in P2 has potential for 

increased disturbance.

239 No Positive

AU decreased 39%, 19% < to 13% > typically 

reported use. Decreased access to woody draws 

with deferred rotation but increased livestock 

density.

240 No Slightly 

positive

AU decreased 6% but additional winter use.

Potential reclamation of two reservoirs with 

adjacent woody draws but they are the only 

draws present.

241 No Slightly 

positive

AU decreased 14% but > reported use. Fence 

woody draws. Winter use in pasture containing 

most draws.
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Allotment 

Number

Woody Draw 

Conditions 

Met

Initial Actions

Effect Rationale

243 No Positive AU decreased 20%, fence woody draw(s).

244 No Slightly 

positive

AU decreased 11%. Some increased woody 

draw disturbance in new pasture, minimally 

changed management effects in remaining 

pastures.

249 Yes Positive AU decreased 17%. Staggered season of annual 

use.

256 No Slightly 

positive

Fence reservoir and draw in P2. Create two 

riparian pastures, but increased livestock 

density/disturbance in south half of P2. AU 

decreased 8% but much > reported use for most 

years.

258 Yes Neutral AU decreased 29% but 3-55% > reported use.

Construct three acre riparian exclosure.

272 No Positive

AU decreased 13%. Fence 1 of 2 woody draws 

in allotment. Construct tank further from draws 

but reservoir near draws not reclaimed.

277 No Slightly 

positive

AU decreased 4%, 4-11% < total annual use 

including winter use. Fence one reservoir 

w/adjacent small woody draw patches. 

278 No Slightly 

positive

AU decreased 26%, 6-19% < reported use, but 

only two woody draws present. Increased early 

season use and cease twice-over rotation.

Minimal effect of not reclaiming reservoir due 

to proximity of other water.

281 No Slightly 

positive

AU decreased 20%. Develop water source in 

pasture 1 away from draws but low number of 

draws present in all pastures.

282 Yes slightly 

positive

Construct large riparian exclosure/pasture. AU 

decreased 13%, 13% > to 4% < than total 

annual use including winter use. Potentially 

increased disturbance in localized draws from 

relocating fenceline.

283 Yes Slightly 

positive

New water tank could alleviate some use of 

seeps along woody draws. No significant 

change in AU.

286 No Neutral

AU decreased 26% but 15-67% > reported use.

Deferred rotation decreases period of woody 

draw access but increased livestock density, 

only one draw present extending through two 

pastures.

287 No Slightly 

positive

AU decreased 13%, 1-8% > typically reported 

use. Limited effectiveness of greater deferment 

of two main pastures and tank management. 
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160 | Chapter 3

Allotment 

Number

Woody Draw 

Conditions 

Met

Initial Actions

Effect Rationale

288 No Slightly 

positive

AU decreased 30%, 9-47% < reported use (9-

14% most years). Management of north water 

tank would improve surrounding draws.

Compressed season and deferred rotation but 

increased livestock density.

289 No Negative

AU decreased 9%, 9% > to 15% typically

reported use not including additional winter 

use. Two new tanks with potential to decrease 

conditions. Tank management in P3 unlikely to 

improve conditions. Creating new pasture and 

rotation likely to decrease conditions in two 

pastures.

300 No Slightly

positive

AU decreased 6%, 2% < to 8% > reported use.

Fencing/reclaiming spring and constructing 

upland tank would decrease disturbance in one 

draw. Removing alleyway fence would disperse 

disturbances but decrease potentially Healthy 

conditions in alleyway.

301 No Slightly 

positive

AU decreased 9%, 9% > to 10% < reported use.

Reconstructing two spring developments with 

increased control of livestock distribution but 

several other water sources would remain 

uncontrolled.

302 No Slightly 

positive

AU decreased 12%, 45% > to 12% < typically 

reported use. Fencing of 3 reservoirs and 

managing access along with a water tank could 

decrease use of adjacent woody draws.

A=Allotment, P=Pasture, AU=Authorized Use, CC=initial estimated carrying capacity,> = greater than, 

< = less than.

Collectively, the initial actions under Alternative 4 would contribute to improved conditions in 

21 of the 32 allotments that do not meet woody draw desired conditions (Table 3.18). The degree 

of improvement would be relatively high in 3 allotments and relatively low in 18 allotments. Of 

the remaining 11 allotments, 4 would experience a decrease in woody draw conditions and 7 

would maintain current conditions. The net effect of proposed actions are predicted to increase 

the proportion of Healthy woody draws to about 60 percent, but decreasing conditions in 4 

allotments could decrease this value to 58 percent.

Initial actions would have negative effects on four allotments. Factors contributing to negative 

effects involve a substantial increase in Authorized Use for one allotment proposed to be 

combined with another allotment. The construction of new water tanks, decreases in pasture size 

as a result of splitting pastures, increased livestock density, increased mid to late summer use, 

and additional winter use not accounted in Authorized Use also contribute to negative or neutral 

effects on woody draw conditions among some allotments. Fencing of woody draws or riparian 

exclosures has the same beneficial and adverse effects as identified in Alternative 3.
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Among the six allotments currently meeting woody draw objectives, two would experience 

slightly positive effects, two would experience a high degree of positive effects, and two would 

be neutral. Improvements in woody draw conditions are associated with decreases in Authorized 

Use, fencing, development of range water outside of woody draws, increased management of 

water access, and the creation of riparian exclosures/pastures.

The adaptive management options under Alternative 4 are the same as those in Alternatives 3 

and 3A. The difference among these alternatives is associated with the rate of change. Because 

Alternative 4 initially takes more aggressive action through reductions in Authorized Use and 

fencing to address impacted woody draws and other resource concerns, less time would be 

needed to further improve affected woody draws if monitoring indicated additional management 

changes were needed. 

CUMULATIVE EFFECTS 

Cumulative effects result from the combination of effects resulting from past, present, and 

reasonably foreseeable actions plus the direct and indirect effects of the alternatives. A 

discussion of past and present actions, reasonably foreseeable actions, and a summary of the

cumulative effects by alternative follows.

Past and Present Actions

The following past and present actions have contributed to the existing At-Risk and Unhealthy 

woody draws in the project area.

Livestock grazing has affected, and continues to affect, woody draws in the project area. In the 

past the effects of livestock grazing, in combination with climatic events (such as drought) and 

the homesteading use of the woody draws for building materials, fuel wood, and fodder,

adversely affected many of the woody draws. The effects of the homesteading era have largely 

disappeared; however, the effects of livestock grazing, including trampling, trailing, lounging, 

browsing, etc., on woody draws continue. Livestock actions have adversely affected 49 percent 

of the surveyed woody draws in the project area. 

Firewood harvest has been gradually increasing on the Medora Ranger District in recent years, 

with a currently reported annual harvest of about 400 cords (Felchle 2009). Only dead and down 

material is permitted for harvest, but some cutting of standing dead trees does occur (Forest 

Service botanist, personal observation). Removal of standing and down trees assists in opening 

woody draw sites, which potentially facilitates increased livestock access and removes safe sites 

for seedling/sapling establishment. Also, more sunlight reaches the woodland floor, increasing

evapotranspiration, which can decrease the success of woody species establishment. However,

these effects are unlikely to have had a large influence on woody draw conditions across the 

project area because of the limited amount of harvest.

Oil and gas development has, in the past, affected woody draws through construction of access 

roads or well pads. Under present oil and gas lease stipulations, construction of well pads in 

woody draws is prohibited. Construction of oil and gas access roads across or parallel to woody 
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draws occurs infrequently when necessary to access existing leases. Such construction is heavily 

mitigated. 

Currently, oil and gas activity in the project area is primarily focused around maintenance of 

existing oil and gas facilities and maintenance of oil and gas roads. These activities still offer the 

opportunity to spread invasive species where roads cross or are located close to woody draws. 

These species affect woody draws by displacing native vegetation, and forming sod layers which 

hamper or prevent the establishment and survival of tree and shrub regeneration. 

Wildfires have been actively suppressed on the LMNG and adjacent private and state lands for a 

century. Past and current wildfire suppression has allowed Rocky Mountain juniper to expand 

into adjacent grasslands, primarily in the Badlands. Review of historical aerial photography 

indicated that green ash woody draws have expanded by less than 5 percent since the 1930s, but 

have not established in previously unoccupied drainages. Where fire control has allowed some 

species to expand, it has also deprived woodlands of the benefits of fire, such as nutrient cycling, 

promoting a flush of new growth through resprouting, improvement of seed beds for seedling 

establishment, and disruption of disease and parasite cycles. Past and current suppression of 

wildfire still plays a role in the health and expansion of woody draws. 

Noxious Weeds and Invasive Grasses. It is unknown when noxious weeds and invasive grasses 

first appeared in the project area. Some invasive species, such as crested wheatgrass, appeared in 

the 1930s when successfully used in the reclamation of sub marginal lands. The primary past, 

current, and future effect of these groups of plants is that they alter or replace native plant 

communities. In the case of woody draws, they reduce or prevent the establishment of tree and 

shrub seedlings by crowding out the seedlings or through development of sod layers and litter 

accumulation that impede seedling establishment. Treatment of noxious weeds in and near 

woody draws has resulted in the loss of some trees and shrubs.

Drought is a recurring natural event in western North Dakota. Woody draws are generally 

located in areas with a greater abundance of water, such as draws, north slopes, etc., so they are 

generally more resistant to the effects of drought than herbaceous vegetation. In the case of a 

severe drought, the 51 percent of woody draws rated as Healthy would be the least or last 

impacted by drought. The 49 percent of woody draws rated as At Risk or Unhealthy, however, 

would have a reduced ability to withstand the effects of drought due to reduced canopy, 

increased evaporation due to the loss of shading, and increased risk to parasites and disease due 

to reduced vigor and drought stress. 

Reasonably Foreseeable Actions

Elkhorn Ranchlands. The recently purchased Elkhorn Ranchlands require that the Grasslands 

Plan be amended to establish management direction for the newly acquired lands. Approximately 

800 acres of the 5,200 acre Elkhorn purchase are directly associated with five of the allotments 

in the North Billings project. Under the proposed amendment these lands would be managed in 

accordance with the adjacent management area, which is MA 3.65 Rangelands with Diverse 

Natural Appearing Landscapes. In the interim, as directed by 36 CFR 254.3(f)(2008), this 
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portion of the purchase is being managed in accordance with the adjacent MA 3.65. If the 

proposed action were selected and implemented there would be no change over the current 

situation. 

The proposed Grasslands Plan amendment also includes establishing a special interest area (SIA)

for the remaining 4,400 acres of the purchase and approximately 17,160 acres contained in 

grazing allotments 279 and 280, which were associated with the Elkhorn Ranchlands when they 

were privately owned. If implemented the SIA would establish a forage reserve on those acres. 

The reserve would provide a place to move livestock to in the event an allotment is burned out or 

if management actions, such as a prescribed fire or additional rest, were needed to help restore 

woody draws in an allotment. 

Travel Management. An environmental assessment (EA) for travel management on the LMNG 

was released for comment in 2010. The proposed action for this EA would close all single-use 

oil and gas roads, unauthorized roads (i.e., two-tracks), and an additional 18 miles of system 

roads in the project area. The travel management plan is expected to have minimal effect to 

grazing permit holders unless single-use roads are blocked from access. If access were to be 

blocked, then additional two-track roads could be created as permittees can travel cross county to 

administer their permits. This may impact woody draws through the creation of two-track roads

that cross or parallel woody draws, creating an inroad for livestock and an opportunity to spread 

invasive species or noxious weeds in the woody draws. 

Oil and Gas Development. Currently there are five applications for permits to drill (APDs) for oil 

and gas wells in the project area. None of the well pads would be located in woody draws;

however, three of the well pads would be located adjacent to them. One access road crosses a 

riparian area that supports trees. Some of these trees would be removed to accommodate the road 

crossing. Design criteria associated with the construction of these facilities would mitigate 

potential adverse effects on the woody draws associated with these proposed oil and gas wells. 

Emerald ash borer (EAB) is a potential future threat to the green ash draws. This Asian beetle 

has no known natural enemies in the United States and no effective large-scale control has been 

developed to date. The emerald ash borer has been traveling from east to west, and in 2009 was 

found in Minneapolis, Minnesota. If the EAB becomes established in the green ash woody draws 

located in the western portion of North Dakota, they will likely eliminate the green ash from 

these draws. This may mean that this type of woody draw would, in the future, tend to be 

comprised primarily of tall shrubs such as chokecherry and service berry. This in turn would 

affect how this type of woody draw is managed and monitored in the future.

Cumulative Effects by Alternative

This section summarizes direct and indirect effects of the alternatives and the effects of 

reasonably foreseeable actions on woody draws. These effects in combination with past and 

present effects combine to create cumulative effects.

Alternative 1 provides the best opportunity of all the alternatives for the most rapid recovery of 

At Risk and Unhealthy woody draws. This is due primarily to the removal of disturbance 
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164 | Chapter 3

associated with livestock, which affords the best opportunity for maintenance or establishment of 

tree and shrub regeneration. However, invasive species would persist and possibly expand,

thereby hampering the establishment and survival of tree and shrub regeneration through direct 

competition and accumulation of litter. If a travel management plan action is selected, it offers

the potential to improve At Risk and Unhealthy woody draws through closure of roads that 

parallel or cross woody draws. Foreseeable oil and gas development includes three well pads,

which would be located adjacent to woody draws. However, design criteria would minimize

adverse impacts to the woody draws. The same is true of the one riparian crossing whose 

construction would result in the loss of some trees associated with the riparian area. If the EAB 

becomes established in the green ash woody draws, they will likely eliminate the green ash from 

these draws. This in turn would affect how this type of woody draw is managed and monitored in 

the future. Continued fire suppression would have positive effects on woody draws by decreasing 

the occurrence of intense and potentially adverse later summer fires, but would also impede the 

beneficial effects of cooler or low intensity fires.

Alternative 2 may see some improvement in the At-Risk or Unhealthy woody draws because of

the potential effects of the Elkhorn Ranchlands Grasslands Plan amendment and Travel 

Management Plan. The Elkhorn Ranchlands Grasslands Plan amendment offers opportunities, 

through a forage reserve, to potentially hasten the rate of recovery of some At-Risk or Unhealthy 

woody draws by offering an alternate source of forage, thereby providing additional recovery 

time for affected woody draws. Reasonably foreseeable effects associated the travel management 

plan, oil and gas development, and EAB are the same as identified in Alternative 1. However, 

because this alternative maintains the existing Authorized Use levels, rotations, etc., the 

opportunity to achieve a cumulatively positive effect in At Risk and Unhealthy woody draws is 

the least of all the alternatives. 

Alternative 3, initial actions are projected to improve At-Risk and Unhealthy woody draws in 12 

allotments, and see a decline in health in six allotments, with the remaining 14 maintaining 

current conditions. Effects associated with reasonably foreseeable actions are the same as those 

identified in Alternatives 1 and 2. The proportion of Healthy woody draws is predicted to 

increase from 51 percent at current conditions to 55 percent with actions of Alternative 3. 

Alternative 3A is the same as Alternative 3, except for addition or deletion of actions in 14 

allotments. Under this alternative a total of 8 allotments would improve, 9 would decline, and 15

would maintain existing conditions. Alternative 3A has greater adverse cumulative effect then 

Alternative 3 because it would further reduce conditions in 4 additional allotments compared to 

Alternative 3. The potential cumulative effects of reasonably foreseeable actions are the same as 

those under Alternative 3. 

Alternative 4, initial actions would improve woody draw health in 20 of the 32 allotments rated 

as At-Risk or Unhealthy. Four would experience decreasing health and 7 would maintain 

existing conditions. The proportion of Healthy woody draws is predicted to increase from 

51percent at current conditions to 59 percent with actions of Alternative 4. The potential 

cumulative effects of reasonably foreseeable actions are the same as those described in 

Alternatives 1 and 2.
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Adaptive Management, Implementation of adaptive management options under Alternatives 3, 

3A, and 4, including actions identified in the tool box, would improve At Risk and Unhealthy 

woody draws not addressed by the initial actions. The greatest difference among these 

alternatives is the amount of time. In some cases, Alternatives 3 and 3A initiate more indirect 

actions (rotation changes, season of use change, etc.) to deal with woody draw concerns. 

Determining whether these actions are effective requires time, generally 3 to 5 years, so this time 

is lost if the actions are determined to be ineffective. However, Alternative 4 implements direct 

actions (fencing, reductions in Authorized Use, etc.) to reduce livestock disturbance; therefore, it 

could have a greater positive cumulative effect in a shorter timeframe.

Consistency with Grasslands Plan—Woody Draws 

There are no standards in the Grasslands Plan that specifically address woody draws. There are, 

however, two guidelines that do address woody draws. They are as follows:

Design and implement livestock grazing strategies to provide for thick and brushy understories 

and multi-story and multi-age structure in riparian habitats, wooded draws, and woody thickets, 

contingent on local site potential. Guideline (Grasslands Plan, p. 1-13)

Alternative 1 would meet this guideline in the shortest period of time because it would remove 

the primary disturbance factor affecting At Risk and Unhealthy woody draws. Alternative 2 

maintains the status quo, which is not conducive to meeting this guideline. Initial actions under 

Alternative 3 are projected to improve woody draws in 11 of the 32 allotments rated as At Risk 

or Unhealthy, but the proportion of Healthy sites would be unlikely to increase by more than 4

percent. Of the remaining 21 allotments 15 would maintain their current condition and 6 would 

experience a decrease in health. Under Alternative 3A, 8 allotments would improve, 15 would 

remain neutral, and 9 would experience a decrease in woody draw condition. Alternative 4 

would improve At Risk and Unhealthy woody draws in 21 of the 32 allotments. Of the remaining 

11 allotments, 7 would remain unchanged and 4 would decrease. The net effect of proposed 

actions is predicted to increase the proportion of Healthy woody draws from the current level of 

51 percent to 59 percent

Alternatives 3, 3A, and 4 are all adaptive by design. If the initial proposed actions under these 

alternatives are not successful in moving At Risk and Unhealthy woody draws towards this 

guideline, then adaptive options and other tools contained in the tool box would be implemented 

to achieve this guideline. 

Manage livestock grazing to maintain or improve riparian/woody draw areas. Implement the 

following practices: 

• Avoid grazing activities, such as feeding, which concentrate livestock in riparian/woody draw 

areas. Guideline (Grasslands Plan, p. 1-19)

Feeding in woody draws is not allowed on any allotment in the project area. Annual Operating 

Instructions identify that feeding is not to be conducted in sensitive areas such as woody draws. 
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This guideline would not apply to Alternative 1 because livestock would be removed under the 

alternative. Alternative 2 maintains the status quo, so existing activities that are currently 

concentrating livestock in woody draws would continue unabated. 

Livestock are attracted to woody draws for a number of reasons, the primary ones being water 

and shade. Alternatives 3, 3A, and 4 implement a variety of different initial management actions, 

such as relocating water developments, fencing, reducing Authorized Use, etc., to reduce the 

effects of livestock on woody draws. If initial actions were not successful in meeting this 

guideline, then adaptive options or other tools from the toolbox would be implemented under 

Alternative 3, 3A and 4 to achieve the guideline. 

HERBACEOUS STRUCTURE

Introduction

Herbaceous structure refers to the height and density of herbaceous plants. Herbaceous plants are 

non-woody plants, i.e., grasses and forbs. The Northern Great Plains (NGP) Viability Report 

(2000) identified that under preEuro-American settlement conditions the primary ecological 

processes on the mixed grass prairie affecting herbaceous structure were (1) climate; (2) 

herbivory by large animals (bison, elk, and pronghorn) and small herbivores (the black-tailed 

prairie dog and grasshoppers); and (3) fire. These natural disturbance processes produced a 

diversity of herbaceous structure habitats occupied by a diversity of fauna.

Today, the primary influences on herbaceous structure in the project area are generally limited to 

climate and livestock herbivory. Formerly, herbivory by wide ranging bison herds was one of 

high intensity and short duration followed by a 2- to 3-year period of rest (Higgins 1986). In 

contrast, grazing by domestic livestock is characterized by high intensity over long duration 

followed by short lengths of rest, depending on the grazing system and management scenario 

(USDA 2000 NGP Viability Report). These two scenarios produce differing structure mosaics 

across the landscape. 

The Grasslands Plan recognized the role of herbaceous structural diversity and its role in 

influencing the diversity and abundance of plants and animals, hydrology, and availability of 

forage for both domestic and wild grazing animals. This section looks at the existing structure in 

the project area and compares it to the Desired Condition for herbaceous structure as defined by 

the Grasslands Plan.

Spatial and Temporal Setting

The analysis area for the structure is the NFS lands located in the 43 grazing allotments located 

in northern Billings County, ND. As there are no other management factors influencing structure 

located outside of the area that would dictate a different analysis area, this is an appropriate 

analysis area for structure. The temporal setting is 10 to 15 years from the signing of the Final 

ROD for this project proposal.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Chapter 3 | 167

Figure 3.13 — Person reading 

a Robel pole to obtain VOR.

Methodology

The Grasslands Plan identifies structure objectives. Specifically, in order to meet the structure 

objectives, there must be approximately 10-20 percent low vegetative structure, 50-70 percent 

moderate structure, and 20-30 percent high structure (Grassland Plan, Ch 2, pp. 2-13 and 2-21).

These objectives are to be applied to biologically capable lands (2006 DPG Grazing ROD, p. 

17). The Visual Obstruction Reading (VOR) methodology is used by the DPG and in this 

analysis to measure and quantify residual herbaceous cover, i.e., structure. The Grasslands Plan 

describes desired structure in terms of VOR. The VOR measurements associated with each 

structure class are: low structure at 0 to 1.49 inches, moderate structure at 1.5-3.5 inches, and 

high structure at greater than 3.5 inches (Ch.2, pp. 2-13, 2-21).

VOR is obtained through the use of a pole called a Robel pole. The pole is painted in one-inch, 

alternating white and gray bands. A 1-meter sight pole is attached to a graduated pole with a 4-

meter string. The graduated pole contains a spike on the bottom end, which is used to anchor the 

pole when readings are taken. Once the graduated pole is anchored, the person taking the reading 

stretches out the 4-meter string and takes four readings at approximately 90-degree intervals 

(Figure 3.13). At each 90-degree interval the reading is taken at a 1-meter height and the lowest 

partially or wholly visible band is then recorded as the VOR value.

The four VORs at each station were averaged to get a mean for each station. A VOR transect

consists of 20 stations located at approximately 10-meter or 5-pace (10-step) intervals along each 

transect. The overall mean for the transect was then calculated from the 20 station means. 

Within the herbaceous communities, VORs were taken on areas that were “biologically capable” 

of producing high structure. For this analysis, habitat types were 

used to define those areas. This approach is in keeping with the 

DPG direction identified for SRT Recommendation I-3 in the 

DPG Final Response to the Scientific Review Team Report 2006.

A habitat type is a unit of land that has similar soils, topography, 

aspect, climate, elevation, and potential vegetation. Habitat types 

identify, in terms of plant communities, what a particular area is 

capable of supporting, regardless of the existing plant 

community. The habitat types used to identify biologically 

capable areas were western wheatgrass/green needlegrass, 

western wheatgrass/green needlegrass/blue grama, western 

wheatgrass/needle-and-thread grass, silver sage/western 

wheatgrass, big sage/western wheatgrass, and western 

snowberry.

The western wheatgrass/green needlegrass/blue grama habitat 
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168 | Chapter 3

type was dropped from consideration because the few acres (252 acres) of this habitat type, 

distributed across the project area, could not be effectively sampled. The Grasslands Plan 

definition of biologically capable also included the needle and thread/sedge habitat type. There 

are 69 acres of this habitat type in the project area. It was dropped from the analysis for the same 

reason as the western wheatgrass/green needlegrass/blue grama habitat above. Sites dominated 

by crested wheatgrass were also considered biologically capable. Of the roughly 87,263 acres of 

NFS lands in the project area, 54,375 acres (Table 3.19) are identified as biologically capable of 

producing high structure. 

Table 3.19 — Approximate acres of the biologically capable habitat types in the project 

area

Habitat Type (HT) Acres

Western wheatgrass/green needlegrass 31,502

Western wheatgrass/green needlegrass/blue grama 252

Western wheatgrass/needle-and-thread grass 14,196

Needle and thread/sedge 69

Silver sage/western wheatgrass 4,412

Big sage/western wheatgrass 2,568

Western snowberry 1,377

Total acres 54,375

If transects located in the three grass/shrub habitat types were dominated or codominated by 

shrubs, they were separated in the analysis. This was done because it is generally considered 

inappropriate to analyze or lump shrubs and herbaceous dominated data together (Uresk, 

personal communication, 2009; Smith 2008).

The SRT recommended that the DPG summarize VOR transect data at the station level rather 

than by averaging together all the stations along a transect (SRT 2005. p. 14). The DPG response 

was that it will provide the data in both formats in the future (see Final Response to the SRT 

Reposts, Recommendation II–2). However, interpreting station averages requires a different 

definition for high structure in order to account for the actual nest site needs of sharp-tailed 

grouse and other ground nesting species, such as Baird’s sparrow. It was recommended during 

the SRT process that a station average of 5.5 inches or greater would define High structure (see 

Final Response to the SRT Reposts, Recommendation II–2). This analysis adopted that 

recommendation. 

During the SRT process, the focus of the station average versus transect average discussion was 

about High structure and whether one method would produce better information than the other. 

Apparently there was no discussion about the class sizes for Low and Moderate structure related 

to the station average approach. For the station average analysis, Low structure was defined as 0 

to 1.49 inches and Moderate as 1.5 to 5.49 inches. 

A detailed explanation of stratification, sampling, and data collection methodologies are located 

in Appendix B of the Wildlife Report (Project Record, Specialist Reports and Notes). 
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Chapter 3 | 169

COOPERATIVE MONITORING DATA 

The 2008 and 2009 VOR data collected through the cooperative effort between the Forest 

Service, NDSU, and the MGA was reviewed in light of this analysis. The VOR data collected by 

NDSU was taken from plots throughout the growing season. NDSU’s objective in collecting 

VOR data in this manner was to determine if there is a correlation between VOR and graminoid 

production. This analysis collected VOR data along a transect in the fall of the year, when 

herbaceous growth and grazing are generally completed. The data were used to determine the 

amount of structure in allotments and across the landscape. The NDSU and Forest Service VOR 

data sets are not compatible because of differing objectives, design criteria, and methodologies;

therefore, the 2008 and 2009 VOR data could not be used in this project analysis.

Affected Environment—Herbaceous Structure

This section provides a general description of information related to herbaceous structure for the 

project area. A detailed description of the existing condition of herbaceous structure in each 

allotment is provided in Part 2 of this chapter.

EXISTING CONDITION

VOR measurements were used to describe the existing condition of herbaceous structure in the 

project area. The LMNG has been collecting VOR measurement since 1996. Between 1996 and 

2001, structure data was collected on approximately 350 transects scattered across the LMNG. 

This broad-scale effort was used by the Northern Great Plains Land and Resource Management 

Plan Revision process to identify how structure was distributed across the landscape. In general, 

this information showed that grassland structure across much of the LMNG was strongly skewed 

towards the lower levels (NGP FEIS, pages 3 to188).

Transects located on NFS lands in Billings County were segregated from the above data set and 

analyzed. Figure 3.14 shows the range of High, Moderate, and Low structure from transects 

surveyed from 1996 through 2001 in Billings County.

Figure 3.14 shows that between 1996 and 2001, in Billings County, 3 to 8 percent of the 

surveyed transects had a VOR average greater than 3.5 inches (High structure), approximately 47 

to 83 percent averaged a VOR rating of 1.5 to 3.5inches (Moderate structure), and roughly 11 to 

49 percent had VOR ratings of less than 1.5 inches (Low structure). This transect information 

shows that herbaceous structure during that time period was skewed towards Low and Moderate 

classes with a minor amount of High structure. 
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170 | Chapter 3

Figure 3.14 — 1996 to 2001 VOR transect data from NFS lands, Billings County, ND.

Of the 350 transects noted above, 42 are located within the project area. Figure 3.15 shows the 

distribution of VOR transects in terms of structure. For example, between 1996 and 1999, high 

structure varied from 4.8 percent to 20 percent of the surveyed transects. Moderate structure 

ranged from about 56 percent to 70 percent, and Low structure from roughly 23 to 36 percent 

during the same period. The figure shows that, in general, Moderate structure was meeting the 

Grasslands Plan objective, i.e., 50 to 70 percent. Low structure exceeded the high end (20

percent) of the Grasslands Plan objective by 3 to 16 percent. High structure ranged from about 5

to 20 percent. This means that in 1999 the High structure objective of 20 to 30 percent was met;

however, in the preceding years the amount of High structure was significantly below the 20 to 

30 percent High structure objective. 

11%

31%

49%

30% 30% 27%

83%

62% 66%

47%

65% 67%

3% 6%

8%

3%

6%

4%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

Year

%

o

f

T

r

a

n

s

e

c

t

s

<1.5 Inches 30% 27% 49% 30% 31% 11%

1.5-3.5 Inches 65% 67% 47% 62% 66% 83%

>3.5 Inches 4% 6% 3% 8% 3% 6%

1996 (113) 1997 (134) 1998 (118) 1999 (123) 2000 (35) 2001 (35)
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Chapter 3 | 171

Figure 3.15 — 1996 to 1999 VOR transect distribution within project area. The numbers in 

parentheses are the number of transects sampled in that year.

In 2004, a total of 183 VOR transects were located in the project area. This represents a sampling 

intensity of approximately 1 transect per 320 acres of biologically capable habitat type. Of the 

183 transects, 22 had shrubs (such as western snowberry or silver sage) listed as dominant or codominant vegetation on the data sheets. These transects were separated in the analysis because, 

as previously stated, it is thought to be generally inappropriate to analyze or lump shrubs and 

herbaceous dominated data together (Uresk, personal communication, 2009; Smith 2008).

The 2004 transect information (Figure 3.16) shows that approximately 53 percent of the transects 

were in the 1.0- to 1.49-inch class (Low structure), 47 percent in the 1.5- to 3.5-inch class 

(Moderate structure), and 1 percent in the greater than 3.5-inch class (High structure). This 

information shows that structure in the project area continued to be skewed to Low and Moderate 

structure, with insufficient High structure to meet Grasslands Plan objectives.
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172 | Chapter 3

Figure 3.16 — Herbaceous dominated structure transect results expressed as percentages 

for the project area (2004 and 2005 results) and Grasslands Plan objectives.

It is important to put 2004 in context of what was happening climatically. According to the North 

Dakota Agricultural Weather Network (NDAWN), during the months of April through 

September 2004, precipitation in Billings County, ND, was approximately 50 to 75 percent of 

normal for the analysis area. The Grasslands Plan (p. G-15) defines drought as 75 percent or less

of normal annual precipitation. There was some moisture recovery in September and October of 

2004. In 2005, precipitation for April to September in Billings County was 25 to 50 percent 

above average annual precipitation. Given the climatic events in 2004, a reduction in High 

structure would be expected, but not to the 0.6 percent level. 

The transect information from 2005 shows some recovery from the 2004 drought (Figure 3.16).

High structure increased from less than 1 percent to almost 7 percent. Low structure decreased 

from about 53 percent to 29 percent, and Moderate structure increased from 47 to 64 percent. 

These results are likely the result of increased precipitation and a mandatory 20 percent animal 

0.0

10.0

20.0

30.0

40.0

50.0

60.0

70.0

15

52.8

29.5

60

46.6

63.6

25

0.6

6.8

% of 

Transects
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Chapter 3 | 173

unit reduction put in place in 2005 as a result of the 2004 drought. In addition to the reduction in 

animal units, turnout onto crested wheatgrass and native pastures was delayed until May 15 and 

June 1, respectively. 

Table 3.20 summarizes where each allotment falls in relation to Grasslands Plan structure

objectives. Review of the 2004 transect data, field visitations (2006), and IDT discussion 

determined that structure objectives were being met on allotments 132A, 239, 241, 243, 248, 

282, 287. A total of 12 allotments are not meeting Low or High structure but are meeting 

Moderate objectives. Twenty-one allotments are not meeting any of the objectives. Two 

allotments are meeting Low structure but not Moderate or High structure objectives. One 

allotment is a hay pasture.

Table 3.20 — Distribution of allotments in relation to Grasslands Plan structure objectives

Allotments

Meeting Structure Objectives

Low Moderate High

132A, 239, 241, 243, 248, 282, 287 Yes Yes Yes

126,128,131,132H, 133, 140,230, 

240,256, 272,283,288 No Yes No

127,130,134,135,136/139,141,142,

158,220,221,237, 244,249,258,

278,286,289,300,301,302

No No

No

126,277 Yes No No

133D5 Hay N/A1

1This is a small allotment (78 acres) with two permittees, half of the allotment (39 acres) is hayed 

every other year, and half (18 acres) of the remaining half is hayed annually.

Field Visitations—2006

Results of the 2004 data collection were shared with the grazing permittees in the project area, 

who were then given the opportunity to challenge an issue if they felt their allotment was 

meeting Grasslands Plan objectives. Several permittees issued challenges related to the amount 

of High structure present on their allotments. The IDT revisited these allotments and several 

others in 2006 and ran additional VOR transects. The transect locations were purposely biased to 

survey areas of the highest structure that could be found. Allotments 126/128, 127, 129, 132A, 

239, 272, 278, and 281 were revisited. Two allotments, 132A and 239, had at least 20 percent 

High structure, the remaining allotments did not meet the High structure objective. 
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174 | Chapter 3

VOR at the Station Scale

In the response to SRT Recommendation II-1, this analysis used both transects and stations to 

describe the existing structure distribution (USDA 2006) in future analyses. That information is 

provided in Figure 3.17 for 2004 and 2005. As described earlier in the Methodology section,

station analysis requires new definitions for High, Moderate and Low structure classes because 

of the site-specific nature of stations. High structure for station averages is a VOR of 5.5 inches

or greater (ibid.). The primary concern during the SRT process was with High structure;

however, all three structure levels are provided in Figure 3.17, which summarizes the station data 

for herbaceous dominated transects within the project area.

The 2004 station data represented in Figure 3.17 shows that within the project area there was 

very little High structure present (0.7 percent), a high amount of Low structure (62 percent), and 

a low amount of Moderate structure (38 percent). Year 2005 shows a limited recovery of High 

structure (0.7 to 1.9 percent), a reduction in Low structure (43 percent), and Moderate structure 

(56 percent) nearing objectives 

Figure 3.17 — 2004 and 2005 VOR distribution of stations within herbaceous dominated 

transects within the project area.

As previously noted, 2004 was a dry year, so an increase in Low structure and a decrease in High 

structure would be expected but not to the degree indicated by the data. The 2005 data show 

about a 1 percent recovery in High structure and approximately an 18 percent reduction in Low 

structure. These changes could be explained by increased precipitation and the mandatory 20 

percent animal unit reductions and turnout restrictions put in place in early 2005. 

2004

2005

LOW MOD HIGH

42.5%

61.6% 55.6%

37.7%

1.9%

0.7%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

%

o

f

S

t

a

t

i

o

n

s

Year

LOW 61.6% 42.5%

MOD 37.7% 55.6%

HIGH 0.7% 1.9%

2004 2005
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Chapter 3 | 175

A comparison of 2004 and 2005 VOR data for project-level transect averages and station average 

methods is presented in Table 3.21. Information in the table indicates that while there are some

differences in the figures, they are minor in nature. Both methods of analyzing the VOR data 

show a skewed distribution of structure towards Low and Moderate structure classes and a 

minimal amount of High structure. As noted previously, High structure for the VOR transect 

average is a VOR reading of greater than 3.5 inches, and for the station average a VOR reading 

of greater than or equal to 5.5 inches.

Table 3.21 — Comparison of transect and station averages and Grasslands Plan structure 

objectives for 2004 and 2005 sample years

TRANSECT AVE. Grasslands

Plan

STATION AVE.

2004 2005 2004 2005

High structure 0.6% 6.8% 20-30% 0.7% 1.9%

Mod structure 46.6% 63.6% 50-70% 37.7% 55.6%

Low structure 52.8% 29.5% 10-20% 61.6% 42.5%

Summary

A review of the LMNG, Billings County, project area, and allotment level VOR transect 

information from 1996 to 2005 shows a bias towards Low and Moderate structure classes and a 

scarcity of High structure. Overall, Grasslands Plan structure objectives for High and Low 

herbaceous structure are not being achieved in the project area. 

Structure objectives are being met on allotments 132A, 239, 241, 243, 248, 282, 287. A total of 

12 allotments are not meeting Low or High structure but are meeting Moderate objectives. 

Twenty-one allotments are not meeting any of the objectives. Two allotments are meeting Low 

structure but not Moderate or High structure objectives. One allotment is a hay pasture (see 

Table 3.20). 

It is acknowledged that 2004 was a drought year and that structure would tend to shift towards 

Low and Moderate; however, the near total absence of High herbaceous structure (<1 percent)

should not be expected or desired (Grasslands Plan, p. 1 to 13). Because of a lack of residual 

structure from 2004, herbaceous structure remained below structure objectives for 2005 despite 

moisture recovery, stocking reductions, and turn-out restrictions. Analyzing the allotment VOR 

data under the transect and station methodologies provided essentially the same results.

DESIRED CONDITION

The desired condition for herbaceous structure is identified in Chapters 1 and 2 of the Grasslands 

Plan. The following direction is provided by the Grasslands Plan:

Goal 1.c: Increase the amount of forests and grasslands restored to or maintained in a healthy 

condition with reduced risk and damage from disturbance processes, both natural and humancontrolled (Grasslands Plan, p 1-3).
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176 | Chapter 3

Objective: Within 10 years, implement management practices, including prescribed fire that will 

move landscapes toward desired vegetation composition and structure as described in 

Geographic Area direction” (Grasslands Plan, Ch 1, p 1-3).

Badlands and Rolling Prairie Geographic Areas: The project area contains Rolling Prairie and 

Badlands geographic areas. The identical structure objectives for both of these geographical 

areas are presented in Table 3.22 (Grasslands Plan pp. 2-13 and 2-21).

Table 3.22 — Grasslands Plan structure objectives for the Rolling Prairie and Badlands 

Geographic Areas

Structure Objectives

Low Moderate High

10-20% 50-70% 20-30%

Capability

Some comments in response to the publication of the DEIS stated that there was no process to 

determine whether the land can produce the vegetation structure to meet the assigned VOR

objectives. These comments revolve around the concern that biologically capable lands, as 

defined by the Forest Service, are not capable of producing high structure. The Grasslands Plan 

(Appendix H) defines High structure as a VOR transect average of greater than 3.50 inches. VOR 

transects conducted on the Medora Ranger District for various purposes from 1996 to 2009 show 

that the habitat types used to define biologically capable are capable of producing High structure. 

One hundred and nineteen VOR transects surveyed during that time measured VORs ranging 

from 3.5 to 7.96 inches. The VOR transects encompassed all the habitat types except for one 

(Table 3.23) included in the definition of biologically capable lands. VOR transects measured 

across the Medora Ranger District from 1996 to 2009 show that approximately 6 percent of these 

transects had VORs greater than 3.5 inches.

Table 3.23 — Summary of VOR transects supporting High structure by biologically 

capable habitat type on the Medora Ranger District 

Habitat Type Name HT 

Number

Number of 

High 

structure 

transects

1

Percentage 

of the High 

structure 

transects

Western wheatgrass/needle and thread 6 21 18

Western wheatgrass/green needle 7 77 65

Silver sage/western wheatgrass 31 18 15

Big sage/western wheatgrass 42 1 1

Western snowberry 150 3 3

Needle and thread/sedge 147 0 0
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Chapter 3 | 177

1

Percentages are rounded to nearest whole number.

The western wheatgrass/needle and thread (HT 6) and western wheatgrass/green needle (HT 7) 

habitat types account for 84 percent of the biologically capable lands in the project area (Table 

3.19). The needle and thread/sedge (HT 147) accounts for less than 1 percent of the LMNG and 

has not been sampled. In the project area HT 147 accounted for less than 69 acres of this habitat 

type. Because of the small amount of this habitat type, it was not sampled. 

Adjacent to the Medora Ranger District is the McKenzie Ranger District; together these two 

districts encompass the LMNG. The McKenzie District contains the same habitat types used in 

the definition of biologically capable lands as the Medora District. A review of VOR transects 

conducted during 2001 and 2002 for the 2006 Northeast McKenzie Allotment Management Plan 

Revisions FEIS (NE McKenzie FEIS) shows that high herbaceous structure is attainable on these 

habitat types. Within that project area, 46 VOR transects measured VORs of 3.51 or greater 

(Table 3.24).

Table 3.24 — Summary of VOR transects supporting High structure on biologically 

capable habitat types in the NE McKenzie FEIS project area

Habitat Type Name HT 

Number

Number of 

High 

Structure 

Transects

1

Percentage 

of the High 

Structure 

Transects

Western wheatgrass/needle and thread 6 8 17

Western wheatgrass/green needle 7 33 72

Silver sage/western wheatgrass 31 2 4

Big sage/western wheatgrass 42 0 0

Western snowberry 150 3 7

Needle and thread/sedge 147 0 0

1

Percentages are rounded to nearest whole number.

Also on the McKenzie District, in the fall of 2009 in Pasture 10, three transects measured VORs 

ranging from 3.69 to 4.13 inches in HT7. These transects accounted for 9 percent of the transects 

measured in that pasture. Pasture 11 in the fall of 2008 had seven transects with VORs ranging 

from 3.51 to 6.15 inches; six were located in HT 7 and one in HT 31. Ten percent of the VOR 

transects in Pasture 11 measured High structure. 

The above information shows that the habitat types used in the definition of biologically capable 

lands are capable of supporting High herbaceous structure as defined by the Grasslands Plan.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

178 | Chapter 3

Environmental Consequences—Herbaceous Structure

DIRECT AND INDIRECT EFFECTS 

Alternative 1

Under this alternative all livestock would be removed from the NFS lands 2 years after the MGA 

is notified of the decision in accordance with Forest Service handbook direction. All range 

structures and water developments would be removed other than those deemed necessary for 

other resource management objectives. 

With no grazing pressure other than that resulting from wildlife there would be a shift in the 

structure mosaic across the project area. Moderate and High structure would increase and the 

amount of Low structure would decrease, meeting or exceeding structure objectives identified in 

the Grasslands Plan.

Vegetation species composition would be expected to improve, at least in the short term, towards 

a later seral state. However, without periodic disturbance, once later seral stages are reached the 

herbaceous community, particularly forbs, may start to decline and eventually stagnate. This 

would result in a shift to lower structure classes. Non-native invasive grasses such as smooth 

brome and Kentucky bluegrass may begin to dominate more sites within the project area 

reducing the native component of the plant communities. The “shifting mosaic” of vegetative 

structure identified in the Grasslands Plan (pp. 2-11, 2-18,), would not be addressed since there 

would be no periodic large-scale disturbance such as livestock grazing within the project area. 

Occasional wildfires and prescribed burns could provide some short-term habitat diversity,

which would provide a mosaic of structure more consistent with Grasslands Plan structure 

objectives.

The effects of drought on High herbaceous structure would be lessened as no grazing would be 

permitted. High structure would remain available, though likely of lower quality, throughout the 

drought period. Given the increase in vegetation the opportunity for more wildfires of larger size 

and duration may increase. 

Alternative 2

This alternative maintains exiting Authorized Use, grazing rotations, allotment arrangements, in 

short, the status quo. Current management direction for each allotment in the project area is 

located in Part 2 of this Chapter.

As this alternative would maintain current management direction, existing structure conditions 

will likely continue to reflect those identified in the Existing Condition section above. Essentially 

the skewed distribution towards Low and Moderate structure would continue, as would the 

continued shortfall in high structure.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Chapter 3 | 179

Alternative 3

The initial actions of this alternative include establishing, changing, or maintaining rotational 

grazing systems; additional range improvements such as fencing, water development, range 

pipelines, etc, on approximately a third of the allotments; and range water management. 

Authorized Use would be Preference.

Grazing systems—The use of rotational systems to address structure concerns appears to be of 

limited benefit according to Briske (2008), Holechek (1999), Hart et al. (1993), Salo (2004), Van 

Poollen and Lacey (1979), and others. They identify that rotational grazing offers no perceived 

vegetative benefits over continuous grazing under similar stocking rates and that the general 

effect is towards even utilization of the forage base, which may result in the project area being 

skewed towards Moderate structure. Therefore, changing or maintaining grazing rotation systems 

while maintaining current Authorized Use levels appears to generally favor a continuation of the 

existing structure situation. Because rotation grazing systems influence the duration and time of 

pasture use, it is possible that some herbaceous structure improvement at the pasture scale may 

occur but the actual outcome is uncertain. 

Infrastructure—Under this alternative, 17 of the 43 allotments would receive additional range 

infrastructure (i.e., range water, water pipelines, tanks, or fencing). The development or 

extension of existing water sources via pipelines affects livestock use patterns and, indirectly, 

structure. Managing access to water affords an opportunity for vegetation regrowth or reduced 

utilization by controlling the duration of grazing on a portion of the allotment or pasture. This 

provides a chance for some Low structure to recover into a higher structure class. However, 

according to the Northern Great Plans (NGP) FEIS (page 3-240), the effect of increased 

infrastructure such as water development, tends to increase the overall harvest efficiency by 

livestock. This means the forage base is utilized more evenly across the entire pasture, which 

under this alternative tends to favor Moderate or Low structure. It is possible that increasing 

water infrastructure may adversely affect High structure because formerly underutilized areas 

(i.e., secondary range) containing High structure may now be exposed to more intensive grazing 

pressure. 

Fencing can have many of the same effects as water development. Reducing a larger area into 

smaller pastures favors increased herbaceous structure homogeneity (USDA 2001b) and 

increased harvest efficiency because livestock tend to utilize the forage in smaller areas more 

thoroughly. Also, existing high structure areas may receive more utilization resulting in a lower 

structure class. Conversely, creating a crested wheatgrass pasture, if feasible, may provide 

additional regrowth time to increase herbaceous structure levels. 

Stocking Level—The Wildlife Report (Project Record, Specialist Reports and Notes) notes that

Holechek et al. (1989), Reece (1991), Hart et al. (1993), Briske et al. (2008), and others, have 

identified that stocking is the most important variable in managing range vegetation. Derner and 

Hart (2007) and Holechek et al. (1989) also note that lighter stocking levels result in higher 

levels of standing crop, which equates to higher structure. Conversely, heavy grazing has the 

reverse effect. When Authorized Use exceeds carrying capacity there is greater utilization of the 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

180 | Chapter 3

existing forage, which results in a greater amount of Low to Moderate structure. If Authorized 

Use is at or below the carrying capacity, then high structure may increase to some degree; 

however, the level of increase would depend upon a variety of factors such as the time, intensity,

and duration of livestock grazing and would be monitored to see if additional adjustments in 

Authorized Use or timing of grazing are warranted.

Given that grazing systems, infrastructure, and the existing Authorized Use levels tend to favor 

homogenous structure, it does not appear that under the initial actions of this alternative High 

structure objectives will be achieved. Adaptive management actions may be necessary to provide 

appreciable movement towards structure objectives, in particular High structure.

The Wildlife Report (Project Record, Specialist Reports and Notes) concludes that some Low 

structure may move to the Moderate category. However, the opportunity to increase the amount 

of High structure appears unlikely because of the homogenization effects of increased 

infrastructure and rotational grazing systems and the lack of Authorized Use adjustments.

Table 3.25 summarizes the predicted results of implementing initial actions under Alternative 3. 

The results are identified in terms of improving, no change, or a decrease in the amount of High 

structure and structure objectives in general.

Under this alternative 30 allotments are projected to have no change; however, six of these 

allotments are currently meeting structure objectives. Twelve allotments are projected to 

decrease High structure; of these allotments, one is currently meeting structure objectives. One 

allotment is hayed, and the structure objective is not applied to it.

Adaptive management under Alternative 3 includes all of the above-mentioned types of range 

management tools plus the ability to adjust Authorized Use. Adaptive management tools are 

identical to those of Alternative 4; the difference between the two alternatives in relation to 

adaptive management is the rate of expected change. See the adaptive management discussion 

under Alternative 4 below for more detail. 

Table 3.25 — Summary of predicted effects on High structure and structure objectives in 

general, Alternative 3

Allot # Improve

No 

Change Decrease Allot # Improve

No 

Change Decrease

126 X 240 X

127 X

1

241 X

128 X

1

243 X

129 X 244 X

130 X

1

248 X

131 X 249 X

1

132A X 256 X

132H X 258 X

133 X 272 X
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Chapter 3 | 181

Allot # Improve

No 

Change Decrease Allot # Improve

No 

Change Decrease

2

133D-5 N/A 277 X

134 X 278 X

135 X 281 X

136/139 X

1

282 X

140 X 283 X

141 X 286 X

142 X

1

287 X

158 X 288 X

220 X 289 X

221 X 300 X

230 X 301 X

237 X 302 X

1

239 X

1These allotments are currently meeting herbaceous structure objectives.

2 This allotment is hayed.

Alternative 3A

This alternative is essentially the same as Alternative 3 with the exception of 16 different actions 

added or deleted from 14 allotments (see Chapter 2, Alternative 3A description). The added or 

deleted actions for the affected allotments will not appreciable affect structure on these 

allotments; therefore, the effects are the same as Alternative 3.

There are no changes in adaptive options between Alternative 3 and 3A with the exception of 

Allotment 135, which changed an adaptive action to an initial action. That action is addressed 

above. The effects of the adaptive actions are the same as those identified in under Alternative 3. 

Alternative 4

Alternative 4 is similar to Alternative 3 in the use of management tools such as implementation 

or changes in rotations, but does not utilize range infrastructure to the extent Alternative 3 does. 

In addition to these actions, Alternative 4 includes Authorized Use based on carrying capacity 

with an adjustment for livestock weight. This alternative is also adaptive management based. 

Table 3.26 summarizes the predicted results of implementing initial actions under Alternative 4. 

The results are identified in terms of improving, no change, or a decrease in the amount of High 

structure and structure objectives in general. 

Table 3.26 — Summary of predicted effects on High structure and structure objectives in 

general, Alternative 4

Allot # Improve

No 

Change Decrease Allot # Improve

No 

Change Decrease

126 X 240 X
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182 | Chapter 3

Allot # Improve

No 

Change Decrease Allot # Improve

No 

Change Decrease

127 X

1

241 X

128 X

1

243 X

129 X 244 X

130 X

1

248 X

131 X 249 X

1

132A X 256 X

132H X 258 X

133 X 272 X

2

133D-5 N/A 277 X

134 X 278 X

135 X 281 X

136/139 X

1

282 X

140 X 283 X

141 X 286 X

142 X

1

287 X

158 X 288 X

220 X 289 X

221 X 300 X

230 X 301 X

237 X 302 X

1

239 X

1These allotments are currently meeting herbaceous structure objectives.

2 This allotment is hayed.

Under the initial actions of this alternative, 29 allotments are projected to move towards structure 

objectives. Seven of the 29 are currently meeting structure objectives; however, initial actions 

could further improve structure distribution in 5 of the allotments, and 2 would remain 

unchanged. No changes to the current structure distribution are projected for 12 allotments. One 

allotment would shift the structure distribution more towards Moderate and Low structure. One 

allotment is hayed, and the structure objective is not applied to it.

If monitoring shows that initial actions are not meeting or making acceptable progress towards 

structure objectives additional reductions in Authorized Use or other management actions may 

be needed. The adaptive options identified under this alternative in combination with the tool 

box offer an array of different tools that could be used to further address structure objectives. 

However, as pointed out under Alternative 1 above, stocking rate is the most import variable in 

managing range vegetation. 
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Chapter 3 | 183

CUMULATIVE EFFECTS

Cumulative effects result from the combination of effects resulting from past, present, and 

reasonably foreseeable actions plus the direct and indirect effects of the alternatives. A 

discussion of past and present actions, reasonably foreseeable actions, and a summary of the

cumulative effects by alternative follows.

Past and Present Actions

The following past and present actions have contributed to the existing array of herbaceous 

structure in the project area.

Livestock grazing has affected and continues to affect herbaceous structure in the project area. In 

the past, the effects of unregulated livestock led to overgrazing. On the LMNG, unregulated 

grazing has been replaced by managed grazing. Domestic livestock have replaced the large 

herbivores of the past and they are the primary factor affecting herbaceous structure across the 

LMNG and project area. Currently 12 allotments are not meeting Low or High structure 

objectives but are meeting Moderate objectives. Twenty-one allotments are not meeting any of 

the structure objectives. Two allotments are meeting Low structure but not Moderate or High 

structure objectives. One allotment is a hay pasture.

Oil and gas development has resulted in the creation of an extensive all-weather road system. 

The road system has provided new or improved access to some formerly inaccessible or 

seasonally accessible grazing areas known as secondary range. Secondary range can serve as a 

reserve for High structure herbaceous vegetation. Because of the road system, secondary range is 

now subject to increased grazing pressure, which directly affects High structure in those areas.

Maintenance of existing oil and gas facilities and roads assures that access to secondary range 

will be maintained. 

When noxious weeds and invasive grasses first appeared in the project area is unknown. Some 

invasive species such as crested wheatgrass appeared sometime the 1930s, when it was 

successfully used in the reclamation of sub-marginal lands. Oil and gas development and winter 

feeding of livestock have also introduced or spread noxious weeds and invasive grasses. The 

primary past, current, and future effect of these groups of plants is that they alter or replace 

native plant communities, which in turn affects the distribution of structure across the landscape. 

Despite the adverse effect on native species, invasive grasses such as annual brome, crested 

wheatgrass, and Kentucky bluegrass can supply High structure, which is the most limiting 

structure class in 36 of the 43 allotments in this project.

Wildfire once played an active role in the configuration of the herbaceous structure mosaic across 

the landscape. For more than a century wildfire has been actively suppressed on private, state,

and federal lands. This has deprived the uplands of the beneficial effects of fire such as nutrient 

cycling, removal of excess litter, and promoting a flush of new growth. Fire also reduces shrubs 

such as western snowberry and plants such as club moss, often resulting in a flush of new grasses
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184 | Chapter 3

such as western wheatgrass, green needle grass, etc., which are all capable of producing High 

structure. Another lost benefit may be the effect fire has on controlling or reducing the spread of 

invasive grass species. 

Drought is a recurring natural event in western North Dakota that affects herbaceous structure, as 

demonstrated by the 2004 VOR data. The lack of moisture adversely affects plant growth, so the 

amount of High structure is naturally less. Livestock grazing during drought further reduces the 

amount of High structure.

Reasonably Foreseeable Actions

Elkhorn Ranchlands. The recently purchased Elkhorn Ranchlands require that the Grasslands 

Plan be amended to establish management direction for the newly acquired lands. Approximately 

800 acres of the 5,200 acre Elkhorn purchase are directly associated with five of the allotments 

in the North Billings project. Under the proposed amendment these lands would be managed in 

accordance with the adjacent management area which is MA 3.65 Rangelands with Diverse 

Natural Appearing Landscapes. In the interim, as directed by 36 CFR 254.3(f)(2008), this 

portion of the purchase is being managed in accordance with the adjacent MA 3.65. If the 

proposed action is selected and implemented there would be no change over the current situation. 

The proposed Grasslands Plan amendment also includes establishing a special interest area (SIA)

for the remaining 4,400 acres of the purchase and approximately 17,160 acres contained in 

grazing allotments 279 and 280, which were associated with the Elkhorn Ranchlands. If 

implemented the SIA would establish a forage reserve on those acres. The reserve would provide 

a place to move livestock to in the event an allotment is burned out or if management actions 

such as a prescribed fire or additional rest were needed to help restore high structure an 

allotment(s). 

Travel Management Plan. An environmental assessment (EA) for travel management on the 

LMNG was released for comment in 2010. The proposed action under this EA would close all 

single-use oil and gas roads, unauthorized roads (i.e., two-tracks), and an additional 18 miles of 

system roads in the project area. It is unlikely that this future action will significantly affect the 

structure mosaic because it will not have an effect on herbaceous vegetation in the project area.

Oil and Gas Development. The Forest Service has received five applications for permit to drill 

(APDs) on NFS lands in the project area. The APDs seek to drill oil and gas wells. The well pads 

associated with each well would be approximately 4 to 5 acres in size, encompassing about 22 

acres total. Approximately 4,250 feet of access roads would be built on reclaimed or new road 

sites disturbing approximately 6 acres. These future actions would remove a total of 28 acres 

from forage production for the life of the wells. Some of the disturbed area may currently

support or be capable of supporting high structure; however, the amount of disturbed area in total 

is so small it would not have a significant cumulative effect on achieving structure objectives. 
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Chapter 3 | 185

Cumulative Effects by Alternative 

This section summarizes direct and indirect effects of the alternatives and the effects of 

reasonably foreseeable actions on herbaceous structure. These effects in combination with past

and present effects combine to create cumulative effects.

Alternative 1 provides the best opportunity of all the alternatives for meeting the High structure 

objectives in the shortest timeframe. This is due primarily to the removal of disturbance 

associated with livestock. However, in a relatively short time the distribution may become 

skewed to Moderate and High structure. However, without active management, which includes 

herbivory, the opportunity for the expansion of invasive grasses increases substantially, 

threatening recovery of impacted resources. Additionally, as litter increases it eventually shades 

out grasses, reducing the vigor of the system and the structure mosaic. Reasonably foreseeable 

actions would not affect the projected outcome of this alternative or result in a cumulative 

significant effect. 

Alternative 2 could see some improvement in meeting or moving towards structure objectives 

due to the potential beneficial effects of the Elkhorn Ranchlands amendment as described under 

Reasonably Foreseeable discussion above. However, because this alternative maintains the 

existing Authorized Use levels, rotations, etc., the opportunity to achieve significant movement 

towards the structure objectives is the least of all the alternatives. 

Alternatives 3 and 3A, initial actions are projected to move some Low structure into the 

Moderate structure category; however, there no projected improvement in the amount of High 

structure, which is the common factor among the 35 allotments that are not meeting structure 

objectives. The Elkhorn Plan Amendment, through the creation of a forage reserve, would 

provide additional forage opportunities. This increases management flexibility in moving 

towards or attaining structure objectives within the project area. Other reasonably foreseeable 

actions would not have a cumulative significant effect under these alternatives for the reasons 

described in the Reasonably Foreseeable discussion above.

Alternative 4, initial actions would improve High structure in 22 of the 35 allotments not 

meeting high structure objectives. Reasonably foreseeable actions would have the same effects

as identified under Alternatives 2, 3, and 3A. 

Adaptive Management. Implementation of adaptive management options under Alternatives 3, 

3A, and 4—including actions identified in the tool box singularly or in combination—would 

meet or provide significant movement towards structure objectives within the timeframe of this 

project. The greatest difference among these alternatives when considering adaptive actions is 

the rate of improvement. Alternatives 3 and 3A initially utilize management actions other than 

adjusting Authorized Use. Determining whether these actions are effective requires time, 

generally 3 to 5 years, so this time is lost if the initial actions are determined to be ineffective. In 
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186 | Chapter 3

contrast, Alternative 4 initially adjusts Authorized Use to carrying capacity, among other actions. 

As identified above, stocking rate is the most important variable in managing range vegetation. 

So by addressing this variable initially Alternative 4 has potentially gained the 3 to 5 years over 

Alternatives 3 and 3A in the event additional adaptive management actions are needed.

Consistency with Grasslands Plan—Herbaceous Structure

There are no standards in the Grasslands Plan for structure; however, there is one guideline,

which is presented below. 

Apply vegetative structural and compositional objectives across all herbaceous community types 

(Grasslands Plan, p. 2-22). Guideline

Currently the project area is not meeting the structural objectives identified in the Grasslands 

Plan. In general there is there is an overabundance of Low structure and a scarcity of High 

structure. Alternative 1 would increase Moderate and High structure and decrease the amount of 

Low structure. However, eventually the Low structure objective may not be met because of the 

degree in the shift towards Moderate and High structure. Alternative 2 would maintain the 

current structure distribution and would not move towards the structure objectives. Initial 

actions under Alternatives 3 and 3A maintain Authorized Use at Preference. These alternatives 

are predicted to move some Low structure into the Moderate objective but will not increase the 

amount of High structure. Alternative 4 establishes Authorized Use at carrying capacity. This 

results in a reduction in Authorized Use, which the FEIS identifies as the most effective means of 

addressing the structural concerns in the project area. 

Alternative 3, 3A, and 4 are adaptive-management-based, which means that other management 

actions may be implemented if monitoring shows that initial management actions are not 

producing desired results. Alternatives 3 and 3A would eventually meet the structure guideline. 

The difference among Alternatives 3, 3A, and 4 is the rate of improvement. Alternative 4, 

because of initial reductions in Authorized Use, provides for the most rapid improvement in 

structure compared to Alternatives 3 and 3A. This is also the case even if additional reductions 

in Authorized Use are required under Alternative 4.

SERAL STAGES

Introduction

The concept of seral stages is that, in the absence of disturbance, distinct plant communities

develop and, over time, move along a linear path until a relatively stable climax plant community 

is attained. Seral stages are assemblages of relatively distinct plant species that occur along the 

path of succession. They are generally classified as early, mid, and late. 

Early seral stages occur in heavily disturbed sites caused by intensive livestock or wildlife 

grazing, burrowing rodents, severe fire, extended drought, and natural erosion and deposition. In 

general, low-stature species such as blue grama and sedge dominate the early seral stages among 
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Chapter 3 | 187

western wheatgrass/ needlegrass potential communities. Early seral stages can also have an 

abundance of annual forbs, annual grass, club moss (Selaginella densa Rydb.), and/or bare 

ground. 

Mid seral stages contain a mixture of early and late seral species, with the latter involving mid 

and tall grasses such as western wheatgrass and needlegrass species in sites with loamy or finer 

textured soil, and little bluestem and prairie sandreed in sandy or less developed soil. 

Late seral stages are attained with continued plant community development as the mid and tall 

height grasses gain dominance over short grass species. The greatest plant diversity often occurs 

among the early and mid seral stages, but late seral communities tend to exhibit the greatest plant 

production and structure. 

The seral stage is important to consider for many reasons. In terms of range management, the

assessment of plant composition is critical for determining forage production, carrying capacity,

and for establishing appropriate stocking rates and seasons of use to maintain sustainable grazing 

systems (NRCS 2006) and achieve other resource objectives. Monitoring of species composition 

is required to quantify the effects of management and environmental influences, and to determine 

if desired goals and objectives for the rangeland resource are achieved, including the 

maintenance of natural ecosystems and biodiversity. The seral stage was estimated through 

measurements of the prominent grass species with respect to habitat types and ecological sites

most commonly utilized by livestock.

Spatial and Temporal Setting

The NFS lands located within the project area boundary are the analysis area for the plant seral 

stage analysis. This is a sufficient analysis area for the seral stage analysis because these are the 

lands that will be directly affected by decisions made from the implemented alternative. The 

temporal scope of the analysis is 10 to 15 years. 

Methodology

The data sampling methodologies used for the seral stage analysis are briefly presented below. A 

detailed discussion of the methodologies is located in the Botany Report (Project Record, 

Specialist Reports and Notes).

FOREST SERVICE 2005 SERE PLOTS

Fifty-three randomly selected sites were sampled during 2005 to assess plant composition and 

the proportion of early, mid, and late seral stages relative to western wheatgrass–green

needlegrass and western wheatgrass–needle-and-thread climax communities or habitat types 

(HTs). The sample sites were later cross-referenced to NRCS ecological site (ES) maps 

developed from soil layers by the NRCS (2009). Based on vegetative and edaphic (soil) keys 

(Jensen et al. 1992), 41 of the sites occurred in the western wheatgrass/green needlegrass HT, 

while 12 sites occurred in the western wheatgrass/needle-and-thread HT. Areas adjacent to 
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188 | Chapter 3

fencelines, water tanks, roads, and prominent trails were buffered to avoid potential areas of high 

or concentrated disturbance. 

Sampling protocol for the sere plots followed the Natural Resource Inventory System (NRIS) for 

terrestrial vegetation (USFS 2008), and sampling designs specific to this project are located in

the Supporting Documentation – Seral Stages section of the Project Record. A 150 foot baseline 

was established for each macroplot. The azimuth of the baseline was recorded, and the baseline 

midpoint was recorded via Global Positioning System (GPS). Three 100-foot transects were 

established perpendicular to the baseline, with the first transect randomly established between 0 

and 50 feet, and the second and third transects spaced at 50-foot intervals. Transect azimuths 

were recorded. Twenty 20- x 50-cm (1.1-ft2) plot frames (microplots) were sampled every 5 feet 

along each transect, for a total of 60 microplots per sample. Key plant species primarily 

involving grasses and shrubs were chosen for measurement based on their significance in 

defining the habitat type and seral stage (Uresk 1990, 2006a). Percentage cover of plant basal 

area by species was recorded in each microplot utilizing seven Daubenmire cover classes (< 1

percent, 1-5 percent, 5-25 percent, 25-50 percent, 50-75 percent, 75-95 percent, 95-100 percent). 

Measurements of ground cover included total plant basal area, plant litter, bare ground, rock, 

moss, and lichen. Frequency values by species and ground components were determined by the 

proportion of the 60 microplots in which a respective measurement was recorded.

FOREST SERVICE 2006 TO 2010 SERE PLOTS

Twenty-six sites were sampled in the project area from 2006 through 2008 and another 9 sites 

were sampled during 2009 and 2010. Allotments or pastures were chosen for sampling based on 

a lack of current plant composition data. Ten of the sample sites involved re-measurement of 

ecoplot samples originally measured from 1996 through 1999 for an inventory and 

characterization of habitat types across the LMNG. Ecoplot sampling methods involved ocular 

estimates of plant canopy cover within 0.1-acre circular plots. The ocular estimates were 

repeated during measurement of the sere plots, but the primary sample was collected with the 

NRIS sampling protocol as described above by roughly centering the 100-x150-foot macroplot 

over the ecoplot location. Percentage canopy cover by species was recorded in each microplot 

utilizing the seven Daubenmire cover classes identified above. Thirty-four of the 35 sample sites 

involved the western wheatgrass–green needlegrass HT, and one sample site occurred in the 

western wheatgrass–needle and thread HT. NRCS (2009) maps were referenced to determine the 

ES for 2006 samples, but field keys (NRCS 2007) were utilized to determine the ES at the time 

of sampling from 2007 through 2010.

As discussed below under Data Analysis, only species frequency was planned for measurement 

after 2005 because a seral stage model developed from the 2005 data indicated plant basal cover 

was not statistically significant (Uresk 2006b). However, plant canopy cover was included in the 

measurements because it provided additional information to estimate relative species 

composition. Thus, measurements of canopy cover replaced basal cover after 2005. Total plant 

basal area along with other ground components was measured within each microplot similar to 
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Chapter 3 | 189

the 2005 measurements. As described in NRIS-Terra (USFS 2008), plant basal area was 

measured along a plane one inch above the ground surface.

Canopy cover measurements were adjusted slightly upwards when moderate defoliation of a 

particular species had occurred within a microplot, or when species were at an early stage of 

growth. Adjustments were confined to recording the next highest cover class when a grazed 

species occurred near the upper range of a cover class, and primarily involved mid and tall grass 

species rather than short grass species such as blue grama. For instance, 4 percent cover (cover 

class 1 (1-5 percent) of western wheatgrass was often recorded as cover class 2 (5-25 percent) if 

the plants showed significant levels of grazing. This concept is similar to reconstruction 

techniques recommended by NRCS (2006) to estimate actual annual production from early 

season measurements or partially grazed vegetation.

An important omission of the 2005 species sampling list involved species of sedge that were 

included among later sample measurements. The primary species involved threadleaf sedge 

(Carex filifolia Nutt.) and sun sedge (Carex heliophila Mack.), but all sedge species were 

collectively measured and recorded as sedge to avoid misidentification. Cover of buffalo grass 

(Buchloe dactyloides (Nutt.) Engelm.) was combined with blue grama. Canada bluegrass (Poa 

compressa L.) was common on several sites and cover measurements were combined with 

Kentucky bluegrass . The term bluegrass hereafter includes both Canada and Kentucky 

bluegrass. Similarly, cover of cheatgrass (Bromus tectorum L.) was combined with the more 

common Japanese brome, and the two species are referenced as annual brome. Other recorded 

species included increaser forbs and half-shrubs, particularly sage species (Artemisia spp), 

dandelion, western yarrow (Achillea millefolium L.), and pussy-toes (Antennaria spp). 

Additional grass, forb, and half-shrub species were recorded as encountered on different sites if 

they were prominent or indicative of the seral stage or potential range trends. 

NDSU 2008 TO 2009

Ninety-eight sites were sampled by NDSU during 2008 and 2009 and referenced to the dominant 

ecological site that was verified in the field with soil pits and NRCS keys. Sample locations were 

buffered 164 feet (50 meters) from roads and fencelines, and 656 feet (200 meters) from water 

developments. 

During 2008, two transects extending 492 feet (150 meters) were established in a cross-wise 

fashion extending north-south and east-west. The transects were photographed and the 

intersection of these two transects was recorded by GPS. Plant basal cover by species was 

measured with 10 point pin frames every 16.4 feet (5 meters) along each transect. Species 

canopy cover was similarly measured from some of the sites. Percent frequency of grass species 

and density of forb species were measured every 32.8 feet (10 meters) along each transect with 

2.69 ft2(0.25 m2) plot frames. Biomass clippings were collected from most sites at four points 

spaced every 98 feet (30 meters) along the left side of each transect with a 1.92 ft2 (0.18 m

2

)

clipping ring, with plant species grouped according to dominant life form or functional group of 

cool season native grasses, warm season grasses, invasive grasses, forbs, shrubs, and plant litter. 

Seventeen indicators of Rangeland Health were assessed within the area of each sample site. 
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190 | Chapter 3

Transect lengths were shortened to 246 feet (75 meters) during 2009 after determining that this 

length was sufficient to characterize the above parameters. The shorter transects had the 

advantage of decreasing the incidence of crossing over into different ecological sites that 

occurred during 2008. Plant basal cover by species, frequency of grass species, and density of 

forb species was measured every 16.4 feet (5 meters) along each transect as described above. 

Plant canopy cover was not measured during 2009. Biomass clippings were collected at three 

rather than four equally spaced locations along each transect, and the production of individual 

plant species was measured rather than grouping growth forms (grasses, shrubs, etc.) as was 

conducted during 2008. 

ECOPLOT DATA

Eighty-seven 0.1 acre circular plots sampled from 1996 through 1999 within the project area 

were utilized as an additional source of baseline data to characterize general plant composition 

and estimate seral stage among the decade-old sample points. Ocular estimates of species canopy 

cover was estimated within each sample plot, but there was a moderate range in the number of 

species recorded based on differences in minimum cover values established for different sample 

subsets. Some of the sample sites were clustered within relatively small areas that had the 

potential to skew the results, but the clusters were usually established to characterize a gradient 

of conditions, such as those occurring with decreasing distance to a water source. 

PACE TRANSECTS

Pace transects were conducted within several allotments in the project area from 1977 through 

1980 to measure plant species frequency. Methodology associated with these transects involved 

recording the plant species or ground component that would fall within a 3⁄4-inch loop 

consistently placed at the toe of a shoe or boot along a transect with 100 measurement stations 

(USDA Forest Service 1977). Measurement stations were usually spaced at intervals of one pace 

(equal to two steps), with a resulting transect length of about 600 feet. A few sample sites 

involved measurement intervals of two paces (four steps), for a transect length of about 1,200 

feet. Twenty-eight samples with sufficient documentation of site locations and transect bearings 

were re-measured during 2009 and 2010. Photographs were taken to document existing 

conditions. Impediments to re-measurement of some sites included poorly documented sample 

locations or transect bearings, the addition of new fencelines adjacent to transects, or heavy 

grazing that increased the difficulty of species identification. Maps of dominant plant 

communities for several allotments or pastures were included with the 1977-80 transect data and 

these were utilized in the assessment of trends in plant composition. 

BELT TRANSECTS

Ninety-three belt transects (Grant et al. 2004) were measured in the project area during 2004. 

The dominant functional group (warm season native short grass, cool season introduced mid 

grass, etc.) was identified every meter along a 25-meter transect. The two to three dominant grass 
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Chapter 3 | 191

species were also identified along each transect, and the data provided generalized information of 

plant composition and production. 

ROBEL POLE

Plant structure as measured with Robel poles (Project Record, Specialist Reports and Notes, 

Wildlife Report) included recording the dominant grass species at 20 stations along 300- to 400-

foot long transects. One hundred eighty-four Robel transects were measured in the project area. 

The plant species data was used to supplement general plant composition characteristics within 

pastures. 

FIELD OBSERVATIONS

Notes of general grassland composition were collected while traversing several pastures on foot 

during the course of woody draw and seral stage sampling. This information was used to 

supplement descriptions of general plant composition. 

BROKEN LANDS 

Previously farmed and abandoned cropland, hereafter referenced as broken land, was identified 

from a GIS layer constructed from aerial photographs from the 1930s and 1950s. These lands 

were generally re-seeded to non-native crested wheatgrass and currently tend to support a 

mixture of crested wheatgrass, varying amounts of several native grasses, and invasive bluegrass, 

smooth brome (Bromus inermis), and annual brome. Other areas with high proportions of 

invasive grasses occurring outside of broken land were delineated during various fieldwork and 

pasture visits. An inventory of heavily invaded portions of the project area is incomplete but a 

partial map layer is included in Appendix A of the Botany Report (Project Record, Specialist 

Reports and Notes). 

DATA ANALYSIS

The above data were utilized to estimate the distribution of seral stages in the project area. The 

sere plot data (2005; 2006 to 2010) were analyzed with respect to habitat types by comparing 

field measurements with quantitative descriptions of the habitat types (Jensen et al. 1992, 2002). 

These data were also evaluated with respect to the ecological sites by comparing species cover 

measurements with quantitative descriptions of the relative plant composition for the ecological 

site (NRCS 2006, 2009). Seral stage of the NDSU sample sites (2008 and2009) was estimated by 

comparing production and/or cover measurements with quantitative descriptions of the 

ecological site and associated state and transition models (NRCS 2006, 2009). 

The state and transition models categorize plant composition into different vegetation states. 

Four states were used in this analysis—Reference State, Native Invaded, Invaded, and Other, 

which in this analysis is identified as planted broken lands. For further explanation of these 

categories see the Botany Report (Project Record, Specialist Reports and Notes). 
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192 | Chapter 3

Seral stage was estimated from the ecoplot data (1996-1999) by comparing measurements of 

plant canopy cover to habitat type descriptions. While these data are valuable, the sampling 

methodology used to collect the data was not as rigorous as the more current sere and NDSU 

data. 

Measurements of species and ground component frequency obtained from the pace transects 

from 1978 through 1980 and 2009 through 2010 were compared to evaluate changes or trends in 

plant compositions. 

A multivariate analysis of the 2005 sere data was also completed. This analysis identified 

frequency of western wheatgrass and blue grama as the only significant measured parameters. 

However, because field evaluation of the model indicated that species frequency was not an 

accurate indicator of existing seral conditions, this model was not used to determine seral stage 

analysis.

The Botany Report (Project Record, Specialist Reports and Notes) contains a detailed description 

of the above analyses.

Affected Environment—Seral Stages 

This section provides a general description of the information related to seral stages for the 

project area. A detailed description of the existing condition of the seral stages in each allotment 

is provided in Part 2 of this chapter.

EXISTING CONDITION

The results of the sere analysis are displayed in Table 3.27. With regard to the collective sere 

plots sampled between 2005 and 2010, the seral stage proportions were similar when evaluated 

with respect to habitat types or ecological sites, with the major difference involving the 

classification of Invaded Grass States that were not assigned a seral stage when referenced to

ecological sites and state and transition models.

The sere plots and NDSU plots measured from 2005 through 2010 provided the most current and 

accurate evaluation of plant composition and seral stages across the project area. The proportion 

of early, mid, and late seral stages of about 7, 72, and 5 percent, respectively, indicate a shortage 

of early and late seral stages compared to desired conditions. Sixteen percent of sites were at an 

Invaded Grass State (Table 3.27) and represent an undesired condition due to adverse effects on 

the maintenance of native plant communities, associated biodiversity, and the sustainability of 

current rangeland resources

The results identified in Table 3.27 for the 2005 and 2006 to 2010 data agree with general field 

observations (Project Record, Specialist Reports and Notes, Botany Report) that indicated a 

predominance of mid seral communities and relatively few areas of early and late seral 

communities among the primary areas of livestock use.

Analysis of the ecoplot data set from 1996 to 1999 suggest that seral stages were at 15, 64, and 

21 percent of early, mid, and late seral stages, respectively, very close to seral objectives 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

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identified under the current Grasslands Plan. This information, when compared to the sere plot 

analysis, is suggestive of a downward trend in late and early seral stages and an upward trend of 

mid seral stages during the past 10 to 14 years. However, because of differences in sample 

methodology, the ecoplot and sere plot data are not statistically comparable. 

Table 3.27 — Seral stage percentages by methodology

Early Seral

Stage

(%)

Mid Seral

Stage

(%)

Late Seral

Stage 

(%)

Invaded 

Grass State

(%)

Grasslands Plan seral stage 

objectives 10-15 65-75 15-20 NA

Ecoplot data(1996-1999) 

compared to habitat types 

descriptions

15 64 21 NA

Sere data (2005; 2006-2010

compared to habitat type 

descriptions 8 85 7 NA

Sere data (2005; 2006-2010)

compared to ecological site 

descriptions)

7 76 5 13

Sere data (2005; 2006-2010) + 

NDSU data compared to 

ecological site descriptions and 

state and transition models

7 72 5 16

Current data provide evidence that invasive grasses are spreading and increasing throughout 

upland grass communities in the project area. This is of greater concern than the proportion of 

seral stages because of the adverse effect of invasive grasses on the maintenance of native plant 

communities and diversity. Remeasurement of the 28 pace transects with the same methodology 

and site locations provided strong evidence of an increase in invasive grasses, with the average 

relative frequency of all invasive grasses increasing from 21 to 37 percent, and Kentucky/Canada 

bluegrass increasing several fold, from 4 to 20 percent between 1980 and 2010.

The sere and NDSU data (185 plots) also indicate that invasive grass species are affecting the 

project area. Analysis of the plots found that 16 percent of the plots were at an Invaded Grass 

State where invasive grasses comprised greater than 40 percent of the relative grass cover among 

sere plots, or more than 30 percent of the total plant biomass with less than 40 percent native 

grass production among NDSU plots with species production data.

Of the 155 sites not at an Invaded Grass State, 15 or 10 percent were identified at a Native 

Invaded State (or a Planted Invaded State for broken land). Invasive grasses constituted 25 to 40 

percent of the relative grass cover among sere plots at this phase, or up to 30 percent of the total 

forage biomass among NDSU plots with species production data when native grasses constituted 

more than 40 percent of the total production. These sites are at a high risk of transitioning to an 

Invaded Grass State without intensive management targeted to reversing the trend of increasing 

invasive grasses (NRCS, 2009).
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Of the 155 sites not at an Invaded State, 128 or 83 percent were at Native Invaded or Planted 

Invaded States, with invasive grasses constituting up to about 25 percent of the total forage 

production as measured in the NDSU plots, or 25 percent of the relative grass cover as measured 

in the sere plots or NDSU plots where production data was not collected. Only 13 or about 8 

percent of the 155 sites were at a Native Vegetation State with no or only minor traces (0.2 

percent). A detailed description of the state and transition model and its results are contained in 

the Botany Report (Project Record, Specialist Reports and Notes).

There are several invasive grasses including Kentucky and Canadian bluegrass, smooth brome, 

Japanese brome, and cheatgrass located in the project area. Of these grasses, Kentucky/Canadian 

bluegrass are of greatest concern because they are the most aggressive and persistent of the 

species. They are able to colonize a wide range of plant communities and habitats and do not 

necessarily require a high degree of disturbance to invade a site. 

A fundamental principle of range management involves a change in species composition as a 

result of selective utilization of certain plant species that confers a competitive disadvantage and 

allows other plant species to increase in dominance (Belsky and Gelbard 2000, Briske et al.

2008, Dyksterhuis 1949, Holechek et al. 1999, Lewis et al. 1956, NRCS 1997, Trammel and 

Butler 1995). Although Kentucky bluegrass can provide quality forage early in the grazing 

season, nutrient quality and palatability sharply decrease during and after seed production that 

occurs by early to mid June (NRCS 2009). Thus, a significant portion of the available forage is 

likely to be surrendered when Kentucky bluegrass constitutes a prominent portion of the plant 

composition and grazing is initiated after late spring or early summer, when palatability and 

utilization of the species decreases. Mid and late summer grazing periods among mixed invasivenative grass pastures are likely to result in excessive utilization of the native component because 

grazing extent and production has been decreased in proportion to the extent of invasive grasses. 

Increased utilization of the native grass component therefore confers a competitive disadvantage 

to these species and establishes positive feedback for additional invasive grass expansion. Poor 

coordination of the grazing season with invasive grass palatability is referenced as a 

composition-timing conflict in table summaries and effects analysis that follow.

DESIRED CONDITION

Plant communities are desired to be dynamic, with the continuum of seral stages shifting across 

the landscape over time. The desired proportion of seral stages for grassland habitat types among 

both the Badlands and Rolling Prairie Geographic Areas is 10-15 percent Early, 65-75 percent 

Mid, and 15-20 Late (Grasslands Plan, pp. 2-11, 2-19). A full spectrum of cool- and warmseason grass species and communities is desired to maintain or perpetuate inherent diversity of 

the system (Grasslands Plan, pp. 2-10, 2-17). 

Environmental Consequences—Seral Stages 

Intensity, frequency, and timing of disturbance on native species communities, and how these 

affect trends towards seral objectives, collectively constitute one of the indicators used to address 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

Chapter 3 | 195

seral stages. As intensity and frequency associated with livestock grazing increases, plant 

composition shifts towards early seral stages. As disturbance associated with livestock grazing 

decreases, plant composition shifts toward late seral stage. Changes in the timing of livestock

grazing disturbances can also affect seral stages by changing the species that are selected;

therefore, those species are competitively disadvantaged.

Intensity, frequency, and timing of disturbance also affect trends in invasive grasses that reduce 

the areas ability to provide the desired proportion of seral stages; therefore, the analysis also uses 

trends of invasive grasses. A decreasing trend of invasive grasses will increase the potential for 

achieving desired seral stage objectives. Increasing trends in invasive grasses decreases the 

potential for achieving desired seral stages objectives.

DIRECT AND INDIRECT EFFECTS 

Alternative 1 

Research on the Northern Great Plains (NGP) has shown that long-term moderate and high 

stocking levels similar to those occurring in most allotments of the project area result in 

increased dominance of early seral species, with corresponding decreases in late seral species 

(Barker and Whitman 1989, Biondini and Manske 1996, Brand and Goetz 1986, Holechek et al.

1999, Jensen et al. 1992, Lauenroth et al. 1994, NRCS 2009, Rauzi 1963, Sims et al. 1978, 

Whitman and Wali 1975, Willms et al. 2002). Thus, removal of current livestock grazing 

pressure would create conditions favorable for a shift of grassland communities towards late 

seral stages and potential climax communities. A shift towards late seral stages would likely 

result in decreased plant diversity or species abundance (Milchunas and Lauenroth 1993) 

involving early and mid seral grasses and forbs. The greatest decrease would occur in the

abundance of early seral species, but they would persist on sites of poorly developed soil or areas 

of primary and secondary succession such as residual buttes and parent material outcrops, sites 

of natural erosion/deposition, and prairie dog towns or other sites heavily disturbed by wildlife.

However, invasive grasses complicate typical paths of succession in much of the project area. 

Invasive grasses have a high potential to continue spreading, even if livestock grazing is 

removed due to inherent competitive abilities and as assisted by increasing plant litter that 

increases moisture conservation. Decreased plant diversity results with increased dominance of 

invasive grasses (Sedivec 2006). Populations of invasive sweet clover may assist invasive 

grasses by increasing nitrogen availability (NRCS 2009, but see Van Riper and Larson 2009), 

and removal of livestock that selectively graze sweet clover could assist greater seed production 

and prominence of the species, thereby assisting further invasive grass expansion.

Less invasive crested wheatgrass would persist at present locations that principally involve 

broken land and other highly disturbed sites where it was seeded. Expansion of crested 

wheatgrass into heavily grazed or disturbed sites would decrease, and native grass species 

intermixed with crested wheatgrass would possibly increase with the removal of selective 

grazing pressure that these species presently experience among several broken land pastures.

Increased expression of native grasses would contribute to community development and later 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

196 | Chapter 3

seral stages, but invasive grasses are also invading areas of broken land and have the potential to 

continue increasing. 

In summary, removal of livestock grazing would contribute to potential shifts in plant species 

composition towards late seral stages, with a decrease of early and mid seral stages and species.

Thus, Grasslands Plan Desired Conditions for seral stages would not be met. However, invasive 

grasses already present in the system have a high potential to continue increasing with or without 

livestock grazing, and would likely impede the development or long-term maintenance of late 

seral native plant communities. Furthermore, native plant diversity or abundance would decrease 

with increased invasive grass dominance. Natural dispersal of invasive grasses and noxious 

weeds would continue and be assisted through vectors of oil and gas development, road 

maintenance, recreation, and wildlife. 

Alternative 2

Current management actions and stocking levels would continue under this alternative. Existing 

seral stage distribution would likely be maintained for a time; however, the apparent trend of 

increasing invasive grasses would be expected to continue under Alternative 2 and would be 

assisted by the current management practices outlined below.

 Moderate to high stocking levels - Moderate to heavy seasonal or seasonlong stocking 

rates repeated on an annual basis can facilitate the spread of bluegrass and other invasive 

grasses when they are present in the system (Belsky and Gelbard 2000, Briske et el. 2008, 

NRCS 2009, NRPH 1997, Trammel and Butler 1995, Uchytil 1993). Many pastures in 

the project area have been grazed seasonlong or are affected by repeated grazing rotations 

during a single year. The average weight of most modern cow breeds has significantly 

increased since the late 1940s (Carter 2008, Dhuyvetter 1995, Hancock 2006). Larger 

cows eat more forage, which isn’t adjusted for under this alternative.

 Composition-Timing Conflicts - Determination of stocking rates based on the production 

of key species and key areas of utilization is a standard range management practice 

(Hancock 2006; NRCS 2006, 1997; Brisket et al. 2008; KSU 1994), but there is a general 

lack of prescribed grazing that incorporates optimum periods of palatability and 

utilization of invasive grasses, including crested wheatgrass. A significant portion of the 

available forage is unused or underutilized when grazing is initiated after the period in 

which invasive species are likely to be most utilized. The result is likely to be excessive 

utilization of the more palatable native grass component, which improves conditions for 

additional invasive grass expansion. This situation is referenced as a composition-timing 

conflict and affects about 70 percent of the allotments to varying degrees. 

 Hay feeding - Most hay is fed in the winter and is often composed of a variety of grasses 

including crested wheatgrass; more aggressive invasive species of sweet clover, smooth 

brome, bluegrass, and annual brome have also been observed. High livestock densities in 

hay feeding areas can result in high levels of trampling, often compounded by moist soil 

conditions. The native grass component is grazed during hay feeding periods during 

relatively open winters and early spring, potentially contributing to excessive use and low 
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Chapter 3 | 197

production the following year. The resulting levels of winter use and the introduction of 

invasive grass seed through the hay likely assists the establishment of these species by 

improving seed-soil contacts and decreasing the competitive ability of native grasses. 

Invasive species have increased under the current grazing management and would continue. 

Alternative 2 would move further away from Grasslands Plan seral stage objectives.

Alternative 3

A summary of the effects of initial actions by allotment is presented in the Table 3.28. A detailed 

discussion of each allotment is contained in Part 2 of this chapter. 

Table 3.28 — Effects of proposed actions on current trends of plant composition under 

Alternative 3

Allotment

Number

Effect of Initial

Actions Rationale

126 Neutral

Similar management complicated by multiple 

livestock herds twelve month use, and mixed 

native/invasive grass pastures. 

127 Neutral Slightly delayed turn-in. AU 37% > CC but 

recently reported use close to CC. 

128 Neutral Slightly delayed turn-in but similar management. 

AU 56% > CC and 17-58% > reported use.

129 Neutral

Positive and negative effects of riparian pasture 

and replacement of water sources. Hay feeding 

introduced to pasture 2 (now part of A-131). AU 

17% < CC and 7-31% > reported use including 

winter use.

130 Negative

Hay feeding introduced to new pasture and 

persistent CT conflicts. AU 8% > CC, and < to > 

reported us including winter use.

131 Neutral

Positive and negative effects of exchanging 

pastures with Allotment 129. Increasing pasture 

size could increase secondary range but adverse 

effects of hay feeding in new pasture. AU 41% < 

CC but reported use 27-54% > AU not including 

additional winter use. 

132A Neutral Similar management with CT conflicts, AU 27% 

> CC, 5% < to 23% > reported use. 

132H Neutral

Decrease of pasture size and increase of pasture 

deferment would benefit litter management but 

intensify CT conflicts and reduce secondary 

range. AU 5% > CC and 15% < to 24% > 

reported use.

133 Neutral

Similar management with increasing invasive 

grasses. 

AU and reported use 58% > CC.

133D5 Neutral Same management with increasing invasive 

grasses.
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198 | Chapter 3

Allotment

Number

Effect of Initial

Actions Rationale

134 Neutral

Switching from 3 times through to a twice 

through rotation would not change CT conflicts. 

AU 33% > CC and 19-26% > reported use. 

135 Slightly

positive

Juniper control. 3 rather than 2 pasture rotation 

(P 8, 9, 10). Delayed turn-in 2 of 3 years would 

benefit P8 but adversely affect winter pastures. 

AU 16% < CC and > to < reported use not 

including additional winter use. 

136/139 Slightly

positive

Benefit in 2 of 4 pastures proposed for early 

season use but increasing CT conflicts persist in 

remaining 2 pastures. Increased disturbance with 

needed water tank. AU 46% > CC and 9-36% > 

reported use. 

140 Negative

Increasing CT conflicts in 1 pasture and partially 

increased in another. AU 36% > CC and 0-39% 

> reported use. 

141 Neutral Same management. AU 81% > CC and = 

reported use 

142 Negative

Continued CT conflicts in P1 and creation of CT 

conflict in P2. AU 50% > CC and 17-92% > 

reported use. 

158 Neutral

Delayed turn-in 2 of 3 years in individual 

pastures but otherwise similar management. AU 

18% > CC and much > reported use not 

including additional winter use.

220 Neutral Similar management. AU 64% > CC, 0-22% > 

reported use. 

221 Slightly

positive

CT conflicts slightly reduced in P2 and P3 but 

persist in P6. AU 63% > CC and about 5% > 

reported use. 

230 Slightly

positive

Improved grazing system in P1, CT conflicts 

persist in P2, winter use/ hay feeding potentially 

halted in P3 but uncertain long-term

management and effects. Delayed turn-in. AU 

17% > CC and 30% > typically reported use not 

including winter use. 

237 Neutral

Positive and negative effects of new tank in P1, 

but persistent CT conflicts. AU 32% > CC and 

40-55 > reported use. 

239 Neutral

Persistent CT conflicts with trend of increasing 

bluegrass, AU 64% > CC and 32-85% > 

typically reported use. 

240 Neutral

Remove livestock from P4 by March 15 but 

varying levels of persistent or increasing CT 

conflicts in most pastures. Reported use 2-32% > 

AU and additional winter use. 
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Allotment

Number

Effect of Initial

Actions Rationale

241 Neutral

Same management with increasing invasive 

grasses. Reported use much < AU but high levels 

of additional winter use in P1. 

243 Neutral

Positive and negative effects of new water tank, 

halt twice-over grazing but persistent CT 

conflict. Reported use = or slightly> AU that is 

24% > CC. 

244 Slightly

positive

Split out crested wheatgrass pasture but CT 

conflicts in remaining two pastures. Reported use 

similar to AU that is 12% > CC. 

248 Neutral

Same management with CT conflicts and 

invasive grasses dominating much of allotment. 

AU 38% > CC. Reported use usually close to 

AU but as much as 23% <. 

249 Slightly

positive

Staggered 3.5 month season of use. AU and 

reported use 21% > CC.

256 Slightly

positive

Creation of large riparian pasture, 4-pasture 

deferred rotation with P2, delayed turn-in. AU 

9% > CC, reported use usually < AU but ranges 

from 17% > to 65% <. 

258 Slightly

negative

Delayed turn but new tank would increase the 

evenness of utilization. AU 41% > CC and at 

least 45% > reported use. 

272 Neutral

Persistent CT conflicts and minimal benefit of 

new water tanks. AU 15% > CC and close to 

reported use.

277 Neutral

Similar management with CT conflicts in P1 and 

P5. AU 4% > CC and 5 > to 7%<> reported use 

including winter use. 

278 Positive Switch to early season use of all three pastures. 

AU 36% > CC and 10-27% > reported use. 

281 Neutral

Similar management with CT conflicts in all 

pastures. 

AU 25% > CC. 

282 Neutral

Similar management. Positive and negative 

effects of reducing sagebrush in P5 & P6. AU 

15% < CC and 10-30%% > reported use 

including winter use. 

283 Neutral

Similar management. Increased level of 

concentrated disturbance associated with new 

water tank. AU equals CC but additional winter 

use. 

286 Neutral

Implement 3-pasture deferred rotation but 

varying levels of CT in each pasture. AU 36% > 

CC and 55-127% > reported use. 
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Allotment

Number

Effect of Initial

Actions Rationale

287 Neutral

Strive for greater pasture deferment but 

ineffective pasture fencelines/barriers. AU 15% 

> CC and 17-25% > typically reported use.

288 Slightly

positive

Benefits of a deferred rotation and water 

management but CT conflicts. AU 43% > CC 

and 23-29% > recently reported use.

289 Negative

Adverse effects of new water tank in P3, positive 

and negative effects of splitting pasture 2 but 

potential for adverse effects to other pastures. 

AU 10% > CC and 67% > to 7% < reported use 

not counting additional winter use. 

300 Neutral

Positive and negative effects of new water tank 

but would effect a small area. AU > 7% CC and 

4-15% > recently reported use. 

301 Slightly

positive

Water management of two springs, delayed turnin but CT conflicts in P3 and increasing in other 

pastures. Potential switch to once-over rotation 

but not stipulated. AU 10% > CC and 0-20% > 

reported use. 

302 Slightly

positive

Manage access to 3 reservoirs. Potentially 

combine herds and switch to deferred rotation, 

delayed turn-in but CT conflicts due to 30% and 

18% broken lands in the two pastures. AU 14% 

> CC and 0-66% > recently reported use.

AU= Authorized Use, CC= carrying capacity, CT=composition-timing conflict, 

wheatgrass, P=Pasture, > = greater than, < = less than.

Collective initial actions under Alternative 3 would improve plant composition in 11 of the 43 

allotments. Of the 11 allotments, 10 are projected to show slight improvement and one 1 would 

show marked improvement. Of the remaining 32 allotments, 26 would experience no change in 

the current trend of plant composition and would remain neutral, and 6 allotments are projected

to experience a decreasing trend in seral conditions as a result of the proposed actions.

The trend of increasing invasive grasses is likely to continue under Alternative 3. The main 

practices contributing to this outcome involve the persistence of varying levels of compositiontiming conflicts in about 70 percent of allotments with high amounts of invasive grasses. 

Adverse effects associated with hay feeding would continue. These factors would likely result in 

downward trends of late seral stages and adverse effects on the maintenance of native plant 

communities. 

Change in grazing strategies that have the potential to result in varying levels of decreased 

composition-timing conflicts would occur in a small portion of invasive grass infested 

allotments. 

The proposed action of delaying turn-in dates until June 1 or after sufficient growth is attained in 

native-dominated pastures has the potential to assist plant health and community development 

among all affected pastures compared to premature grazing that often occurs at present (Manske 
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Chapter 3 | 201

2001, Peck et al. 1994, Cook and Child 1971). Early May and occasionally late April turn-in into 

crested wheatgrass or invasive pastures is appropriate for coordinating grazing with periods of 

high palatability for these species. Efforts to shift grazing periods towards early use of invasive 

grasses is proposed among relatively few affected allotments. 

Managing water sources would likely improve livestock distribution and decrease levels of 

excessive utilization in some pastures. The addition of new water sources has the potential to 

result in similar benefits. However, increased distribution has the potential to result in decreased 

secondary range and a decrease in seral stages and high structure. Disturbances associated with 

new water developments are likely to facilitate local spread of invasive grasses. 

Across the project area, continued levels of apparent overstocking and composition-timing 

conflicts are likely to facilitate current trends of increasing invasive grasses and shifts towards 

early seral and/or invaded grass states.

If monitoring reveals that initial actions are not resulting in the desired outcome, then additional 

adaptive management actions would be implemented. The primary effect under this alternative is 

that the timeline to meet the seral objectives would be extended beyond the 10- to 15-year 

timeframe associated with this project.

Alternative 3A 

Alternative 3A differs from Alternative 3 in 14 of the allotments, which are identified in Table 

3.29. Initial actions proposed in 10 of these allotments (126, 127, 129, 142, 240, 243, 258, 272, 

278, 300) are not expected to affect seral stage / plant composition any differently than 

Alternative 3. Of the remaining 4 allotments (135, 244, 287, 301), all would experience a shift 

away from the Grasslands Plan seral stage objectives. 

The effects of adaptive management actions are the same as identified under Alternative 3.

Table 3.29 — Effects of proposed initial actions on plant composition under Alternative 3A

Allotment 

Number

Effect of

Initial 

Actions

Rationale

126 Neutral Minimal effect of not fencing spring in pasture 4. Otherwise similar management complicated by multiple livestock herds, 12-month use, and 

mixed native/invasive grass pastures. 

127 Neutral Increased use around existing developed spring would be countered by decreased use of other water sources. Slightly delayed turn-in. AU 37% > 

CC but reported use close to CC. 

129 negative

Increased disturbance around additional water tank. Positive and negative 

effects of riparian pasture and replacement of water sources. Hay feeding 

introduced to pasture 2 (now part of A-131). AU 17% < CC and 7-31% > 

reported use including winter use.
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Allotment 

Number

Effect of

Initial 

Actions

Rationale

135 Neutral

New tank would be developed in current high use area with no change in 

livestock distribution. Juniper control. 3 rather than 2 pasture rotation (P 8, 

9, 10). Delayed turn-in 2 of 3 years would benefit P8 but could adversely 

affect winter pastures. AU 16% < CC and > to < reported use not including 

additional winter use. 

142 Negative

Increased CT conflicts with deferred rotation and increased pasture 

number but potentially forced use of invasive grasses with increased 

livestock density. 

AU 50% > CC and 17-92% > reported use.

240 Neutral Persistent or increasing CT conflicts in P1 regardless of potential fencing of two reservoirs. Some benefit of removing livestock from P4 by March 

15. Reported use 2-37% > AU and additional winter use. 

243 Neutral Development of spring on west side of pasture would not change livestock distribution. Positive and negative effects of other new water tank but 

persistent CT conflict. Reported use = or slightly > AU that is 24% > CC. 

244 Neutral Not fencing stand of crested wheatgrass for early season use would forgo half of the pasture forage with persistent high use of unbroken land. 

Reported use similar to AU that is 12% > CC. 

258 Negative

Continued premature grazing of native grasses would impede plant 

development and production and increase opportunities for invasive grass 

spreading. New tank would increase the evenness of utilization. AU 41% > 

CC and at least 45% > reported use.

272 Neutral Development of spring would minimally influence livestock distribution in the small area of pasture 2. Persistent CT conflicts and minimal benefit of 

new water tanks in P1. AU 15% > CC and close to reported use.

278 Positive Not reclaiming reservoir would not affect livestock distribution or plant composition due to an adjacent water well and tank. Switch to early season 

use of all three pastures. AU 36% > CC and 10-27% > reported use. 

287 Negative

Additional water tank in secondary range would decrease mosaic of 

grazing pressure and seral stages. Strive for greater pasture deferment but 

ineffective pasture fencelines/barriers. AU 15% > CC and 17-25% > 

typically reported use. 

300 Neutral Not fencing or reclaiming developed spring would have minimal effect on livestock distribution due to relatively close proximity of new water tank. 

AU > 7% CC and 4-15% > recently reported use. 
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Allotment 

Number

Effect of

Initial 

Actions

Rationale

301 Neutral

Not fencing spring developments and reconstructing plumbing systems 

would prohibit control of livestock distribution. Potentially switch to onceover rotation, delayed turn-in but CT conflicts in P3 and increasing in 

other pastures AU 10% > CC and 0-20% > reported use. 

AU= Authorized Use, CC= carrying capacity, CT=composition-timing conflict,

P=Pasture, > = greater than, < = less than.

Alternative 4 

A summary of the effects of initial actions by allotment is presented in Table 3.30. Also provided is a short synopsis 

of the reasoning for the effects determination. A detailed discussion of each allotment is contained in Part 2 of this 

chapter. 

Table 3.30 — Effects of proposed actions on current trends of plant composition under Alternative 4 

Allotment 

Number

Effect of 

Initial 

Actions

Rationale

126 Negative

AU increased 42% = CC, 36-107% > reported use not including additional 

winter use. Positive change in grazing system by adding to A128 and 

implementing 7-pasture deferred rotation, but complicated by winter versus 

early-season pastures and CT conflicts in other pastures. 

127 Slightly 

positive Delayed turn in, AU decreased 27% = CC, 3% > to 16% < reported use. 

128 Positive Combined with A126 and switch to once through deferred rotation with 

delayed turn-in. AU decreased 36%, 0-25% < reported use. 

129 Neutral

Replace reservoir with water tank would increase disturbance in secondary 

range. AU decreased 13%, 7% < to 14% > reported use including winter use. 

Increased summer use in new pasture. Increased upland use with riparian 

pastures and adjustments needed for change in acreage after pasture exchange. 

130 Neutral

Increased early season use of crested wheatgrass in P8 and P9, but persistent 

CT conflicts in other pastures. Winter use/introduced to new pasture. AU 

decreased 7% < reported use including winter use.

131 Negative

Hay feeding introduced to pasture 129-2 that would become part of allotment 

131. Continued predominance of winter use and associated impacts throughout 

allotment. AU decreased 13% but reported use 27-41% > AU and additional 

winter use. 

132A Neutral Similar management with pronounced CT conflicts throughout allotment. 

Maintain AU 27% > CC and 5% < to 45% > typically reported use. 

132H Neutral

Similar management focused on early-season use. Increased pasture deferment 

increases potential for CT conflicts but may be impeded by unreliable water 

sources. AU decreased 5%, 19% < to 18% > reported use. 

133 Neutral Same grazing system with strong apparent trend of increasing invasive grasses. 

AU decreased 37% but high CT conflicts. 

133D5 Neutral Same management of cutting invasive grass hay.

134 Neutral Switching from 3 times through to a twice times through rotation would not 

change CT conflicts. AU decreased 25%, 5-11% < typically reported use.
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204 | Chapter 3

Allotment 

Number

Effect of 

Initial 

Actions

Rationale

135 Positive

Combine herds and switch to 5-pasture deferred rotation with delayed turn-in 2 

of 3 years, but potentially increased impacts in 2 winter pastures. Control 

juniper. AU decreased 13%, 10% > to 27% < reported use and additional 

winter use.

136/139 Slightly 

positive

Positive effect in 2 of 4 pastures proposed for early season use but increasing 

invasive grasses and CT conflicts in remaining 2 pastures. Increased 

disturbance around needed water tank. 

AU decreased 32%, 7-25% < reported use, but CT conflicts. 

140 Slightly 

negative

Increased CT conflicts in 1 pasture and partially increased in another pasture. 

AU decreased 27%, 0-28% < reported use. 

141 Neutral Same grazing system with high CT conflicts in both pastures. 

AU decreased 44% but may further assist invasive grasses. 

142 Negative Increased CT conflicts with deferred rotation. AU decreased 33%, 22% < to 

28% > typically reported use. 

158 Neutral

Delayed turn-in but several winter pastures with hay feeding and potential 

premature grazing. AU decreased 15%, 21-65% > reported use but additional 

winter use. 

220 Slightly 

positive

Same grazing system with AU decreased 39%, 26-40% < reported use, but 

may facilitate the increase of bluegrass. 

221 Slightly 

negative

AU decreased 38%, about 35% < reported use, but persistent or increased CT 

conflicts with 3-pasture deferred rotation. 

230 Slightly 

positive

Improved grazing system in P1, CT conflicts persist in P2, use shifted from 

winter to spring and late fall in pasture 3 with increased invasive grass 

utilization . AU decreased 14%, 11% > typically reported use not counting 

varying levels of current winter use. 

237 Neutral

Low or decreasing coordination of grazing seasons with invasive grass 

palatability. Positive and negative effects of new water tank in P1. AU 

decreased 24%, but 6-17% > reported use. 

239 Neutral Persistent CT conflicts. AU decreased 39%, 19% < to 13% > typically reported 

use.

240 Neutral

Potential shift from twice through to once through rotation but similar effects 

with persistent CT conflicts. AU decreased 6% but reported use often > AU 

not including additional winter use. 

241 Neutral

Similar management with CT conflicts in P3 and P6, increasing in P7. AU 

decreased 14% but > currently reported use due to a large portion of use 

occurring in P1 during the winter. 

243 Neutral Switching from modified twice over rotation to deferred rotation but persistent 

CT conflicts in both pastures. AU decreased 20%. 

244 Slightly 

positive

AU decreased 11% and CT conflict corrected in east half of P2, but persistent 

or increasing in remaining two pastures. 

248 Neutral

Two-week earlier turn-in and 2-pasture deferred rotation but similar effects 

with predominance of Invaded Grass States and CT conflicts. AU 38% > CC 

and 0-23% > reported use. 

249 Positive AU decreased 17%, staggered season of annual use. 
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Allotment 

Number

Effect of 

Initial 

Actions

Rationale

256 Slightly

positive

Delayed turn-in. Potentially improved conditions in P2 (& 2a) with creation of 

riparian pasture and 4-pasture deferred rotation with other allotment, but 

increased disturbance of 2 new water tanks. AU decreased 8%, but > currently 

reported use for most years. 

258 Neutral Delayed turn-in. Increased disturbance and decreased grazing mosaic with new 

water tank. AU decreased 29%, but 3-55% > reported use. 

258 Neutral Delayed turn-in. Increased disturbance and decreased grazing mosaic with new 

water tank. AU decreased 29%, but 3-55% > reported use. 

272 Neutral AU decreased 13% but increasing invasive grasses and CT conflicts in main 

summer pasture. Positive & negative effects of two new water tanks. 

277 Neutral

AU decreased 4%, 4-11% < total annual use including winter use. CT conflicts 

in P1 & P5. Halt thrice-over grazing but complicated by 12-month permit. 

Increased disturbance around new water tank. 

278 Positive

Switch to early season use of all three crested wheatgrass pastures. AU 

decreased 26%, 7-19% < reported use, but may facilitate increased litter and 

invasive grasses. 

281 Neutral Delayed Turn-in for P1, but significant invasive component. Adverse effects of 

new water tank in P1. AU decreased 20% but persistent CT conflicts. 

282 Neutral

Similar grazing system. Sagebrush control would increase forage production 

but may assist invasive grasses. Increased grazing at north boundary of P5/P6. 

Delayed turn-in complicated by 12-month permit. AU decreased 13%, 13% > 

to 4% < than total annual use including winter.

283 Neutral

Increased disturbance associated with new water tank. No change in 

management or AU. Poor record of use but AU much > reported summer use 

and much < total use including winter use. 

286 Neutral Persistent or increasing CT conflicts in all three pastures with deferred 

rotation. AU decreased 26% but 15-67% > typically reported use. 

287 Slightly 

positive

Switch to deferred rotation (but only partially effective pasture fence/natural 

barriers). AU decreased 13%, 1-8% > typically reported use.

288 Positive

AU decreased 30%, 9-14% < recently reported. Switch from seasonlong to 

compressed season and deferred rotation. Water management. Persistent CT 

conflicts in almost 1/4 of 640-acre pasture.

289 Negative

AU decreased 9%, 9% > to 15% < reported use not including additional winter 

use. Adverse effects of two new tanks and splitting pastures. Persistent CT 

conflicts in P6, 7, 8. 

300 Neutral

Increased disturbance associated with new tank but located in broken land. AU 

decreased 6%, 2% < to 8% > typically reported use. CT conflicts associated 

with 18% broken land. Positive and negative effects of adding alleyway to 

pasture. 

301 Slightly 

positive

AU decreased 9%, 9% > to 10% < typically reported use. Water management 

of 2 springs. Switch from 3 to 4 pasture deferred rotation would increase ue of 

secondary range in new pasture. Delayed turn-in but CT conflicts in P3 & 

other pastures.
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Allotment 

Number

Effect of 

Initial 

Actions

Rationale

302 Slightly 

positive

Fence and graze some crested wheatgrass early 1 of 3 years, but persistent CT 

conflicts with 31% and 18% broken land in 2 pastures. Potentially combine 2 

herds and switch to deferred rotation. Fence and control access to 3 reservoirs 

& 1 water tank in P2. AU decreased 14%, 45% > to 12% less than typically 

reported use. 

AU= Authorized Use, CC= carrying capacity, CT=composition-timing conflict,

P=Pasture, > = greater than, < = less than.

Collective initial actions under Alternative 4 would increase the potential for achieving seral 

stage objectives in 14 of the 43 allotments. Of the 14 allotments, 9 are projected to show slight 

improvement and 5 would show marked improvement. Of the remaining 29 allotments, 23 would 

experience no change in current trends and would remain neutral; however, communities with 

high amounts of invasive grasses would have the potential to transition to invaded grass states. 

Six allotments are projected to experience a shift away from Grasslands Plan seral stage 

objectives. Five of the 6 allotments would be adversely affected by an increase in compositiontiming conflicts and one of the allotments would be additionally impacted by splitting pastures 

and adding water tanks. The sixth allotment is also affected by composition-timing conflicts and 

would be additionally affected by a 42 percent increase in Authorized Use.

The adaptive management tools available under Alternative 4 are the same as Alternatives 3 and 

3A. The difference between these alternatives is time. Because Alternative 4 initially improves 

more allotments in the project area the amount of time to improve the remaining areas is less 

than that of the other two alternatives. 

CUMULATIVE EFFECTS

Cumulative effects result from the combination of effects resulting from past, present, and 

reasonably foreseeable actions plus the direct and indirect effects of the alternatives. A 

discussion of past and present actions, reasonably foreseeable actions, and a summary of the 

cumulative effects by alternative follows.

Past and Present Actions 

The following past and present actions have contributed to the existing array of seral stages in 

the project area.

Livestock Grazing. Moderate to high livestock stocking levels, composition-timing conflicts, and 

winter hay feeding have affected and continue to affect the seral stage mosaic in the project area.

Stocking levels have resulted in excess use of native species in some areas. Composition timing 

conflicts have resulted in native species being more heavily utilized than accompanying invasive 

grass components because grazing occurs when the invasives are less palatable then the native 

grasses. Winter hay feeding introduces or spreads invasive grasses because they are part of the 

hay. These actions singularly or in combination have affected plant composition and hence the 

seral stages mosaic in the project area.
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Oil and Gas Development. The development of oil and gas has, in the past, affected plant 

composition through soil and vegetation disturbances associated with the development of well 

pads, access roads, utility corridors, etc. Until the 1980s, disturbed soils resulting from these 

activities were often reseeded with crested wheatgrass and other invasive species. Since that 

time, however, only native grasses and forbs species are used to revegetate disturbed areas. 

These early activities have assisted the spread of invasive grasses along the majority of access 

roads, utility corridors, and well pads (Washington and Gildar, 2004) and have adversely 

affected seral stages. 

Existing oil and gas facilities and access roads continue to receive annual maintenance. 

Maintenance activities such as road grading and ditch maintenance still present opportunities to 

spread invasive species as does vehicle traffic. 

Wildfire can have both beneficial and adverse effects on plant composition. Beneficially, fire 

provides a flush of nutrients, removes accumulated litter, and promotes a flush of new growth, all 

of which improve grassland vigor and dynamics. Wildfire also plays a role in the distribution of 

seral stages across the landscape. Conversely, wildfire is often succeeded by flushes of various 

invasive and noxious weeds that could increase their current extent. Wildfire control activities 

such as fireline construction can also offer opportunities for establishment or spreading of 

invasive species. Wildfire and fire suppression both have the potential to be contributing agents 

affecting seral stage distribution in the project area. However, given the high priority placed on 

fire suppression, the possibility of wildfire being a major contributor effecting seral distribution 

under any of the alternatives appears remote in comparison to fire suppression.

Noxious Weeds /Invasive Species. It is unknown when noxious weeds and invasive grasses first 

appeared in the project area. Some invasive species, such as crested wheatgrass, appeared in the 

1930s when successfully used in the reclamation of sub marginal lands. The primary past, 

current, and future effect of these groups of plants is that they alter or replace native plant 

communities which affects the distribution of native seral stages across the LMNG and the 

project area.

Drought is a recurring natural event in western North Dakota. The effects of drought combined 

with livestock grazing can, in a prolonged drought, results in a shift towards earlier seral stages.

Reasonably Foreseeable Actions

Elkhorn Ranchlands. The recently purchased Elkhorn Ranchlands require that the Grasslands 

Plan be amended to establish management direction for the newly acquired lands. Approximately 

800 acres of the 5,200 acre Elkhorn purchase are directly associated with five of the allotments 

in the North Billings project. Under the proposed amendment these lands would be managed in 

accordance with the adjacent management area, which is MA 3.65 Rangelands with Diverse 

Natural Appearing Landscapes. In the interim, as directed by 36 CFR 254.3(f)(2008), this 

portion of the purchase is being managed in accordance with the adjacent MA 3.65. If the 

proposed action were selected and implemented there would be no change over the current 

situation. 
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The proposed Grasslands Plan amendment also includes establishing a special interest area (SIA) 

for the remaining 4,400 acres of the purchase and approximately 17,160 acres contained in 

grazing allotments 279 and 280, which were associated with the Elkhorn Ranchlands when they 

were owned privately. If implemented the SIA would establish a forage reserve on those acres. 

The reserve would provide a place to move livestock to in the event an allotment is burned or if 

management actions, such as a prescribed fire or additional rest, were needed to help restore 

seral stages in an allotment or decrease composition timing conflicts. 

Travel Management Plan. An environmental assessment (EA) for travel management on the 

LMNG was released for comment in 2010. The proposed action under this EA would close all 

single use oil and gas roads, unauthorized roads (i.e., two tracks), and an additional 18 miles of 

system roads in the project area. The travel management plan is expected to have minimal effect 

on grazing permit holders unless single-use roads are blocked from access. If access were to be 

blocked, then additional two-track roads could be created as permittees can travel cross county to 

administer their permits. Closing or reducing use on roads removes or reduces the number of 

vectors spreading invasive species, which reduces the adverse effects on plant composition and 

hence seral stages. The potential creation of new two-tracks may result in the spread of invasive 

species, which if they become sufficiently established could adversely affect plant composition 

and the distribution of seral stages.

Oil and Gas Development. The Forest Service has received five applications for permit to drill 

(APDs) on NFS lands in the project area. The APDs seek to drill oil and gas wells. The well pads 

associated with each well would be approximately 4 to 5 acres in size, encompassing about 22 

acres total. Approximately 4,250 feet of roads would be built to access the well sites. The well 

pads would be surfaced with scoria or gravel and kept free of vegetation, so there is little 

opportunity to encourage the spread of invasive grasses. The access roads provide an opportunity 

for establishment/spread of invasive grasses That increases their potential for spreading into 

adjacent rangeland.
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Cumulative Effects by Alternative 

This section summarizes direct and indirect effects of the alternatives and the effects of 

reasonably foreseeable actions on seral stages. These effects in combination with past and 

present effects combine to create cumulative effects.

Alternative 1 may slow the spread of invasive grasses, but they are likely to continue expanding 

through natural competitive advantages and other vectors of dispersal. Although nativedominated grass communities would have the potential to progress towards later seral stages and 

climax communities with the removal of grazing, the potential expansion of invasive grasses 

would likely lead to Invaded Grass States in a high portion of the project area. Also, increased

herbaceous litter accumulation is likely to occur with the removal of livestock grazing and would

assist the expansion of some invasive grasses (NRCS 2009, 2006) through increased shading and 

moisture conservation and decreased vigor of the native plant community. As native plant 

communities change, so too would the distribution of seral stages away from that desired by the 

Grasslands Plan. Future oil and gas development has the potential to introduce or spread invasive 

species, which adversely affects the maintenance of native plant communities and the potential 

achievement of seral stage objectives. The proposed travel management plan closes or reduces 

use on roads and would remove or reduce the number of vectors spreading invasive species,

which reduces the adverse effects on plant composition and hence seral stages. However, these 

reasonably foreseeable actions are unlikely to affect a large enough area to have a cumulatively 

significant affect on the distribution of seral stages in the project area.

Alternative 2 may see some improvement in the mosaic of seral stages because of the potential 

beneficial opportunities of the forage reserve that is part of Elkhorn Ranchlands amendment. The 

travel management plan would help by reducing the numbers of vectors that spread invasive 

species along closed roads, but potentially increased off-road use would decrease the level of 

positive effect. However, because this alternative maintains the existing Authorized Use levels, 

rotations, etc., it will maintain current conditions and trends in plant composition. For these 

reasons this alternative has the least opportunity to achieve a significant improvement in late 

seral stage of all the alternatives. 

Alternative 3, initial actions are projected to increase the potential for achieving seral stage 

objectives in 11 allotments, maintain current condition in 26 allotments, and experience a 

decreased potential to achieve seral objectives in 6 allotments. The effects of reasonably 

foreseeable actions are the same as those identified under Alternatives 1 and 2.

Alternative 3A, initial actions would improve conditions in one allotment, maintain existing 

conditions in nine allotments, and decrease conditions in four allotments. The potential 

cumulative effects of reasonably foreseeable actions are the same as those under Alternatives 1

and 2. 

Alternative 4 would increase the potential for achieving seral stage objectives in 14 of 

allotments, maintain existing conditions in 23 allotments, and decrease conditions in 6

allotments. The potential cumulative effects of reasonably foreseeable actions are the same as 

those under Alternatives 1 and 2. 
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Adaptive Management. Implementation of adaptive management options under Alternatives 3, 

3A, and 4, including actions identified in the tool box, would improve the distribution of seral 

stages. The greatest difference among these alternatives is the rate of response. Alternatives 3 

and 3A are projected to improve fewer allotments than Alternative 4. The amount of time needed 

to improve allotments not addressed under initial actions will be greater for Alternative 3 and 3A 

than for Alternative 4, which addresses more allotments than Alternative 3 and 3A.

Consistency with Grasslands Plan—Seral Stages

There are no standards for seral stages in the Grasslands Plan; however, there is the following 

guideline:

Apply vegetative structural and compositional objectives across all herbaceous community types. 

Guideline

Initial actions under Alternatives 3, 3A, and 4 would, to differing degrees, move plant

composition (i.e., seral stages) towards objectives identified in the plan. Where monitoring 

shows initial actions to be insufficient, adaptive management actions would be implemented to 

help move areas towards objectives.

SHARP-TAILED GROUSE

Introduction

The plains sharp-tailed grouse (Tympanuchus phasianellus jamesii) is the management indicator 

species (MIS) for the biological community associated with grasslands that contain scattered 

shrubs and diverse vegetative structure (Appendix H USDA 2001a). An important feature to this 

community is the availability of high-structure vegetation (such as herbaceous dominated 

grassland). Such habitat benefits nesting sharp-tailed grouse and some other ground-nesting 

avian species.

Spatial and Temporal Setting

The analysis area for sharp-tailed grouse is associated with the potential occurrence of quality

nesting and brooding habitat within 1 mile (Grasslands Plan 1-14, #17) of their leks (dancing

grounds). Surveys in 2004 and 2005 (Knowles) identified 37 sharp-tailed grouse leks located in 

or adjacent to the project area. The analysis area for the sharp-tailed grouse includes the project 

area plus an additional mile buffer to account for the leks identified outside the project area. The 

temporal context for the analysis is 10-15 years from present. 
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Methodology

Two different methodologies were used to provide data for the sharp-tailed grouse analysis. 

First, visual obstruction reading (VOR) information was used to determine the amount of High 

structure, which is an important component of grouse habitat. Sharp-tailed grouse require high 

herbaceous structure for nesting, brooding, and hiding cover. High structure grassland for the 

LMNG is defined as areas with average VOR transect readings greater than 3.5 inches. The VOR 

methodology and analysis is described under the Herbaceous Structure section in earlier in this 

chapter. 

Second, Forest Service and contract (Knowles 2005) surveys were conducted to determine the 

number and location of sharp-tailed grouse leks (dancing grounds) in the project area. From mid 

April to early May, leks were observed and documented. In 2007 the DPG established a series of 

long-term lek monitoring blocks on each ranger district to monitor sharp-tailed grouse population 

trend. In these blocks lek locations and number of male sharp-tailed grouse are documented. 

Affected Environment—Sharp-tailed Grouse

This section provides a general description of the information related to seral stages for the 

project area. A detailed description of the existing condition of the seral stages in each allotment 

is provided in Chapter 3 Part 2.

EXISTING CONDITION

Lek surveys conducted in 2005 (Knowles 2005; Warm 2004, 2005) identified 37 leks throughout 

the project area, with the majority located in the eastern half of the project area. Some of the 37 

leks may be “satellite” leks. Satellite leks are defined as those leks that are typically used for 2 

years or less (Haukos and Smith, 1999); typically less than 0.6 miles from an established lek 

(Washington Department of Fish and Wildlife, 2002); and/or are attended by a low number of 

males. Additional satellite leks likely exist in the project area; however, given their dynamic 

nature and typically small size, they are difficult to detect. Most established leks are relatively 

stable over time but do move on occasion.

The known leks occur in both the Rolling Prairie and Badlands Geographic Areas (GA). 

However, within the project area the interface between the two geographic areas contains the 

highest density of leks, with 16 known leks within 1 mile and 24 within 2 miles of the interface 

between the two GAs. 

The 2001 Northern Great Plans FEIS (p. 239) states that “livestock grazing is the most 

significant and widespread activity affecting grassland structure.” Baseline grassland VOR 

transect data, collected in 2004 and 2005 within the project area, indicates that High structure 

grassland habitat is under represented, whereas Low and Moderate structure habitats are overly 

represented. Using the individual station data from the VOR transect information provides the 

same overall picture as the transect average. When analyzing by stations, High structure is 

defined as equal to or greater than 5.5 inches, in accordance with the DPG response to SRT 
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recommendation II-2. Structure data are collected in the fall after most grazing is complete. 

Tables 3.31 and 3.32 provide summaries of project area transect and station structure distribution 

data from 2004 and 2005. 

Table 3.31 — (Left) 2004 and 2005 transect herbaceous structure distribution within the 

project area

Table 3.32 — (Right) 2004 and 2005 station herbaceous structure distribution within the 

project area

The year 2004 was dry and met drought criteria under the Grasslands Plan definition. There 

currently is not a drought strategy for the DPG; however, as identified in Chapter 1, a 

modification of the NE McKenzie FEIS (page 22) is being used as an interim policy. Under this 

direction there is a transect structure objective of at least 10 percent High structure and at least 

40 percent Moderate structure during drought. The VOR information provided above indicates 

that the project area contained low amounts of High structure, which is an important component 

of quality sharp-tailed grouse habitat.

The Grasslands Plan (page 1-14) identifies the need to emphasize quality nesting and brooding 

habitat, consistent with GA objectives, within 1 mile of active sharp-tailed grouse leks. The lek 

site is the hub of nesting and other annual activities for sharp-tailed grouse (Connelly et al. 1998,

Prose 1987). One mile buffering of the known leks within the analysis area accounts for 

approximately 42 percent of the NFS lands in the project area. Table 3.33 shows that for 2004 

and 2005 the herbaceous structure distribution within the buffered lek areas is similar to the 

overall project area. Because sharp-tailed grouse utilize a combination of grasslands and shrubs, 

the shrub dominated or co-dominated transects were included in determining structure 

distribution identified in Table 3.33.

Sharp-tailed grouse utilize a variety of habitats including green ash woody draws. These 

woodlands provide forage, cover, and roosting sites and may be important in harsh winters 

(Prose 1987). The quality of the green ash woody draw habitat varies from healthy to unhealthy;

however, because of the number of woody draws within the project area, the woody draws do not 

appear to be a limiting factor for the sharp-tailed grouse.

VOR TRANSECTS

LOW

0-1.49”

MODERATE

1.5-3.5”

HIGH

>3.5”

2004 53% 47% <1%

2005 29% 64% 7%

VOR by STATION

LOW

0-1.49"

MODERATE

1.5 – 5.49"

HIGH

>5.5 "

2004 59% 38% 3%

2005 42% 56% 2%
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Table 3.33 — 2004 and 2005 VOR structure distribution within 1 mile of leks within the 

project area

Year Low

0-1.49”

Moderate

1.5-3.5”

High

>3.5”

2004 46.6% 50.0% 3.4%

2005 29.6% 63.0 % 7.4%

There are areas within some allotments that are either not grazed or are very lightly grazed. 

These static long-term “rested” areas occur primarily in the Badlands, where topography may 

limit access and/or the forage base. However, densities of sharp-tailed grouse in the Badlands are

typically low and, within the Badlands, these rested areas do not provide appreciable amounts of 

potential habitat for grouse or other ground-nesting species that prefer high-structure habitats.

In summary, sharp-tailed grouse occur in the project area as demonstrated by the presence of the 

37 leks. However, project area structure information provided above and in the Herbaceous 

Structure section of this chapter indicates that the amount of High structure is well below 

Grasslands Plan structure objectives and interim drought structure objectives. High herbaceous 

structure is an important feature of quality sharp-tailed grouse habitat because it provides nesting 

and brooding habitat. The lack of good quality nesting and brooding habitat is thought to be a 

limiting factor throughout the range of sharp-tailed grouse (Hillman and Jackson 1973, in Prose 

1987). Prose assumes that between 5 to 20 percent good cover is required for minimal population 

levels. The existing level of quality habitat may have adverse long-term affects to the sharptailed grouse population.

Sharp-tailed Grouse Population

The plains sharp-tailed grouse (grouse) occurs over a broad geographic area, in a nearly 

contiguous manner, ranging from eastern North Dakota, west to the Continual Divide, south to 

New Mexico, and north to central Alberta, Canada. The grouse has experienced population 

declines in many parts of its range due primarily to habitat loss, notably from conversion of 

habitat to agriculture uses (Connelly et al. 1998). The Nature Conservancy (2000), summarizing 

the North American Breeding Bird Survey information, found no significant grouse population 

trend for the period from 1966 to 1995. The Nature Conservancy, however, notes 7 and 8 percent 

declines for Canada and the western U.S., respectively, and about an 8 percent increase for North 

Dakota. According to the Nature Conservancy, sharp-tailed grouse populations in eastern 

Montana, North Dakota, South Dakota, Nebraska, and southern Canada are more secure than 

other populations. 

The NDGF has been surveying sharp-tailed grouse using a block survey method. One of their 

survey blocks, the Gorham Census Area, is located in the project area. NDGF has been surveying 

this area since 1966. Their 1966 to 2009 data show a stable to slightly increasing sharp-tailed 

grouse population in that block. 
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The DPG also monitors sharp-tailed grouse unit-wide through a system of monitoring blocks. 

One of these blocks lies within the project area. Survey information from 2007 to 2010 showed 

that the number of male grouse peaked at 59 males in 2008. In 2010, the number of counted 

males had dropped to 20. In 2008 the survey block contained five leks and in 2010 there were 

three leks. Two consecutive harsh winters, 2008 through 2010, likely contributed to the decline 

in numbers. However, these data cover a very short time period for a highly variable population 

and it would not be valid to determine population trend based solely on this information.

The population of sharp-tailed grouse in the project area is unknown, and predicting populations 

in a finite area such as the project area is difficult without extensive, long-term field data. 

However, surrogate information, including lek survey information from the project area and 

information contained in North Dakota Game and Fish (NDGF) monitoring reports (from 1998 

to 2006), was used to model the grouse population within the project area (Project Record, 

Specialist Reports and Notes, Wildlife Report). The estimated number of grouse in the project 

area is identified at between 473 and 659 grouse. 

When discussing populations of a wide-ranging species such as the sharp-tailed grouse, it is 

important to note that focusing on project scale populations is incorrect since it is out of spatial 

and temporal contexts. Sharp-tailed grouse populations are highly variable and can experience 

significant annual fluctuations in population numbers due to climate and habitat changes and 

other influences. Therefore, separating the individuals within the project area (a very small 

portion of the larger range) from the larger population would not be consistent with most 

viability analyses (Ruggiero et al. 1994). 

DESIRED CONDITION

The desired condition is to provide diverse and quality nesting, brooding, and wintering habitat 

at levels that, in combination with habitat on adjoining lands, help support stable to increasing 

sharp-tailed grouse populations within 10 to 15 years (Grasslands Plan, p. 2-14, 2-21).

Environmental Consequences—Sharp-tailed Grouse

DIRECT AND INDIRECT EFFECTS 

This section provides a summarization of direct and indirect effects for the 43 allotments in the 

project area. Detailed effects information is presented in Part 2 of this chapter.

Alternative 1 

With no livestock grazing, a significant increase in Moderate and High structure would be 

expected, resulting in increased nesting opportunities for ground-nesting species requiring or 

preferring High structure. It is uncertain how much High structure could be produced; however,

the 2001 Northern Great Plains FEIS (Alt. 4, page 3-319) analysis projects that a minimum of 46 

percent High structure on the landscape may be produced under a no-grazing scenario. Given a 

lack of other large-scale disturbances (such as fire), biologically capable sites would be strongly 
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biased towards High structure, which provides important nesting and brooding habitat for sharptailed grouse. Additionally, there would be no potential for nest destruction resulting from 

livestock trampling and there would be reduced incidences of collisions with fences. 

The occurrence of drought may affect grouse habitat and, therefore, populations under this 

alternative. However, because of the substantial increase in High structure and absence of 

livestock influence, the effects on the sharp-tailed grouse population would be mitigated. 

Ultimately, under this alternative sharp-tailed grouse nesting and brooding habitat would 

increase, nests lost due to livestock would decrease, and sharp-tailed grouse populations would 

increase, barring some unforeseen natural calamity. 

Alternative 2 

Alternative 2 proposes to continue current management; therefore, the existing conditions would 

likely continue relatively unchanged as described in the Affected Environment section above. 

The existing low levels of quality brooding and nesting sharp-tailed grouse habitat would be 

maintained.

The occurrence of drought generally tends to reduce the amount of High structure, which is 

further impacted by livestock grazing. Given the low amount of existing High structure, drought,

in combination with livestock grazing, has the potential to adversely affect sharp-tailed grouse 

habitat and, therefore, population dynamics.

Alternative 3 

The initial actions of this alternative include establishing, changing, or maintaining rotational 

grazing systems, additional range improvements, fencing, water development, range pipelines, 

and range water management. Authorized Use would be maintained at current levels. Table 3.34

summarizes the effects of proposed initial actions to sharp-tailed grouse nesting and brooding 

habitat.

As identified in the Herbaceous Structure section of this chapter, the use of grazing rotations and 

additional range infrastructure without Authorized Use/AUM adjustments is likely to result in 

the continued homogenization of herbaceous structure. Some Low structure may move to 

Moderate. However, there may also be a loss of existing High structure as rangelands are more 

efficiently utilized by livestock because of smaller pastures and more water sources. Because the 

amount of High structure is not projected to increase, sharp-tailed grouse nesting and brooding 

habitat in18 of the allotments would remain neutral, that is, exiting habitat conditions within a 

mile of known sharp-tailed grouse leks would be maintained. Nesting and brooding habitat 

would decrease in 13 allotments because of increased number of water sources, smaller pastures, 

and absence of changes in Authorized Use. Twelve allotments had no known sharp-tailed grouse 

leks (Table 3.34) within a mile of the allotment.
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Table 3.34 — Summary of projected effects, by allotment, for Alternative 3 initial actions 

on the nesting and brooding habitat of sharp-tailed grouse

Allot 

#

Improve Neutral Decrease No 

Lek1

Allot

#

Improve Neutral Decrease No 

Lek

126 X 240 X

127 X 241 X

128 X 243 X

129 X 244 X

130 X 248 X

131 X 249 X

132A X 256 X

132H X 258 X

133 X 272 X

133D5 X 277 X

134 X 278 X

135 X 281 X

136/139 X 282 X

140 X 283 X

141 X 286 X

142 X 287 X

158 X 288 X

220 X 289 X

221 X 300 X

230 X 301 X

237 X 302 X

239 X

1No known leks in or within one mile of the allotment. 

Under this alternative an interim drought strategy has been identified until the pending DPG 

drought strategy in completed. As identified in Chapter 2, the interim drought strategy is a 

modification of the one adopted by the McKenzie Ranger District 2006 NE McKenzie Allotment 

Management Plan Revisions FEIS. The structure guidelines (>10 percent high structure and > 40 

percent moderate structure) set under this strategy would reduce impacts to nesting and brooding 

habitat but would not eliminate the effects of drought. 

Implementation of adaptive management actions, including reductions in Authorized Use and 

implementation of rest, would improve sharp-tailed grouse habitat. This is because both of these 

actions are key in improving herbaceous structure (Briske et al. 2008, Rice and Carter 1984),

which in turn provides quality nesting and brooding habitat. 
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Alternative 3A

The affects of Alternative 3A are the same as those of Alternative 3, with the exception of 

allotment 287. Under Alternative 3A an additional water source would be installed in what is 

now secondary range. Installation of the water, with no change in Authorized Use, would even 

out livestock distribution and homogenize the structure distribution within the allotment,

resulting in a decrease in nesting and brooding habitat.

Alternative 4 

Alternative 4 is similar to Alternative 3; however, it would rely less on structural improvements 

and would set Authorized Use at levels below Preference. Under this alternative, adjustments for 

cow size would also be implemented. Of the 31 allotments that contained leks, 23 (Table 3.35) 

would see improved nesting and breeding cover, 7 would remain unchanged, and 1 would 

decrease. The primary reason the 23 allotments would improve is because of reductions in 

Authorized Use, which would potentially provide for increased High structure. Also, fewer range 

improvements are proposed under this alternative than under Alternative 3. This may lead to 

fewer impacts to existing secondary range, which potentially carries more High structure.

Continued monitoring of herbaceous structure and the grouse survey blocks would determine if 

the Authorized Use set under this alternative is sufficient or if additional actions, such as 

additional reductions in Authorized Use, are needed. The seven allotments projected not to 

change from existing conditions are those that are proposed for an increase in water distribution, 

smaller pastures, and/or the change in Authorized Use does not account for existing levels of 

permitted use. 

The allotment that is projected to see a decrease under this alternative would do so because of a 

projected 24 percent increase in Authorized Use, which would result in less residual cover,

which adversely affects the amount of nesting and brooding habitat. 

Because stocking levels are key to improving grouse nesting and brooding habitat (Reece et al.

2001), this alternative would improve grouse habitat faster than Alternatives 2, 3, or 3A. 

Adaptive management actions for Alternative 4 are the same as those for Alternative 3 and 3A 

and would have the same effects; that is, they would improve grouse habitat. The primary 

difference between this alternative and Alternatives 3 and 3A is the rate of improvement of 

nesting and brooding habitat. Because Alternative 4 starts out with Authorized Use below 

Preference, faster improvement is predicted then under Alternatives 3 or 3A. If additional 

adjustments in Authorized Use were required, the time needed to reach desired objectives would 

be less than Alternatives 2, 3, or 3A. 

Table 3.35 — Summary of Alternative 4 effects on sharp-tailed grouse nesting and 

brooding habitat within 1 mile of known leks

Allot 

#

Improve Neutral Decrease No 

Lek1

Allot

#

Improve Neutral Decrease No 

Lek

126 X 240 X
FEIS Vol. I North Billings County Allotment Management Plan Revisions

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Allot 

#

Improve Neutral Decrease No 

Lek1

Allot

#

Improve Neutral Decrease No 

Lek

127 X 241 X

128 X 243 X

129 X 244 X

130 X 248 X

131 X 249 X

132A X 256 X

132H X 258 X

133 X 272 X

133D5 X 277 X

134 X 278 X

135 X 281 X

136/139 X 282 X

140 X 283 X

141 X 286 X

142 X 287 X

158 X 288 X

220 X 289 X

221 X 300 X

230 X 301 X

237 X 302 X

239 X

1No known leks in or within one mile of the allotment. 

CUMULATIVE EFFECTS 

Cumulative effects result from the combination of effects resulting from past, present, and 

reasonably foreseeable actions plus the direct and indirect effects of the alternatives. A 

discussion of past and present actions, reasonably foreseeable actions, and a summary of the 

cumulative effects by alternative follows.

Past and Present Actions 

The following past and present actions have contributed to the low amount of High structure,

which has affected nesting and brooding habitat for sharp-tailed grouse in the project area.

Livestock grazing has affected, and continues to affect, quality sharp-tailed grouse habitat in the 

project area. Livestock grazing reduces the amount of high herbaceous vegetation, which serves 

as important nesting and brood habitat for sharp-tailed grouse.

Oil and Gas. Oil and gas development has resulted in road development, which has fragmented 

sharp-tailed grouse habitat to a limited degree and may have introduced some incidental 

mortality due to collisions with oil field traffic and infrastructure. Historical oil and gas 
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development probably displaced some grouse leks, however, avoidance is now used if this 

conflict arises. Past oil and gas development also resulted in the creation of an all-weather road 

system, which created or improved access for livestock into formerly inaccessible or seasonally 

accessible areas. In some areas this has resulted in secondary range containing High structure 

becoming primary range with a corresponding reduction in High herbaceous structure. Currently,

oil and gas activity in the project area is primarily focused around maintenance of existing oil 

and gas facilities and maintenance of oil and gas roads, which has little effect on sharp-tailed 

grouse other then direct mortality caused by collisions with vehicles.

Noxious Weeds/Invasive Grasses. It is unknown when noxious weeds and invasive grasses first 

appeared in the project area. Some invasive species appeared sometime in the 1930s, such as 

crested wheatgrass, when it was successfully used in the reclamation of sub-marginal lands. The 

primary past, current, and future effect of these groups of plants is that they alter or replace 

native plant communities. While this is not a preferred situation, sharp-tailed grouse will utilize 

some of the invasive grass species (such as crested wheatgrass) for nesting and brooding cover 

where they produce high structure in sufficient amounts. One exception to this is Kentucky 

bluegrass which does not provide spring nesting cover. 

Wildfire, a natural historical disturbance factor, has been actively suppressed on the LMNG and 

adjacent private and state lands for about a century. The result has been an increase in some tree 

and shrub communities and possibly in invasive species, as well as a reduction or loss of vigor in 

plant communities where fire plays a role in maintaining the health of those systems. Fire 

initially removes vegetative structure and built-up litter; however, this is a short-term effect that

is offset by the regenerative effects of fire, such as fertilization. Fire also plays a role in altering 

the mosaic of vegetation structure and composition across the landscape, affecting sharp-tailed 

grouse habitat. Due to an aggressive fire control policy over the past several decades, wildfire 

has burnt fewer than 4,500 acres, annually, on the LMNG and Grand River National Grasslands 

combined. While this may seem to be a significant number of acres, it represents less than 0.5 

percent of these grasslands. Wildfire may have some localized effect on grouse habitat but

overall it is considered to be minor because of the small amount of acreage annually burned.

Drought, a recurring natural event in western North Dakota, limits available soil moisture, which 

in turn affects vegetative production and in turn the availability of nesting and brooding habitat 

for sharp-tailed grouse.

Farming. In the past, cultivation of crops occurred within the project area on what are now NFS 

lands. Farming is no longer conducted on the LMNG; however, it does occur on the intermingled 

private lands within and adjacent to the project area. Farming outside the project area on private 

lands has resulted in the loss and/or fragmentation of sharp-tailed grouse habitat and, indirectly,

grouse numbers. This has had an effect on the overall grouse population; however, that effect is 

more historical in context. Because of a lack of data on private lands, it is not possible to 

determine the effect of current farming activities on the sharp-tailed grouse populations in the 

project area or on the LMNG.
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Reasonably Foreseeable Actions

Elkhorn Ranchlands. The recently purchased Elkhorn Ranchlands require that the Grasslands 

Plan be amended to establish management direction for the newly acquired lands. Approximately 

800 acres of the 5,200-acre Elkhorn purchase are directly associated with five of the allotments 

in the North Billings project. Under the proposed amendment, these lands would be managed in 

accordance with the adjacent management area, which is MA 3.65 Rangelands with Diverse 

Natural Appearing Landscapes. In the interim, as directed by 36 CFR 254.3(f)(2008), these 

portions of the purchase are being managed in accordance with the adjacent MA 3.65. 

The proposed Plan amendment for the Elkhorn Ranchlands also includes establishing a special 

interest area (SIA) for the remaining 4,400 acres of the purchase and the approximately 17,160 

acres contained in grazing allotments 279 and 280, which were associated with the Elkhorn 

Ranchlands when they were owned privately. If implemented, the SIA would establish a forage 

reserve on those acres. 

Travel Management. An environmental assessment (EA) for travel management on the LMNG 

was released for comment in 2010. The proposed action under this EA would close all single-use 

oil and gas roads, unauthorized roads (i.e., two-tracks), and an additional 18 miles of system 

roads in the project area. It is unlikely that this future action will significantly affect sharp-tailed 

grouse because it will not have an effect on herbaceous vegetation in the project area.

Oil and Gas Development. The Forest Service has received five applications for permit to drill 

(APDs) on NFS lands in the project area. The APDs seek to drill oil and gas wells. The well pads 

associated with each well would be approximately 4 to 5 acres in size, encompassing about 22 

acres total. Approximately 4,250 feet of roads would be built to access the well sites. The well 

pads would be surfaced with scoria or gravel and kept free of vegetation, so there is little 

opportunity to encourage the spread of invasive grasses. One of the proposed wells is located 

with a mile of a known sharp-tailed grouse lek the others are not. 

Cumulative Effects by Alternative 

This section summarizes direct and indirect effects of the alternatives and the effects of 

reasonably foreseeable actions on sharp-tailed grouse. These effects in combination with past 

and present effects combine to create cumulative effects.

Alternative 1 provides the best opportunity of all the alternatives for improving sharp-tailed 

nesting and brooding habitat in the short term. This is primarily due to the removal of 

disturbance associated with livestock grazing, which affords the best opportunity for the 

recovery of High structure. Mortality resulting from nest destruction caused by livestock would 

cease, and, as most fences would be removed under this alternative, collisions with fences and 

resultant mortality would decrease. Additionally, travel management may result in slightly less 
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direct mortality as the result of potential road closures but is not expected to affect sharp-tailed 

nesting and brooding habitat. Potential oil and gas development is not expected to have any 

significant affect on sharp-tailed grouse habitat despite one proposed oil well being located 

within a mile of a sharp-tailed grouse lek. The Elkhorn Grasslands Plan amendment would have 

no effect as livestock grazing would be prohibited under this alternative. 

Alternative 2 would maintain current sharp-tailed grouse habitat but would not increase the 

amount of quality nesting and brooding habitat. The Elkhorn Ranchlands Grasslands Plan 

amendment would establish a forage reserve on those acres. The reserve would provide an 

alternate source of forage, providing management flexibility to meet resource needs, such as 

increasing the amount of sharp-tailed grouse brooding and nesting habitat. The effects of the 

remaining reasonably foreseeable actions are the same as those identified under Alternative 1. 

Alternative 3, initial actions under this alternative sharp-tailed grouse nesting and brooding 

habitat in18 of the allotments would be maintained and 13 allotments would experience a 

decrease in habitat conditions. Twelve allotments had no known sharp-tailed grouse leks (Table 

3.34) within a mile of the allotment. The effects of the Elkhorn Grasslands Plan amendment

would be the same as those identified under Alternative 2. The effects of travel management and

foreseeable oil and gas developments are the same as those identified in Alternative 1. 

Alternative 3A, initial actions would have the same effects as Alternative 3. The one exception is 

Allotment 287, where the quality of grouse habitat is expected to decrease because of increased 

water availability. The effects of reasonably foreseeable actions are also the same as Alternative 

3. 

Alternative 4, initial actions would improve grouse habitat within a mile of known leks 

associated with 23 of the allotments, remain unchanged for 9 allotments, and would decline in 1 

allotment. The potential cumulative effects of reasonably foreseeable actions are the same as in 

Alternatives 3 and 3A. The remaining 13 allotments had no known sharp-tailed grouse leks 

(Table 3.35) within a mile of the allotment.

Adaptive Management. Implementation of adaptive management options under Alternatives 3, 

3A, and 4, including actions identified in the tool box, would be sufficient to improve nesting 

and brooding grouse habitat, even if initial management actions are determined through 

monitoring to be insufficient. In terms of adaptive management, the greatest difference between 

these alternatives is the rate of change. Alternative 4 would result in initial reductions in 

Authorized Use, whereas Alternatives 3 and 3A maintain Authorized Use at Preference. The 

analysis has identified that reductions in stocking is the most effective way of influencing 

structure and, hence, nesting and brooding habitat. Therefore, a reduction in Authorized Use as 

an adaptive action under Alternatives 3 and 3A would lag behind Alternative 4.

Consistency with Grasslands Plan—Sharp-tailed Grouse

The following Grasslands Plan standards are associated with the management of sharp-tailed 

grouse on the LMNG.
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1. Manage for native forb abundance and diversity to provide foraging habitat for big game, 

grassland birds, and other grassland wildlife. Guideline

Alternative 1, through the removal of cattle, would initially result in an increase in native forb 

diversity, but over time there would be an overall loss in forb diversity because ungrazed grasses 

would eventually shade out many forbs, thus reducing their diversity. 

Alternative 2, by maintaining current management, would maintain the current levels of forb 

diversity. 

Alternatives 3 and 3A, by increasing management intensity (implementing/changing rotations 

and infrastructure improvements) while retaining current Authorized Use, would initially 

maintain the existing forb diversity. 

Alternative 4, by increasing management intensity (implementing/changing rotations and 

infrastructure improvements) while adjusting current Authorized Use and accounting for 

livestock weight, would generally result in an increase in forb diversity.

2. Use the following criteria at the project level to help determine where to manage for high 

structure habitat in as large of blocks as possible in upland areas for waterfowl, prairie grouse, 

and other ground-nesting birds: Guideline

a. Presence of moderate to highly productive soils.

b. Dominance of mid to tall grass species.

c. Proximity to waterfowl pairing ponds and/or prairie grouse display grounds.

d. Proximity to wetlands with well-developed emergent vegetation. 

Currently there is a stable to slightly increasing trend in sharp-tailed grouse; therefore, no 

specific blocks have been identified for increasing High structure habitat. Alternatives 1, 2, and 

4 would maintain or increase the amount of sharp-tailed grouse nesting and brooding habitat. 

Alternatives 3 and 3A have the potential to reduce the amount of habitat because of more 

intensive management actions. If Alternatives 3 or 3A were selected, and monitoring of initial 

actions showed a decrease in quality sharp-tailed grouse habitat, then this guideline would be 

implemented to improve grouse habitat. Waterfowl were not an issue for this analysis.

3. Manage for high vegetative structure in areas where it would enhance nesting habitat for 

sharp-tailed grouse. Emphasize areas characterized by:

 Presence of moderate to highly productive soils and range sites.

 Plant composition dominated by mid and/or tall grasses.

 Proximity to sharp-tailed grouse display grounds.

 Proximity to shrub habitats, private croplands, and other sharp-tailed grouse foraging 

habitats. Guideline

This guideline is essentially the same as the preceding guideline, with the exception of the last 

sub-point. As previously identified, there are no designated areas identified to be managed for 

High structure. If Alternatives 3 or 3A were selected, and monitoring of initial actions showed a 
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decrease in quality sharp-tailed habitat, then this guideline would be implemented to improve 

grouse habitat. 

4. Limit construction or placement of non-oil and gas structures or facilities within 1/4-mile of 

active prairie grouse display ground if structures are likely to adversely affect reproductive 

success of these species. Project-level analysis should consider the type, source, frequency, and 

duration of the potential disruption, as well as the affected species and presence of screening 

vegetation or topography. Guideline

Prior to construction of any range facility identified under any of the alternatives, facility site 

locations would be reviewed by the wildlife biologist. 

5. Emphasize quality nesting and brooding habitat, consistent with Geographic Area objectives, 

within 1.0 mile of active greater prairie chicken and sharp-tailed grouse display grounds and 3.0 

miles of active sage grouse display grounds. Consult Appendix H for a description of quality 

habitat for prairie grouse. Guideline

No specific areas were identified under any of the alternatives as special management areas for 

sharp-tailed grouse, as populations are currently being maintained. Alternatives 1 and 4 would 

enhance the quality of sharp-tailed grouse habitat. Alternative 2 would maintain the current 

level of sharp-tailed grouse habitat. Initial actions of Alternatives 3 and 3A would have the 

potential to reduce quality habitat on a number of allotments in the project area. 

There are no known greater prairie chickens on the LMNG. They do occur on the Sheyenne 

National Grassland in eastern North Dakota.

6. Limit activities within 1.0 mile of active greater prairie chicken and sharp-tailed grouse 

display grounds and 2.0 miles from active sage grouse display grounds from March 1 to June 15 

if they are likely to adversely affect the reproductive success of these species. Project-level 

analysis should consider the type, source, frequency, and duration of the potential disruption, as 

well as the affected species and presence of screening vegetation or topography. Guideline

Herbivory is a natural activity of sharp-tailed grouse natural history. Impacts from herbivory, or 

related actions from the animal such as temporarily disrupting a lek or trampling a nest, may 

impact the reproductive success of individuals but not the species as a whole. Alternative 1 

would remove all livestock; therefore, disturbance to leks or nests would not occur. 

Though two oil and gas wells are proposed in the project area, they are not within a mile of any 

known lek and are not projected to have an effect on sharp-tailed grouse.

There are no known greater prairie chickens on the LMNG. They do occur on the Sheyenne 

National Grassland in eastern North Dakota.

7. Delay livestock grazing until after June 15 in areas being managed to provide upland gamebird 

nesting cover for the current year. Guideline

There are no designated areas specially managed for upland gamebird nesting cover under this 

project. 
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8. Manage prairie grouse display ground viewing activities to reduce disturbances and adverse 

impacts to the birds on the display grounds. Guideline

There are no organized sharp-tail grouse viewing activities on the Medora Ranger District. Lek 

surveys conducted by the district wildlife biologist are designed and conducted in a manner that 

minimizes potential disturbance.

9. Manage for high plant species diversity, including forbs, in areas where it would enhance 

sharp-tailed grouse brooding habitat quality. Emphasize areas in proximity to nesting habitat.

Guideline 

This guideline is addressed in points 3 and 4 above.

10. In areas used by wintering sharp-tailed grouse, maintain and enhance shrub patches and 

shrub components in wooded draws and riparian habitats. Guideline

There are no shrub patches specifically identified for wintering habitat for sharp-tailed grouse. 

Woody draws and other shrubby species (e.g., buffalo berry) provide important winter habitat. 

Though varying amounts of woody draws, specifically green ash woody draws, have been 

affected by livestock grazing, the number of woody draws is sufficient to provide needed winter 

cover. Woody draws and shrubby species are not limiting sharp-tailed grouse populations within 

the project area under any of the alternatives.

11. Meet rest objectives based on, but not limited to, the following desired conditions:

 Where high structure is required for plant and animal communities and reproductive 

success for Management Indicator Species (see Geographic Area direction).

 Where ungrazed areas are desired for biological diversity. Guideline

There are no specific areas under this project identified as needing rest or requiring ungrazed 

areas for the reproductive success of MIS species. 

ECONOMICS

Introduction

The social and economic implications of grassland resource management are of interest to local 

residents in Billings County, ND, and other areas surrounding the LMNG; visitors to the 

grasslands; and some people from other parts of North Dakota and throughout the United States. 

Residents in Billings County, ND, would be most likely to experience the direct social and 

economic impacts of the North Billings project. Ranchers who graze livestock on NFS lands in 

the project area may be affected, either positively or negatively, depending on alternative

selection.

The economic impacts of the alternatives described in the North Billings project were evaluated 

in two different fashions. The first analysis used IMPLAN Pro software (MIG 2003) to support 

an input-output analysis method to estimate regional employment and labor income impacts.

Input-output analysis is a way to examine relationships within an economy both between 
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businesses and between businesses and final consumers. It captures all monetary market 

transactions for consumption in a given year. This economic impact analysis examines the effect 

of a change in one or several economic activities on an entire economy when all else is held 

constant.

In the second analysis, North Dakota State University (NDSU) evaluated how allotment 

management alternatives proposed for the project area by the Medora Ranger District would 

affect individual ranch operations in the Little Missouri Grasslands. These economists have 

provided a report disclosing their best projections of impacts using enterprise analysis and debt 

payment capacity based on information collected from North Dakota Farm and Ranch Business 

Management (NDFRBM) and interviews of lending institutions.

Neither the regional economic impact analysis described above nor the NDSU analysis are based 

directly on financial information specific to the MGA permittees that will be directly affected by 

selection of an alternative. These two methods of portraying economic impacts are very 

different, but, as each has its own strengths and weaknesses, the results of both analyses will be 

shown in this document. 

This section also contains information related to the social setting and briefly explores the effects 

of the different alternatives on relationships between the Forest Service and ranchers with 

grazing permits on NFS lands. 

After the DEIS was completed, new vegetation production information from the NRCS 

ecological site descriptions became available. The new information changed Authorized Use

numbers under Alternative 4. Approximately half of the allotments would see less of a reduction 

in Authorized Use and about half would remain unchanged. As a result of these changes, the 

projected negative impacts to cattle ranching are reduced. These reduced impacts are still 

combined with the small positive agricultural support services impacts from additional annual 

spending on cattle ranching infrastructure improvements (in Alternatives, 3, 3A, and 4) to 

estimate total impacts.

Forest Service analysis output dates were advanced 1 year in the SDEIS (for example, from 2010 

to 2014 became from 2011 to 2015), reflecting later implementation dates than expected during 

the DEIS. 

Spatial and Temporal Setting

The geographic scope of the economic analysis includes: Billings, Bowman, Dunn, Golden 

Valley, McKenzie, Slope, Stark, and Williams Counties, ND; and Dawson, Fallon, Richland, and 

Wibaux Counties, MT. This economic impact area is an appropriate scope of analysis because,

even though the project would occur in Billings County, ND, these adjoining counties provide 

important inputs to the cattle ranching operations and serve as markets for beef cattle produced 

in the project area. The temporal scope of the analysis is 10 to 15 years. 
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Methodology

Following are descriptions of the various methodologies used by the Forest Service and NDSU 

in determining the economic effects of the different alternatives contained in the proposed North 

Billings project.

GOVERNMENT REVENUES AND PAYMENTS TO COUNTIES

For each alternative, anticipated changes in revenue to the government and the impact on 

payments to counties are projected based on the current fees and legislation governing payments 

to states.

FOREST SERVICE REGIONAL ECONOMIC CONTRIBUTIONS AND IMPACTS

The MGA provided grazing permits for the allotments in the project area for 2005 through 2007. 

An average from this 3-year period was used to portray current conditions. This analysis 

compares the pace of authorized AM reductions for each of the alternatives. The anticipated 

changes under each alternative were determined by range specialists calculating the number of 

AMs authorized for each alternative based on information obtained from grazing association 

issued grazing permits, grazing association Preference numbers, or estimating livestock carrying 

capacity numbers. Using the expected AMs under each alternative, economic impacts are 

estimated as direct, indirect, and induced employment (full- and part-time jobs) and labor income 

generated by (1) the foraging of cattle on NFS lands, and (2) the marketing of all cattle that rely 

on national grassland forage as part of their growth requirements. The true economic 

contribution and impacts associated with each of the alternatives likely falls within the ranges of 

estimates generated using these two techniques.

The existing condition is calculated by first determining the portion of total North Dakota cash 

receipts for cows and calves that are produced from NFS lands located in the 43 allotments in the 

project area. To calculate the percentage contribution that the NFS lands in the project area make 

to state cash receipts, the number of authorized AMs are divided by the number of AMs for all 

cows and calves marketed across North Dakota (2007 National Agricultural Statistical Service 

data). The 2007 data were the latest available at the time the analysis was conducted and were 

paired with the 2005-2007 average. Using more recent NASS data would not be technically 

correct because it would not match the time period for the MGA data.

Since marketed cows and calves spend roughly 12 and 8 months, respectively, foraging before 

they are marketed, the total number of marketed cows is multiplied by 12 and the total number of 

marketed calves across the state is multiplied by 8. These are then added together and used to 

estimate the total number of AMs required to bring animals to market and sell them for cash 

receipts. The 2005 through 2007 average authorized AMs are then divided by this number to 

calculate the portion of state total attributable to federal forage on the allotments. When this 

portion is multiplied by the 2007 cash receipts, the cash receipts for each year are calculated for 

the project area. It is important to acknowledge that when the portion of North Dakota 

marketings is calculated this way, it likely overestimates the portion because not all cows and 
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calves feeding on grasslands are indeed marketed each year. The true percentage marketed likely 

varies each year as many relevant markets change. Since we have no data describing this 

percentage, the portion of the statewide marketings estimated for the allotments is presented as a 

maximum percentage of statewide marketed animals directly attributable to federal forage in the 

project area.

Some cattle ranchers who have cows and calves that spend time on national grasslands in the 

project area rely on these lands to feed cattle away from base ranches so that they can produce 

feed to winter the cattle when they are not feeding on national grasslands. Since these ranchers 

rely on having their cows and calves off the ranch, the existing situation needs to also consider 

the current contribution that all of the cattle spending any time on national grasslands make to 

state marketings. By taking the 2005-2007 3-year average of cows, calves, and yearlings (no 

bulls, sheep, or horses), an estimate of the number of cows and calves relying on grassland 

forage is produced. This estimate is then compared directly to the sum of cows and calves 

marketed across the state (2007 National Agricultural Statistics Service). It is important to again 

acknowledge that when the portion of North Dakota marketings is calculated this way, it likely 

overestimates the portion because not all cows and calves foraging on NFS lands are indeed 

marketed each year. The true percentage marketed likely varies each year as many relevant 

markets change. Since we have no data pertaining to this percentage, this estimate is presented as 

a maximum percentage of statewide marketed cows and calves attributable to the project area.

This analysis used IMPLAN Pro software (MIG 2003) to support an input-output analysis 

method, to estimate employment and labor income impacts. Input-output analysis is a way to 

examine relationships within an economy both between businesses and between businesses and 

final consumers. It captures all monetary market transactions for consumption in a given year.

The economic contribution and impact analyses examine how a change in one or several 

economic activities affect an entire economy when all else is held constant. IMPLAN translates 

changes in the final demand for goods and services into changes in economic effects, such as 

labor income and employment of the affected area’s economy. 

The IMPLAN modeling system allows the building of regional economic models of one or more 

counties for a particular year. The regional model for this analysis used 2007 IMPLAN data for

Billings, Bowman, Dunn, Golden Valley, McKenzie, Slope, Stark, and Williams Counties, ND;

and Dawson, Fallon, Richland and Wibaux Counties, MT, the economic impact area for the 

North Billings project on the DPG.

Economic impacts are used to evaluate potential direct, indirect, and induced effects on the 

economy. The direct employment and labor income benefit employees and their families and,

therefore, directly affect the local economy. The direct response coefficients represent the 

number of jobs and the amount of labor income that are a direct impact to the cattle ranching and 

farming, and the agriculture support activity economic sectors in the IMPLAN model. Additional 

indirect and induced multiplier effects (ripple effects) are generated by the direct activities.

Indirect jobs represent the additional circulation of money to purchase inputs for cattle ranching 

and farming and inputs for the agriculture support sector. These jobs and this labor income are 
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distributed among the various economic sectors that exist in the 12-county area in North Dakota 

and Montana. Workers and proprietors working and earning money from direct and indirect 

impacts spend their earnings. Some of the money that is spent circulates in the local economy; 

much of the money leaks out to other parts of the country. The amount that remains local 

contributes additional jobs and labor income in a diverse group of economic sectors. This portion 

of the project area contribution to the economic impact area is called induced economic impacts. 

Potential future expenditures by the Forest Service and permittees associated with range 

improvements on the allotments under alternatives 3, 3A, and 4 are multiplied by estimates of 

direct, indirect, and induced effects for the agricultural support services IMPLAN sector and are 

combined with the cattle ranching impacts in the analysis. The sum of direct, indirect, and 

induced effects for both the cattle ranching and farming and the agricultural support services 

sectors is labeled total economic impacts.

Potential limitations of these estimates are the time lag in IMPLAN data, the structural changes 

to the economy that have happened since autumn 2008, and the accuracy of the methodology for 

calculating the portions of total cash receipts attributable to federal forage and all the cattle that 

spend some of the year grazing within the project area. As noted above, the lack of data 

regarding the percentage of annually marketed animals that are using the allotments is also a 

limitation. In this case, that has been dealt with by assuming all animals are marketed. Because 

of these limitations and assumptions, the best use of the economic impact modeling is to reveal 

relative differences in economic impacts between the alternatives.

NDSU ENTERPRISE AND DEBT REPAYMENT CAPACITY

Billings County, a cooperating agency, asked Dr. Larry Leistritz, Distinguished Professor of 

Agricultural Economics-NDSU, and Dean Bangsund, Agricultural Economist-NDSU, to 

evaluate how the alternatives proposed for the North Billings project would affect individual 

ranch operations. These economists have provided a report disclosing their best projections of 

impacts using enterprise analysis and debt payment capacity analysis. Their full report and 

appendices are located in the Cooperating Agency section of the Project Record. 

Below is a detailed description of their methods that describes their data and how they were used 

to evaluate potential impacts. These data and methods are intended to consider the baseline 

scenario (no change in NFS grazing), as well as three possible immediate AM reduction levels 

(10, 20, and 40 percent) and how they could impact local ranching enterprises of three size 

classes (150, 250, and 350 head). It then shows how changes in enterprise net margins would 

affect the debt repayment capacity for the three herd size operations in the next 10 years,

following implementation of Alternative 4. 

There are several assumptions used by these economists that differ from those used by the Forest 

Service economist. The following is a list of assumptions in the NDSU report that either do not 

exactly match the alternatives or which could be considered possible interpretations of likely 

outcomes of Forest Service alternatives. 
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Neither the regional economic impact analysis described above nor the NDSU impact analysis is

based directly on financial information specific to the MGA permittees that will be directly 

affected by selection of an alternative. This is because the permittee ranch-specific financial data 

describing ranches in the project area were not made available to either the Forest Service or the 

NDSU economists. However, both the regional economic impact analysis and the NDSU 

analysis do rely on actual economic data for larger areas that encompass the study area.

Data obtained from the MGA by NDSU indicate that 49 ranches would be affected by grazing 

cuts to the allotments in Billings County (Project Record, Cooperating Agency). Fifteen 

operations have 201 to 500 cow-herds, 9 operations were sized 101 to 200 cow-herds, and 11 

operations had 50 to 100 cow-herds. Fourteen operations were estimated to have fewer than 50 

cows. This breakdown does not match the herd sizes used in this NDSU analysis exactly, and the 

number of operations facing potential 10, 20, or 40 percent cuts was not provided as part of this 

NDSU analysis. While this information is not provided in the NDSU report, the Forest Service

estimated the percentage AM reductions for each allotment in the Range section of Chapter 3 of 

this FEIS.

AM reductions in the main NDSU study are all modeled to occur in the first year and persist for 

the remainder of the 10-year study period. This matches only those allotments under Alternative 

4 that have a 10 percent reduction proposed for Authorized Use. This is because, under the 

Forest Service proposal for Alternative 4, 10 percent reduction is the annual reduction limit for 

any one allotment. Therefore, a 20 percent reduction would take a minimum of 2 years, and a 40 

percent reduction would take a minimum of 4 years, to implement. This extra time can be 

important in providing a ranch operator with herd management options, and slightly changes the 

results. In the Billings County Economics Report (Project Record, Cooperating Agency), the 

NDSU economists have added some useful analysis describing how results change when 

reductions are phased in at a maximum of 10 percent per year.

In the NDSU study, AM reductions on NFS lands are assumed to lead to the same percentage 

reduction in herd size for all cattle run by a rancher. For example, a 20 percent reduction in NFS 

AMs used by a rancher is assumed to lead to a 20 percent reduction in overall herd size for a 

rancher. This is based on a belief that no substitute forage or other transition options would be 

viable.

Herd size reductions are not accounted for in the main NDSU study financial calculations. 

Accounting for the one-time sale of livestock to reduce herd size would be a logical step given 

the two assumptions above. The NDSU economists have added some useful estimation for these 

one-time revenue sources (Project Record, Cooperating Agency). 

Methods and results assume that 90 percent of all ranch revenues are derived from cow-calf 

operations. The exact percentage is not known for the individual ranch operations in the LMNG

affected by the North Billings project. However, 25 of the ranches in the project area have 100 or 

fewer head of cattle, suggesting that less than 90 percent of all ranch revenue comes from cowcalf operations on many of the ranches.
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The NDSU study suggests that reductions in sales values will be proportionally greater than herd 

size reductions. The report states, “Since fixed expenses cannot be easily changed in the short 

run, fixed costs were treated to be independent of grazing reductions. Fewer cows would be 

available to cover the same level of fixed expenses thereby reducing per-cow net margins 

compared to baseline conditions.” Next, it stated that, “The overall effect was decreased net 

revenues that were disproportionately greater than the level of grazing reductions. For example, a 

10 percent reduction in grazing capacities produced 16 to 19 percent reductions in total net 

revenues over the 2010-2019 period.” However, it is hard to make the case that all fixed costs 

(hired labor, building and machinery depreciation, farm insurance, property taxes, interest on 

term debt, and miscellaneous items [such as dues, subscriptions, and membership contributions]) 

would remain the same with a smaller herd size over the 10-year analysis period 

NDSU METHODS - EXTRACTED FROM BANGSUND AND LEISTRITZ (2010)

To provide insights on how cuts in grazing capacities might affect typical ranch operations, an 

analytical framework was developed to track anticipated changes in several key economic 

measures over a 10-year period. A baseline scenario was developed along with several herdreduction scenarios to provide context to how impacts from grazing cuts compare to anticipated 

future operations without grazing cuts.

Data for the analysis came primarily from the NDFRBM program. Ranches enrolled in the 

program that are located in western North Dakota provided the basis for financial data for this 

assessment.

A baseline scenario containing anticipated gross revenues (i.e., livestock sales), variable 

expenses, fixed expenses, and net margins was estimated for each cow-calf herd size for the 

2010-2019 period. Similar economic measures were also estimated based on grazing cuts of 10 

percent, 20 percent, and 40 percent for each of the three herd sizes. Grazing reductions were 

modeled to occur in year one of the 10-year period.

A baseline scenario was developed for estimating debt repayment capacity. Within that 

assessment, future estimates of family living withdrawals, off-farm income, and cow-calf net 

margins were included.

ENTERPRISE ANALYSIS

Projected livestock sales and net margins were based solely on average profitability measures for 

cow-calf production coefficients (e.g., calves sold per cow) and key measures for expenses (e.g., 

direct expenses per cow). The effects of grazing cuts on producers who are less profitable than 

average and those who are more profitable than average are likely to differ from the effects 

described in the NDSU report.

The analysis focused on tracking changes in gross revenues and net revenues from cow-calf 

operations and evaluating debt repayment capacities for ranch operations. Net revenues were 

defined to be gross revenues less variable and fixed expenses. To identify differences in financial 

performance associated with enterprise size, three cow-calf operations were modeled: 150-cow 
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herd, 250-cow herd, and a 350-cow herd. Those herd sizes approximated the delineation of 

enterprise data from the NDFRBM program and match typical operations in northern Billings 

County. Data obtained from the MGA indicates that 49 ranches would be affected by grazing 

cuts to the allotments in Billings County (Project Record, Cooperating Agency). Fifteen 

operations have 201 to 500 cow-herds, 9 operations were sized between 101 to 200 cow-herds, 

and 11 operations had 50 to 100 cow-herds. Fourteen operations were estimated to have fewer

than 50 cows.

A 10-year period was chosen to evaluate the effects of grazing reductions on cow-calf ranches.

Consistent with analysis periods used by the Forest Service, a 10-year period was assumed 

sufficient to observe anticipated changes in selected financial measures associated with cow-calf 

production. Also, a 10-year period is generally consistent with historical cattle cycles (Anderson 

et al. 2002, Petry 2009). Cattle cycles result from producer responses to anticipated price 

changes that affect industry-wide decisions on herd expansion and contraction. Those industrywide inventory changes lead to corresponding changes in average seasonal prices over the length 

of the cattle cycle (Anderson et al. 2002). As a result, the analysis period should cover both 

price-increasing and price-decreasing phases of the cattle cycle.

Trends in key enterprise and ranch-level measures are contained in NDSU Report - Appendixes 

A and B. The annual rate of change in the statistically significant trends was used to make 

projections over the 10-year evaluation period. In situations where trends were not statistically 

significant, average values for 3-year, 5-year, and 7-year periods were used as static values in the 

projections. Future livestock prices were based on projections made by NDSU Extension Service 

and conversations with NDSU Extension Specialists (Haugen et al. 2009, Petry 2009).

The analytical framework first assigns starting values for production coefficients (e.g., calf 

selling weights, calf production per cow, cull weights, death loss, cow culling percentages). Also 

assigned are starting values for key financial measures (e.g., variable expenses per cow, fixed 

expenses per cow).

Net margins over the period were based on the same techniques for estimating per- cow variable 

expenses in the baseline analysis (i.e., per head expenses increased but total expenses were tied 

to number of head). However, fixed expenses in the herd reduction scenarios were based on the 

level of fixed expense estimated in the baseline analysis. Since an operation’s fixed expenses 

cannot be easily changed in the short run, this assessment treated fixed costs to be independent of 

grazing cuts. In the grazing reduction scenarios, fewer cows are available to cover the same level 

of fixed expenses, thereby reducing net margins over time when compared to baseline 

conditions.

Variable or direct expenses in cow-calf enterprises consisted of feed supplements (e.g., protein, 

mineral, vitamin); purchased rations; primary feed stuffs (e.g., aftermath grazing, silage, hay);

grazing or pasture; miscellaneous feed stuffs; breeding fees; veterinary; supplies; fuel and oil;

repairs; livestock leases; marketing; and operating interest. Fixed or indirect expenses consisted 

of hired labor, building and machinery depreciation, farm insurance, property taxes, interest on 

term debt, and miscellaneous items (e.g., dues, subscriptions, membership contributions).
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When grazing cuts were expressed as one-time reduction, grazing reductions were expressed as a 

percentage change in herd size, since a loss of grazing capacity was expected to result in a

proportional loss of herd size. For example, a loss of one-third of available summer grazing 

capacity would translate into a one-third reduction in the cow-calf herd. In the analyses 

performed in this study, grazing cuts were assigned in year 1 of the 10-year period. A separate 

section is included that discusses the differences between a phased-in grazing reduction versus a 

one- time grazing reduction.

DEBT REPAYMENT CAPACITY

A reduction in the debt repayment capacity, all things equal, is generally a negative development 

for a ranch. Debt repayment measures enable borrowers and lenders to evaluate if a farm or 

ranch has the funds necessary to repay debts with maturity dates longer than 1 year (Ellinger 

1998). The measure assumes that credit obtained from current-year operating expenses is paid 

within 1 year as a normal conversion of agricultural production to cash assets.

The definition of the debt repayment capacity measure used by the NDFRBM program is 

consistent with the recommendations of the Farm Financial Standards Council (1995). Financial 

resources available for debt coverage for a farm business are defined as net farm income plus 

depreciation plus interest on term debt.

Net farm income is derived by subtracting expenses from gross revenues. Depreciation and 

interest on term debt are subtracted from gross revenues as part of the calculation of net farm 

income. Principal on term debt is not considered an expense and therefore is not subtracted from 

revenues as part of the calculation for net farm income.

Ranches in Billings County were treated as owner-operator entities. As owner- operator entities, 

the definition of debt repayment capacity is adjusted to include non-farm income, family living 

withdrawals, and income taxes paid (Farm Financial Standards Council 1995). 

The principal component of intermediate and long-term debt is not included as an expense in net 

farm income; however, interest expense on intermediate and long-term debt is counted as a fixed 

expense. Therefore, net farm income by itself is not sufficient to determine if a ranch can meet 

its debt obligations since only the interest component of principal and interest payments on 

intermediate and long-term debt are covered in the estimate of net farm income. Therefore it is 

necessary to estimate farm-level changes in financial measures other than net farm income to 

address debt repayment capacity. Payments for personal debt were ignored in the analysis as 

NDFRBM records showed those payments to be negligible.

Debt repayment capacities were estimated for both baseline and herd-reduction scenarios. Trends 

in farm-level depreciation, income taxes paid, family living withdrawals, and off-farm income 

were evaluated (NDSU Report - Appendix B). Trends in those values were combined with 

changes in net farm income to estimate debt repayment capacities over the 10-year period.
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LENDER INTERVIEWS

Phone interviews were conducted with agricultural lenders in western North Dakota to obtain 

their perspectives on how grazing reductions might affect ranches operating in the LMNG.

Affected Environment—Economics

EXISTING CONDITION

Medora, ND, with approximately 100 residents, is the closest town to the project area. Nearby, 

Dickinson, ND, is the closest full-service city, with roughly 16,000 residents. To provide context 

and comparisons, some of the demographic and background economic information is 

summarized for Billings County, some for the 12-county economic impact area and some for 

North Dakota.

Demographic Information

During the past 35 years, the population of the 12-county area peaked during the early 1980s at 

roughly 105,000 people. The population then declined fairly rapidly during the 1980s before the

loss began to slow through the 1990s. Even at this slower rate of decrease, the 12-county area 

shrank by 6 percent between the 1990 and 2000 censuses. The population has leveled off during 

the past few years, 2003 through 2007 (BEA REIS 2005).

Table 3.36 depicts general census demographic information for Billings County as compared to 

all of North Dakota. Billings County is very rural, with just under one person per square mile. As 

is the case in much of the rural West, both the Billings County and the North Dakota populations

declined over recent years. While the overall North Dakota population declined slightly between 

1990 and 2000, the population in Billings County declined by just over 10 percent (Bureau of 

Census 2000). Although a portion of the Fort Berthold Indian Reservation lies adjacent to part of 

the economic impact area, it is not inside Billings County. 

Total employment in the 12-county economic impact area also peaked during the early 1980s;

however, after falling with the population decrease during the mid 1980s, total employment has 

since grown and was at 57,261 jobs during 2005. About 80 percent of job growth from 1970 to 

2005 was in wage and salary employment. Much of this job growth has been focused in the 

various parts of the service sector. This growth in services has occurred in most parts of the 

country. State and local government job growth also explains some of total employment growth. 

By 2005, 15 percent of all employment in the 12-county area was in government jobs, with 

federal civilian and military jobs accounting for small percentages of the total. Retail trade has 

fallen as a percent of total employment. (BEA REIS 2005). Tables 3.37 and 3.38 provide a 

snapshot of employment in North Dakota and Billings County, ND, as of the 2000 Census.
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Table 3.36 — Demographic overview for North Dakota and Billings County, ND

North Dakota Billings County, 

North Dakota

2000 population total 642,200 888

2007 population estimate 639,715 798

Population, % change, April 1, 2000 to July 1, 2007 -0.4% -10.1%

Persons under 5 years old, % 2007 6.3% 4.1%

Persons under 18 years old, % 2007 22.3% 18.0%

Persons 65 years old and over, % 2007 14.6% 16.4%

Female persons, % 2007 49.8% 47.1%

Male persons, % 2007 50.2% 52.9%

Black persons, % 2007 1.0% 0.0%

American Indian, % 2007 5.4% 0.1%

Asian, % 2007 0.8% 0.1%

Hispanic or Latino, % 2007 1.9% 0.4%

Other, % 2007 1.0% 1.5%

White, % 2007 89.9% 97.9%

Living in same house in 1995 and 2000, % age 5+, 2000 56.8% 72.9%

Households, 2000 257,152 366

Median household income, 2007 $43,936 $44,819

Per capita money income, 1999 $17,769 $16,186

Persons below poverty, % 2007 11.8% 11.4%

Land area, 2000 (square miles) 68,976 1,151

Persons per square mile, 2000 9.3 0.8

Source: U.S. Census Bureau, from State and County QuickFacts 

http://quickfacts.census.gov/qfd/states/38/38007.html
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Table 3.37 — Summary of occupations in North Dakota and Billings County, ND, 2000

Occupation North 

Dakota

Percent of 

Total

Billings 

County

Percent of 

Total

Management professions and related occupations 105,314 33.3 173 38.7

Service occupations 52,942 16.7 60 13.4

Sales and office occupations 82,726 26.1 102 22.8

Farming, fishing, and forestry occupations 5,299 1.7 24 5.4

Construction, extraction, and maintenance 

occupations 30,935 9.8 50 11.2

Production, transportation and material moving 

occupations 39,416 12.4 38 8.5

Employed civilian population 

16 years and over 316,632 100 447 100

Source: U.S. Census Bureau, Census 2000 Summary File 3.

Table 3.38 — Summary of industries in North Dakota and Billings County, ND, 2000

Industry North 

Dakota

Percent of 

Total

Billings 

County

Percent of 

Total

Agriculture, forestry, fishing and hunting, and 

mining 25,914 8.2 166 37.1

Construction 19,707 6.2 41 9.2

Manufacturing 22,471 7.1 8 1.8

Wholesale trade 11,764 3.7 15 3.4

Retail trade 40,154 12.7 27 6

Transportation and warehousing, and utilities 18,203 5.7 12 2.7

Information 7,438 2.3 8 1.8

Finance, insurance, real estate, and rental and leasing 18,779 5.9 5 1.1

Professional, scientific, management, administrative, 

and waste management services 19,001 6 7 1.6

Educational, health and social services 76,698 24.2 39 8.7

Arts, entertainment, recreation, accommodation and 

food services 25,813 8.2 60 13.4

Other services (except public administration) 15,588 4.9 21 4.7

Public administration 15,102 4.8 38 8.5

Employed civilian population 

16 years and over 316,632 100 447 100

With the exception of two short periods, the 12-county area had very low average annual 

unemployment since the early 1980s. During 2005 this rate was estimated at 2.6 percent.

Seasonal fluctuations in the unemployment rate occur in this area, with winter months typically 

showing higher unemployment rates than the rest of the year. With the boom in oil and gas, even 

the 2006 winter rate was low, staying below 3 percent (BLS 2006). 
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Total personal income across the 12 counties has varied more year to year than population or 

total employment and has climbed from 1988 to 2005 ($1,139,000,000), with substantial 

increases occurring since 2000. Proprietors’ income, which was 43 percent of total income 

during 1970, fell to 20 percent by 2005. Much of this can be explained by the decrease in farm 

proprietors’ income, which fell from 25 percent of the total during 1970 to 6 percent during 2005 

(BEA REIS 2005). 

Aggregate average earnings per job in the 12 counties were lower than state and national 

averages. After adjusting wages for inflation, it is notable that average wages per job were also 

lower in 2005 ($30,248) than during 1970 ($30,988). Inflation-adjusted per capita personal 

income, however, was higher during 2005 ($29,151) than during 1970 ($16,683). Much of the 

explanation lies in the increase in non-labor income. Like most areas in the country, non-labor 

income has grown to a larger portion of total income in the last few decades. In the 12-county 

area, this reached a maximum of roughly 45 percent during the early 1990s. By 2005, it had 

fallen back to approximately 34 percent of total income. Welfare payments remained a small 

portion of non-labor income. Consistent growth in age-related non labor income explains some 

of this change, but the major changes in dividends, interest, and rent (investments) explain the 

overall trend in non-labor income growth (BEA REIS 2005).

Forest Service Regional Economic Contributions and Impacts

The methods and tools described in the methodology section above were used to estimate the 

contribution that forage from NFS lands located in the North Billings project area makes to the 

local economy, as well as the contribution that all cows and calves using the NFS lands 

associated with the allotments make to the local economy. In 2007, there were 874,000 cows and 

139,500 calves marketed in North Dakota. The number of cows is multiplied by 12 months, and 

the number of calves by 8 months (March 1 through October 31). When these are then added

together, the result is 11,604,000 AMs for marketed cows and calves across the state. The 

authorized AMs are divided by this number. The result of the division shows that 0.00251 of the 

state cash receipts were produced on average from the federal portion of the allotments each year 

from 2005 through 2007. When this portion is multiplied by the 2007 cash receipts 

($741,066,000), the result is that the NFS lands within the project area produce up to $1.86 

million dollars worth of cash receipts each year. To consider the contribution of all the animals 

that rely on the allotments for some part of the year, the estimated number of cows and calves 

that rely on the allotments for some forage (5,013) is divided by the total of marketed cows and 

calves for the state during 2007. This becomes the portion (0.00495) of the state cash receipts 

(already noted) that relied, at some point in the year, on the allotments. This leads to an estimate 

of $3.67 million in cash receipts each year.

Table 3.39 shows the annual direct, indirect, and induced contribution, and total part and fulltime jobs contribution based on the 3-year average from 2005 through 2007. During 2005,

drought conditions reduced authorized grazing below Preference. The 2007 IMPLAN model for 

the 12-county area reveals an employment multiplier of 2.07, meaning that for each direct job 

there was approximately one more indirect/induced job contributed—or roughly two total jobs in 
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the economy. While this is lower than often suggested, it is based on economic data for this area 

when using a 100 percent regional purchasing coefficient in IMPLAN. Considering the 

contribution of cash receipts from just the federal forage in the project area, 9 direct and 20 total 

part- and full-time jobs are contributed annually. When all cows, yearlings, and calves spending 

time on the allotments are considered, these direct and total part- and full-time job estimates 

increase to 20 and 39, respectively. As noted in the Northern Great Plains FEIS (USDA FS 2001, 

p. 3-10), these contributions, though small compared to either national cattle production or the 

total cattle production of the 37 Northern Great Plains national grassland counties, are a valuable 

component of the local economy. They are especially important to the permittees who have 

developed operations based on grazing NFS lands. This range of estimates forms the basis of 

jobs comparisons for all alternatives in the environmental consequences section.

The jobs presented in Table 3.39 represent the range of part and full-time jobs (20 to 39) 

contributed from the North Billings project area each year. Considering that several permittees 

operate more than one allotment and that there are 37 individuals (including spouses, hired 

hands, and children) listed on the 60 permits in the project area, these modeled numbers appear 

reasonable.

Similar to job estimates, a range of labor income estimates attributable to the allotments is 

provided in Table 3.40. The total labor income contributed by NFS forage, and which is a result 

of cows and calves in the allotments being marketed each year, represents roughly $359,497 each 

year. Considering the contribution of cash receipts from all the cows, yearlings, and calves that

rely on the allotments for a portion of the year, total labor income is estimated at roughly 

$708,453 per year. These estimates form the basis of jobs and labor income comparisons for all 

alternatives in the environmental consequences section.

Table 3.39 — Annual part- and full-time employment contribution* from the North 

Billings project area

Existing Condition

Part- and Full-Time Jobs

Contributed Per Year (2005-2007 

Average) from Federal Forage 

(29,125 AMs)

Part- and Full Time Jobs Contributed 

Per Year for All Cows and Calves That 

Rely on the Project Area at Some Point 

in the Year (5,013 Head)

Direct 9 19

Indirect and induced 10 20

Total** 20 39

*Based on federal forage only, and all cows, calves, and yearlings spending any time on NFS lands in the project 

area.

**Totals reflect the sum rounded estimates. 
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Table 3.40 — Annual labor income contribution* from the North Billings project area

Existing Condition

Labor Income Contributed Per 

Year (2005-2007 Average) from 

Federal Forage (29,125 AMs)

Labor Income Contributed Per Year 

for All Cows and Calves That Rely on 

the Project Area at Some Point in the 

Year

Direct $88,676 $174,752

Indirect and Induced $270,821 $533,701

Total** $359,497 $708,453

*Based on federal forage only, and all cows, calves, and yearlings spending any time on NFS lands in the project 

area.

**Totals reflect the sum rounded estimates. 

NDSU Enterprise Analysis

Based on Bansgund and Leistritz (2010) analysis of NDFRBM data, a 150-cow herd was 

projected to generate nearly $1 million in gross livestock sales from 2010-2019 (10-year study 

period) based on average productivity coefficients and expected future livestock prices (NDSU 

Table 1). Over that period, after accounting for expected changes (i.e., based on analysis of 

trends in those values) in variable expenses and fixed expenses, that operation would likely 

generate a cumulative net margin over $220,000, translating to an annual net margin of $22,000. 

(NDSU Report, Table 1). Likewise, a 250-herd operation would likely generate net margins of 

$307,894, or roughly $31,000 per year, and a 350-herd operation would generate net margins of 

$432,254 or $43,000 per year. Net margins represent returns to operator labor, management, and 

equity; however, net margins do not necessarily equate to strict accounting measures of profit. 

Note that projected livestock sales and net margins were based solely on average profitability 

measures for cow-calf production coefficients (e.g., calves sold per cow) and key measures for 

expenses (e.g., direct expenses per cow). The cumulative effects of grazing cuts on producers 

who are less profitable than average and those who are more profitable than average are likely to 

differ from the effects described in this report.

NDSU Debt Repayment Capacity

Trends in farm-level depreciation, income taxes paid, family living withdrawals, and off-farm 

income were evaluated (NDSU Report - Appendix B). Trends in those values were combined 

with changes in net margins to estimate debt repayment capacities over the 10-year period.

Non-farm income was expected to average over $28,000 annually for the 150-cow herd analysis 

and was projected to increase by about 33 percent over the period. Family living withdrawals for 

ranches with 150-cow herds were projected to average about $43,900 per year, and increased by 

38 percent over the period. Initial values and trends in both factors were obtained from

NDFRBM data (NDSU Report - Appendix B). Trends in the rate of change for income taxes and 

term interest were not statistically significant with the NDFRBM data, so values for those 

variables were not modeled to increase over the period. By contrast, deprecation (i.e., non-cash 
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Chapter 3 | 239

expense associated with buildings and machinery) was expected to increase by nearly 20 percent 

over the period. Combined with changes in the above variables and changes to net margins for 

the 150-cow herd, annual debt repayment capacities were expected to decrease over the period in 

the baseline scenario.

Under the baseline situation for a 150-cow herd, the average annual debt repayment capacity was 

about $14,300. Cumulatively, debt repayment capacity in the baseline scenario was estimated to 

be over $143,000 for the study period (NDSU Report - Table 4).

Non-farm income was expected to average more than $42,000 annually for the 250-cow herd 

analysis and was projected to increase by 33 percent over the period. Family living withdrawals 

for ranches with 250-cow herds were projected to average about $40,000 per year, and increased 

by 38 percent over the period. Trends in the rate of change for income taxes and term interest 

were not statistically significant within the NDFRBM data, so values for those variables were not 

modeled to increase over the period. By contrast, deprecation (i.e., non-cash expense associated 

with buildings and machinery) was expected to increase by nearly 28 percent over the period.

Combined with changes in the above variables and changes to net margins for the 250-cow herd, 

annual debt repayment capacities were expected to decrease over the period.

Under the baseline situation for a 250-cow herd, the average annual debt repayment capacity was 

about $41,200. Cumulatively, debt repayment capacity in the baseline scenario was estimated to 

be nearly $412,000 for the study period (NDSU Report — Table 4).

The NDFRBM data did not delineate separate values between 250-cow and 350-cow herds for 

non-farm income and family living withdrawals. Therefore, the same values and rates of change 

used for the 250-cow herd was used with the 350-cow herd. Depreciation (i.e., non-cash expense 

associated with buildings and machinery) was expected to increase by nearly 28 percent over the 

period, which is the same rate of change found with the 250-cow herd. However, per-cow values 

were greater for the 350-cow herd. Combined with changes in the above variables and changes to 

net margins for the 350-cow herd, annual debt repayment capacities generally declined over the 

period.

Under the baseline situation for a 350-cow herd, the average annual debt repayment capacity was 

about $58,800. Cumulatively, debt repayment capacity in the baseline scenario was estimated to 

be nearly $588,000 for the study period (NDSU Report — Table 4).

Bankhead-Jones Payments and Conservation Practice Funds

Historically, a percentage of revenue received from grazing fees has been distributed to Billings 

and Golden Valley Counties from the Bankhead-Jones Farm Tenant Act Fund (Payment Act of 

July 22, 1937). Under this Act, 25 percent of net receipts from grazing fees are given to the 

counties (USDA FS 2001, p. 3-24), 25 percent are returned to the U.S. Treasury, and the 

remaining 50 percent is available for Conservation Practice (CP) projects. Recent grazing rates, 

set by the U.S. Congress, are $1.35/head month. The MGA permittees also pay additional spread 

charges to the MGA for each AM grazed on federal lands. Table 3.41 displays estimates of the 

average annual receipts collected by the federal government from grazing fees for livestock run 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

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on NFS lands in the North Billings project area over the past 3 years, the average payment made 

to Billings and Golden Valley Counties, ND, and the MGA receipts from Bankhead-Jones Act 

payments. Given that a grazing association can petition to obtain the county’s payment for use in 

administration and CP funds, up to 75 percent of gross Bankhead-Jones receipts can be used for 

administration and CP (such as water developments, fences, noxious weed control, and cultural 

resource surveys) purposes on the NFS unit from which they were collected (USDA Forest 

Service 2001, p. 3-26). In comparison, Billings County received $101,686 from the Payment in 

Lieu of Taxes program during 2008.

Table 3.41 — Average annual receipts and payments returned to project area county

Counties

Average Annual

Receipts, 

2005-2007

Average Bankhead Jones Act 

Payments to Billings and 

Golden Valley Counties, 2005-

2007

Average Grazing 

Receipts Held by the 

Medora GA, 2005-

2007

Billings and 

Golden Valley 

Counties, ND

$39,319 $9,830 $19,659

Source: Forest Service INFRA Database.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

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EXISTING SOCIAL CONDITIONS

Land Base Overview and Settlement History

The project area is located almost entirely within Billings County, ND, with a small area located 

in Golden Valley County. Pages 3-49 through 3-51 of the FEIS for the Dakota Prairie Grasslands 

Plan (USDA Forest Service 2001), and pages 3-162 through 3-191 of the LMNG Rangeland 

Assessment (USDA Forest Service 2002) provide a good history and overview of the social and 

economic setting of communities in western North Dakota, including Billings and Stark 

Counties. A summary from those documents is provided here.

From 10,000 B.C. until the early to mid-1800s, human use in the area was primarily hunting and 

gathering, with some agriculture, by Native Americans. In the early 1700s, the arrival of 

European traders and the introduction of the horse started a chain of events that significantly 

changed historic human use of the plains. Bison were hunted nearly to extinction and were 

replaced with large herds of cattle. Homesteads and communities were established. By the mid to 

late 1870s, most tribal peoples were forced onto reservations, while European settlers became 

established in the area. Farm and ranch operations significantly altered the once intact prairie 

grassland ecosystem.

The federal government encouraged homesteading on the Great Plains through the 1862 

Homestead Act and similar laws; however, the soils and climate of the region made productive 

farming difficult. Western North Dakota reached its peak population in the 1920s, but by the end 

of that decade many people had left. The 1930s drought exacerbated the problems of farming in 

the arid west.

Environmental and economic devastation led to federal action to assist people and communities 

in the Great Plains. Through several acts, the federal government repurchased land and relocated 

families. This effort to purchase lands was called the Land Utilization Program (LUP). The 

program culminated with passage of the Bankhead-Jones Farm Tenant Act in 1937, which 

provided management direction for the purchased lands. As part of the LUP in western North 

Dakota, grazing associations were formed to integrate management of the purchased lands with 

private ranch and farm operations. 

In 1954, administration of the LUP was transferred from the Soil Conservation Service to the 

Forest Service. In 1960, the USDA created 19 national grasslands, including the Little Missouri 

National Grassland (LMNG). These grasslands were to be administered under Title III of the 

Bankhead-Jones Act. The grassland grazing permits would be managed by the Forest Service 

through the already established grazing associations to help maintain and improve the national 

grasslands. The same year, the Multiple-Use Sustained-Yield Act of 1960 was passed, which 

applies to national grasslands as well as national forests, calling for multiple-use management on 

these lands. 

Livestock production from NFS lands on the Northern Great Plains is very important to the 

people who hold grazing permits. Overall, though, the national grasslands and forests of the 

Northern Great Plains play a minor role in the total production of cattle and sheep. Total 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

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production from the 37 counties in the area of influence (those counties containing or adjacent to 

NFS lands in the Northern Great Plains planning area) is approximately 2.2 percent of the 

national cattle herd size. Of the 37-county cattle production total, less than 4 percent of the 2.2 

percent contribution to the national cattle herd is derived from the national grasslands and forests 

on the Northern Great Plains (Census of Agriculture 1992, Forest Service grazing records).

Nonetheless, local ranchers with grazing permits have an interdependent relationship with the 

national grasslands and forests. The public lands grazed, under inventory permits, provide up to 

12 months of grazing while turn-in permits provide livestock forage for part of the year, with the 

permittee providing forage for the remainder of the year. Therefore, any increase or decrease in 

forage provided from public lands may cause adjustments in herd sizes or other factors related to 

permittees' livestock operations and affect efficient grazing use of their own lands.

Cooperative Livestock Grazing Management

Since the national grasslands were established, the Forest Service and the MGA have 

cooperatively managed livestock grazing on the LMNG in Billings and Golden Valley Counties. 

This cooperative management is outlined in a Grazing Agreement between the FS and the MGA. 

The Grazing Agreement acts as the permit for livestock grazing on NFS lands within the county, 

and spells out the terms and conditions under which the MGA administers permits for individual 

permittees to graze livestock within an allotment. Grazing allotments can be, and usually are, 

made up of a combination of NFS, private, and state lands.

Ranchers live throughout the project area on private property surrounded and interspersed with 

NFS lands. A grazing association grazing permit to graze NFS lands is attached to what is 

referred to as base property. Base property is historically designated property on which a grazing 

Preference was established when original members came into the MGA. A person must own or 

lease the base property to qualify for a grazing association grazing permit on NFS lands.

According to government policy, a grazing permit is an instrument that grants the permittee the 

privilege of grazing on federal lands. It carries no rights or value, and it can’t be bought, sold, or 

used as collateral. Nevertheless, banks and real estate markets do associate real property values 

with federal grazing permits. Base property with a federal grazing permit sells for considerably 

more per acre than similar property without such a permit (USDA FS 2002, p. 3-181, 3-182). 

Ranching Lifestyles

Billings County is very rural, and farming and ranching are important components of the 

economic base of the county. Additionally, farming and ranching lifestyles are an important and 

traditional culture of the county. Even people who are not directly involved in farming and 

ranching are usually indirectly involved or affected through their business and social lives. A 

general flavor of western heritage is obvious in Billings County, from the merchandise available 

in local stores to community activities such as rodeos, 4-H, Future Farmers of America, and 

spring brandings.
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This western heritage and culture is partly due to the expansive ranch operations in the county, 

which include operations on NFS lands. Large fenced allotments in the North Billings project 

area, and other parts of the county are conducive to maintaining a ranching lifestyle where a 

cowboy on horseback is still sometimes the best way to check or move cattle. Depending on the 

allotment, these large federal allotments can be grazed by one or several permittees running their 

livestock together. Such intermingled land and livestock ownership requires ranchers to work 

closely together as well as with the Forest Service.

DESIRED ECONOMIC AND SOCIAL CONDITION

The desired economic condition is to provide for long-term sustainable management on the 

DPG; to build a common vision for national grassland resources; and to demonstrate sound and 

practical management of grassland ecosystems for the multiple benefits of grassland agriculture, 

local communities, and the rural economy and the public.

The desired social condition evolves from Goals 1 and 2 of the Grasslands Plan (pages 1-2 and 

1-4). These goals point out that by taking care of the ecosystem the grasslands will be able to 

provide a sustained supply of goods and services, which, in turn, positively affects social wellbeing. 

Paraphrased, these goals identify that, by ensuring sustainable ecosystems through promoting 

ecosystem health and conservation using a collaborative approach, the grasslands will be able to 

provide multiple benefits to people by providing a variety of uses, values, products, and services 

for present and future generations.

Environmental Consequences—Economics 

DIRECT AND INDIRECT EFFECTS

Alternative 1 

Alternative 1 would prohibit livestock grazing on NFS lands in the project area. According to 

Forest Service Handbook (FSH) 2209.13, Section 16.24, this alternative could not be 

implemented until 2 years after the notification of each affected permittee (36CFR 222.4(4)(1)). 

Regular grazing would persist for two seasons following selection of this alternative. After that, 

all grazing on the allotments would cease as of 2013. Table 3.42 shows that the number of 

authorized AMs, revenue, and jobs would fall to zero on NFS lands. 

Revenues (Table 3.41, above) generated from grazing fees would drop to zero, thus there would 

be no returns to the U.S. Treasury and no funds available for Bankhead-Jones Payments or 

Conservation Practice.

The social impacts of terminating grazing may include changes of lifestyles for some permittees 

currently running cattle operations. The ranchers and local communities that could be affected by 

selection of this alternative hold cattle ranching culture in high esteem and do not wish to lose 

this cultural identity and preferred lifestyle. There may be a loss of leisure time as loss of access 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

244 | Chapter 3

to graze local national grasslands may mean more time is required to transport livestock to 

distant pastures. Although an increase in social problems associated with unemployment is 

possible, the extremely low average annual unemployment rate in the area indicates that other 

work would likely be available. The growth of oil and gas production and its likely continued

growth, means that outdoor work is available in this area; this could potentially moderate or 

negate any negative social impacts that could result from loss of a few cattle operations. 

Table 3.42 — Proposed reduction schedule for authorized federal AMs

Alternative 1 2011 2012

2013 and Each 

Year in the 

Future

Federal AMs 29,125 29,125 0

Total part and full-time jobs

contributed per year 20 to 39 20 to 39 0

Total labor income contributed per 

year

$359,497 -

$708,453

$359,497 -

$708,453 0

Another social impact would be the relationship between the cattle ranching community and the 

Forest Service. The long tradition of grazing NFS lands would likely be perceived as degrading. 

Even if resource conditions were to improve following implementation of no grazing, and even if 

this spurred additional economic activity in the agriculture support services and recreation and 

tourism related sectors (such as hunting and bird watching), the net effect would likely be a 

negative perception of federal lands management. 

Alternative 2 

Alternative 2 represents the current grazing occurring on the 43 allotments. No changes are 

anticipated in federally authorized AMs. Under this alternative, current contribution levels would 

persist for 10 years. This means the current economic contributions from the project area would 

continue, thus there would be no economic impacts and no change to collected receipts expected 

from federal actions. However, under this alternative, market factors and individual management 

decisions might cause small economic impacts. All information in the affected environment 

discussion applies to this alternative. 

The NDSU ranch viability analysis describes baseline conditions and associated 10-year 

enterprise conditions as total and annual net margins and annual and total debt repayment 

capacity. Since this alternative would not change grazing levels in the project area, these baseline 

observations would persist and there would be no impacts, defined as changes from existing.

Perhaps the largest social impacts would be the relationship between the cattle ranching 

community and the Forest Service. This long tradition of grazing NFS lands may be perceived by 

permittees as enduring successfully.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

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Alternative 3 

Under this alternative there may be a small increase in economic activity in the agriculture 

support sector, possibly leading to one or two additional jobs per year in the 12-county area. 

These jobs would be based on continued funding for range improvement (such as drilling water 

wells, installing pipeline, fencing, etc.). The projected annual level of investments in grazing 

infrastructure coming from Conservation Practice funds, permittees, and Forest Service 

watershed and wildlife funds are estimated at $47,917. This money is multiplied with the 

response coefficients for the agriculture support activities sector in the twelve-county area. Table

3.43 shows that, in general, economic and job impacts from this increased investment in new 

management practices described in this alternative are expected to be small increases above 

current NFS forage and total contribution levels.

Table 3.43 — Annual part- and full-time employment and labor income contributions from

federal forage, Alternative 3*

* Changes or impacts from the current contributions are indicated in parentheses.

**Totals reflect the sum of rounded estimates.

Alternative 3 2011 2012

2013 and Each 

Year in the 

Future

Direct part and full-time jobs contributed per year 11

(+2)

11

(+2)

11

(+2)

Indirect and induced part and full-time jobs

contributed per year

11

(+1)

11

(+1)

11

(+1)

Total** part and full-time jobs contributed per 

year

22

(+2)

22

(+2)

22

(+2)

Direct labor income contributed per year $136,943 

(+$48,267)

$136,943 

(+$48,267)

$136,943 

(+$48,267)

Indirect and induced labor income contributed per 

year

$277,958

(+$7,139)

$277,958

(+$7,139)

$277,958

(+$7,139)

Total* labor income contributed per year $414,902

(+$55,405)

$414,902

(+$55,405)

$414,902

(+$55,405)
FEIS Vol. I North Billings County Allotment Management Plan Revisions

246 | Chapter 3

Table 3.44 — The economic impacts of alternative 3, considering the economic contribution 

of all cows, yearlings, and calves that spend time in the project area at some point in the 

year*

Alternative 3 2011 2012

2013 and Each 

Year in the 

Future

Direct part and full-time jobs contributed per year

20

(+1)

20

(+1)

20

(+1)

Indirect and induced part and full-time jobs

contributed per year

20

(0)

20

(0)

20

(0)

Total** part and full-time jobs contributed per 

year

41

(+2)

41

(+2)

41

(+2)

Direct labor income contributed per year $223,018

(+$48,266)

$223,018

(+$48,266)

$223,018

(+$48,266)

Indirect and induced labor income contributed per 

year

$540,840

(+$7,143)

$540,840

(+$7,143)

$540,840

(+$7,143)

Total* labor income contributed per year $763,858

(+$55,405)

$763,858

(+$55,405)

$763,858

(+$55,405)

* Changes from the current contributions are indicated in parentheses.

**Totals reflect the sum of rounded estimates.

If reductions in authorized AMs were necessary based on monitoring, there may be negative 

impacts. Further AM adjustments would reduce receipts to the U.S. Treasury, counties. and 

grazing associations. However, because it is unknown if, when, or what those adjustments might 

be, it is not possible to predict what those economic effects may be on jobs and income.

The grazing fees revenue generated by this alternative would be same as the existing condition;

thus, funds available for Bankhead-Jones payments, conservation practices, and the return to the 

U.S. Treasury would be the same. 

Social impacts expected with this alternative are that current relationships between the Forest 

Service and the MGA and its permittees would be maintained. If monitoring results in the need 

for reductions in Authorized Use it could result in a shift of some livestock grazing from federal 

to private lands, and a possible reduction in herd sizes if the federal graze can’t be made up for 

by private graze and /or feeding. This may lead to a new configuration of cattle ranching 

operations in the economic impact area. In other cases, the increased cost of renting private graze 

and/or feed for the current herd size could possibly lead to a smaller number of cattle ranching 

operations. Therefore, these impacts could mean that some people may retire or change to other 

professions. However, these potential effects would depend on the percentage of reduction, the 

ability of the ranching operation to absorb reductions, etc., which are unknown at this point in 

time.
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Alternative 3A

Alternative 3A was created by including applicable actions identified in the MGA Exhibit 2 that 

the MGA recommended be added to Alternative 3 and excluding some actions identified in 

Alternative 3 with which the MGA did not agree. Tables 2.5 and 2.6 in this FEIS summarize the 

changes made. The economic consequences of implementing Alternative 3A would be identical 

to those described for Alternate 3. Although additional infrastructure improvements have been 

identified, the funding limitations identified by the Medora District mean that the there is no 

difference in the effects regarding the changes in employment and labor income. Socially, 

Alternative 3A may provide improved cooperation between the Forest Service and the MGA.

Alternative 4 

Under Alternative 4, Authorized Use is equal to the allotments’ initial estimated carrying 

capacity, which is expressed in AUMs. Since the economic analysis uses AMs for its 

calculations, the AUMs under alternative 4 were converted to AMs. Any reductions implemented 

under Alternative 4 would be limited to 10 percent per year for each of the affected allotments. 

The result is that reductions will be phased in over a 5-year period and that the total reductions 

proposed would be less than 10 percent every year. 

Tables 3.45 and 3.46 how the contributions and (impacts) for the next 5 years for part and fulltime jobs as well as annual labor income based on the federal forage only and on all cows, 

calves, and yearlings spending any time on NFS lands in the project area. These estimates 

include additional infrastructure investments made where there may be a small increase in 

economic activity in the agriculture support sector. This could lead to one or two additional jobs 

per year in the 12-county area. The projected annual level of investments in grazing 

infrastructure coming from Conservation Practice funds, permittees, Forest Service watershed 

funds, and Forest Service wildlife funds are estimated at $47,917. This money is multiplied with 

the response coefficients for the agriculture support activities sector in the 12-county area. Taken 

together, the estimated changes in the number total of part- and full-time jobs range from no 

change in 2011 to a loss of four jobs in 2015. The estimated change in the annual labor income 

from the current condition ranges from +$22,907 during 2011, to minus $53,626 during 2015. 

The explanation for why there is an increase in labor income estimates for 2011 is that the new 

investments outweigh the reductions the first year. 

Tables 3.45 and 3.46 display annual part- and full-time employment and labor income

contributions from the federal forage and on all cows, calves, and yearlings spending any time on 

NFS lands in the project area. Changes from the current conditions are indicated in parentheses.
FEIS Vol. I North Billings County Allotment Management Plan Revisions

248 | Chapter 3

Table 3.45 — Annual part- and full-time employment and labor income contributions 

from federal forage, Alternative 4*

Alternative 4 2011 2012 2013 2014

2015 and Each 

Year in the 

Future

Direct part and fulltime jobs

contributed per 

year

10

(+1)

10

(+1)

10

(+1)

10

(+1)

10

(+1)

Indirect and 

induced part and 

full-time jobs

contributed per 

year

10

(0)

9

(-1)

9

(-1)

9

(-1)

9

(-1)

Total part and fulltime jobs

contributed per 

year

20

(0)

19

(-1)

19

(-1)

19

(-1)

19

(-1)

Direct labor income

contributed per 

year

$128,926 

(+$40,250)

$125,131

(+$36,455)

$123,650

(+34,974)

$123,322

(+$34,636)

$123,295

(+$34,619)

Indirect and 

induced labor 

income contributed 

per year

$253,478

(-$17,341)

$241,886

(-$28,933)

$237,364

(-$33,455)

$236,362

(-$34,457)

$236,281

(-$34,538)

Total labor income

contributed per 

year**

$382,404

(+22,907)

$367,017

(+$7,520)

$361,014

(+$1,517) 

$359,684

(+$187) 

$359,576

(+$79)

* Changes from current contributions indicated in parentheses.

** Totals reflect the sum of rounded estimates.
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Table 3.46 — Annual part- and full-time employment and labor income contributions 

from federal forage based on the economic contribution of all cows, yearlings and calves 

that spend time in the project at some point in the year, Alternative 4*

Alternative 4 2011 2012 2013 2014

2015 and Each 

Year in the 

Future

Direct part and 

full-time jobs

contributed per 

year

19

(0)

18

(-1)

18

(-1)

17

(-2)

17

(-2)

Indirect and 

induced part and 

full-time jobs

contributed per 

year

19

(-1)

18

(-2)

17

(-3)

17

(-3)

17

(-3)

Total part and fulltime jobs

contributed per 

year

37

(-2)

36

(-3)

35

(-4)

35

(-4)

35

(-4)

Direct labor 

income

contributed per 

year

$207,221

(+$32,469)

$199,742

(+$24,990)

$196,823

(+$22,071)

$196,177

(+$21,425)

$196,124

(+$21,372)

Indirect and 

induced labor 

income

contributed per 

year

$492,593

(-$41,105)

$469,750

(-$63,948)

$460,838

(-$72,860)

$458,863

(-$74,835)

$458,703

(-$74,995)

Total labor income

contributed per 

year**

$699,814

(-$8,639)

$669,492

(-$38,961)

$657,661

(-$50,792)

$655,040

(-$53,413)

$654,827

(-$53,626)

* Changes from current contributions indicated in parentheses.

**Totals reflect the sum of rounded estimates.

Alternative 4 would see a reduction in grazing fees collected; therefore, fewer Bankhead-Jones 

and conservation practice funds would be available. The U.S. Treasury would also see a 

reduction in funds paid into the treasury. Table 3.47 shows what those reductions may look like 

based on a current congressionally set rate of $1.35 / head month.

Table 3.47 — Effects of Alternative 4 on grazing fee collections

Alternative 4 2011 2012 2013 2014

2015 and Each

Year in the 

Future

Grazing fees $35,763 $34,083 $33,425 $33,279 $33,268
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Alternative 4 is also an adaptive alternative, so if further reductions in authorized AUMs were 

necessary there might be some additional negative impacts past 2014, and the receipts to the U.S.

Treasury, counties, and grazing association would decrease from current levels. The amount is 

unknown because future possible reductions are unknown.

The NDSU Ranch Viability Analysis 

The NDSU ranch viability analysis describes new expectations for each of the three herd-size 

operations as well as the change from baseline conditions for both net margins and debt 

repayment capacity. 

For a 150-cow herd, a grazing reduction of 10 percent was expected to reduce livestock sales 

over the study period by about $103,000. Cumulative net margins over the period decreased by 

$36,000 relative to the baseline situation (NDSU Report - Table 1). The combination of fewer 

cows and greater relative fixed expense per cow resulted in net margins decreasing in percentage 

terms and dollar values in excess of the relative reduction in grazing capacity. Over the study 

period, a 10 percent reduction in herd size for a 150-cow herd reduced cumulative net margins 

by over 16 percent (NDSU Report --Table 1). Under the 10 percent reduction scenario for a 150-

cow herd, the average annual debt repayment capacity decreased to nearly $7,700 or by 46 

percent from baseline levels. With just a 10 percent reduction in herd size, ranches with debt-toasset ratios greater than 20 percent would likely find their ability to service debt substantially 

compromised.

A grazing reduction of 20 percent was expected to reduce livestock sales over the study period 

by about $202,000. Cumulative net margins over the period decreased by $68,000 relative to the 

baseline situation (NDSU Report - Table 2). Over the study period, a 20 percent reduction in 

herd size for a 150-cow herd reduced cumulative net margins by over 31 percent (NDSU Report 

- Table 2). With a 20 percent reduction in herd size, even a ranch with low debt-to-asset ratios 

would have difficulty meeting debt obligations. While under baseline conditions, a typical ranch 

would likely handle debt obligations with a debt-to-asset ratio between 40-to-60 percent. With a 

20 percent grazing cut, that same ranch would no longer be capable of servicing an average level 

of debt.

A grazing reduction of 40 percent was expected to reduce livestock sales over the study period 

by about $395,000. Cumulative net margins over the period decreased by $128,000 relative to 

the baseline situation (NDSU Report - Table 3). Over the study period, a 40 percent reduction in 

herd size for a 150-cow herd reduced cumulative net margins by 58 percent (NDSU Report -

Table 3).

The profitability of the enterprise was reduced substantially greater than the relative loss of 

livestock sales in all cases.

A 250-cow herd was projected to generate in excess of $1.5 million in gross livestock sales over 

the 10-year study period based on average productivity coefficients and expected future livestock 

prices (NDSU Report - Table 1). Over that period, after accounting for expected changes in 

variable expenses and fixed expenses, that operation would likely generate a cumulative net 
FEIS Vol. I North Billings County Allotment Management Plan Revisions

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margin around $308,000 (NDSU Report - Table 1). By comparison, a grazing reduction of 10 

percent was expected to reduce livestock sales over the study period by about $164,000.

Cumulative net margins over the period decreased by $55,000 compared to the baseline 

situation. Over the study period, a 10 percent reduction in grazing capacity for a 250-cow herd 

reduced cumulative net margins by 18 percent (NDSU Report - Table 1). A 10 percent reduction 

in herd size also results in a substantial decrease in the ranch’s ability to cover debt payments.

While the debt repayment margin was estimated to remain positive under a 10 percent herd 

reduction, the margin decreased by 57 percent from baseline levels. Repayment margins would 

suggest ranches with debt-to- asset ratios less than 40 percent could handle average debt with a 

10 percent reduction in cow-herd size. Conversely, slight reductions in herd size would create 

debt repayment problems for typical 250-cow herd ranches with greater than 40 percent debt-toasset ratios.

A grazing reduction of 20 percent was expected to reduce livestock sales over the study period 

by about $313,000. Cumulative net margins over the period decreased by $94,000 compared to 

the baseline situation. Over the study period, a 20 percent reduction in grazing capacity for a 

250-cow herd reduced cumulative net margins by nearly 31 percent (NDSU Report - Table 2). A 

20 percent reduction in herd size results in a substantial decrease in the ranch’s ability to cover 

debt payments. While the debt repayment margin was estimated to remain positive under a 20 

percent herd reduction, the margin decreased by 78 percent from baseline levels.

A grazing reduction of 40 percent was expected to reduce livestock sales over the study period 

by about $614,000. Cumulative net margins over the period decreased by $177,000 compared to 

the baseline situation. Over the study period, a 40 percent reduction in grazing capacity for a 

250-cow herd reduced cumulative net margins by nearly 57 percent (NDSU Report - Table 3). A 

40 percent reduction in herd size results in a substantial decrease in the ranch’s ability to cover 

debt payments. While the debt repayment margin was estimated to remain positive under a 40 

percent herd reduction, the margin decreased by over 62 percent from baseline levels. A typical 

ranch with a 250-cow herd with debt-to-asset ratios at 20 percent or less would be capable of 

handling their debt obligations.

A 350-cow herd was projected to generate nearly $2.2 million in gross livestock sales over the 

10-year study period based on average productivity coefficients and expected future livestock 

prices (NDSU Report - Table 1). Over that period, after accounting for expected changes in

variable expenses and fixed expenses, that operation would likely generate a cumulative net 

margin around $432,000 (NDSU Report - Table 1). By comparison, a grazing reduction of 10 

percent was expected to reduce livestock sales over the study period by about $235,000.

Cumulative net margins over the period decreased by $82,000 compared to the baseline 

situation. Over the study period, a 10 percent reduction in grazing capacity for a 350-cow herd 

reduced cumulative net margins by 19 percent (NDSU Report - Table 1). A 10 percent reduction 

in herd size results in a substantial decrease in the ranch’s ability to cover debt payments. While 

the debt repayment margin was estimated to remain positive under a 10 percent herd reduction, 

the margin decreased by 76 percent from baseline levels. Repayment margins would suggest 
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ranches with debt-to-asset ratios less than 40 percent could handle average debt with a 10 percent 

reduction in cow-herd size.

A grazing reduction of 20 percent was expected to reduce livestock sales over the study period 

by about $445,000. Cumulative net margins over the period decreased by $139,000 compared to 

the baseline situation. Over the study period, a 20 percent reduction in grazing capacity for a 

350-cow herd reduced cumulative net margins by 32 percent (NDSU Report - Table 2). A 20 

percent reduction in herd size results in a substantial decrease in the ranch’s ability to cover debt 

payments (i.e., $233,000 compared to -$7,300) and would likely jeopardize the ability to cover 

average debt repayment levels. Repayment margins would suggest 350-cow herd ranches with 

debt-to-asset ratios less than 40 percent could handle average debt with a 20 percent reduction in 

cow-herd size.

A grazing reduction of 40 percent was expected to reduce livestock sales over the study period 

by about $874,000. Cumulative net margins over the period decreased by $262,000 compared to 

the baseline situation. Over the study period, a 40 percent reduction in grazing capacity for a 

350-cow herd reduced cumulative net margins by 60 percent (NDSU Report - Table 3). The sum 

of the debt repayment margins over the study period was $233,000 for the baseline condition and 

($144,000) for the 40 percent grazing reduction scenario (NDSU Report - Table 5). A 40 percent 

reduction in herd size would prevent an average ranch from being able to service average levels 

of debt. Repayment margins would suggest a typical ranch with a 350-cow herd, under the 40 

percent herd reduction scenario, would only be capable of servicing debt if the ranch had debt-toasset ratios less than 20 percent prior to the grazing reductions.

Summary of Debt Repayment Capacities

Debt repayment capacities were estimated for three cow herd sizes. A baseline condition was 

estimated, along with changes to debt repayment capacities under a 10 percent, 20 percent, and 

40 percent grazing cut. The results of estimating debt repayment capacities and debt repayment 

margins clearly show that both on relative and absolute terms, the 150-cow herds cannot support 

the same level of debt as the larger cow herds. Further, small reductions in grazing capacity 

quickly compromise the ability of the 150-cow herds to service debt. For the larger herds, debt 

repayment becomes compromised with 20 percent or greater grazing cuts; although, some herds 

could have trouble meeting debt obligations if they are over leveraged prior to even modest 

grazing cuts. Regardless of existing debt obligations, debt repayment capacities for all herd sizes 

decreased with grazing cuts. In some cases, debt repayment capacities became negative–

implying that the herd could no longer service any debt. Under those circumstances, only debt 

free operations would survive grazing cuts.

Regardless of the magnitude of grazing reductions or size of the cow herd, highly leveraged 

ranches will have greater difficulty meeting debt obligations. Ranches with debt- to-asset ratios 

in the neighborhood of 40 percent or greater prior to the grazing reductions will experience 

substantially reduced debt repayment capacities. With the 20 percent and 40 percent grazing 

cuts, the 150-cow herds are unlikely to be able to service any debt. Even debt-free herds in the 

150-cow size might find survivability compromised since they no longer have the ability to 
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finance any debt, which might prevent the ranch from acquiring necessary intermediate debt 

(e.g., financing replacement machinery). The vulnerability of the larger cow-herds becomes 

more pronounced as the grazing cuts exceed 20 percent. Under the 40 percent grazing reductions, 

only the largest cow herds with the lowest debt levels would remain capable of servicing their 

debt obligations after herd reductions.

The assessment of debt repayment capacities did not examine all of the strategies to cope with 

decreased herd sizes and the accompanying reduction in debt repayment capacities. The 

assessment did not attempt to evaluate how debt repayment might be affected by adjusting key 

financial measures reflective of individual ranch characteristics or strategies for handling herd 

reductions (e.g., reducing family living withdrawals, securing additional non- farm income).

Also, the one-time sale of breeding stock was ignored in the analysis (see Project Record, 

Cooperating Agency for discussion of the values of herd liquidations). It is plausible to expect 

that ranches facing grazing cuts might choose to use that cash to pay down existing debt. 

However, it is also plausible that ranches might retain those resources to assist in meeting 

unforeseen financial obligations over the short term. Another potential option for ranches would 

be to sell some ranch assets to pay down existing debt. What those ranch assets would be, and 

how many assets would be available for sale will vary by ranch size (i.e., less flexibility for small 

ranches) and individual operations. Ultimately, each ranch will handle the specifics of a grazing 

reduction in a manner that best suits the individual physical and financial characteristics of the 

ranch. However, based on typical and average values for debt, it remains unclear how existing 

ranches that have moderate to high levels of debt would find the resources to service existing 

debt obligations after incurring the proposed level of grazing cuts.

The NDSU report provides summary information suggesting what will happen to permittees with 

various size cow-calf operations under three reduction levels in terms of the operation’s net 

margins and their operator’s debt repayment capacity. These analyses are intended to represent 

many of the scenarios under Alternative 4. The loss of cow-calf operations described as a likely 

outcome of AM reductions on North Billings allotments by the NDSU economists would have 

similar effects to the direct decreases in jobs and labor income contributions estimated in the 

regional economic impact analysis. The regional economic impact analysis goes the extra step of 

describing the additional multiplier effects that would be felt in the twelve-county economic 

impact area. 

The social impacts of the Alternative 4 reductions in Authorized Use are the same as those in 

Alternative 1 except that fewer people would be likely to change positions, retire, etc., as a result 

of this alternative. If further reductions in Authorized Use were to occur as adaptive actions, it 

could have a multiplier effect in terms of the number of people who may change lifestyles or 

seek additional work. However, the effects would depend on the same factors as those identified 

in Alternative 3 and 3A above. Without knowing this information it not feasible to predict the 

effects of additional reductions in authorize use. 

Perhaps the largest social impacts would be the relationship between the cattle ranching 

community and the Forest Service. This long tradition of grazing NFS lands would likely be 

perceived as degrading. 
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Summary of Economic and Social Conditions

The Forest Service has taken a hard look at the existing social and economic conditions and the 

consequences of implementing the five alternatives. This evaluation of existing conditions and 

contributions consists of a brief demographic and economic profile, a description of social 

setting, and a description of the spectrum of current contributions that federal forage makes to 

the regional economy (based on two calculation methods). This was conducted by a Forest 

Service Northern Region (Region 1) economist. This analysis indicates that there are between 9 

and 19 direct part- and full-time jobs and 20 to 39 total (direct plus multiplier) part- and full-time 

jobs associated with the forage available and the cattle feeding on that forage at some point in the 

year, respectively.

The depiction of the existing condition also includes ranch viability and debt repayment capacity 

analyses conducted by economists with NDSU, compiled for Billings County, a cooperating 

agency. The NDSU report provides estimates of the number of affected MGA permittees in 

several herd size categories and attempts to reveal current annual net margins from cow-calf 

operations for three herd sizes (150, 250, and 350 head). The report shows that, based on NDSU 

projections for input and beef prices for the next 10 years, even with no changes, under the 

baseline condition the smallest ranch operations will struggle to service medium and long-term 

debt. The 250-head and 350-head ranch operations appear to be capable of servicing debt under 

the baseline scenario (Alternative 2). 

The report then addresses the impacts of implementing the five alternatives using many of the 

same tools, where impacts are defined as changes from existing condition. The regional 

economic impacts are based on any planned reductions in AMs of Forest Service grazing for 

alternatives 1 and 4 using the same two calculation methods used to estimate the existing 

contribution; the reductions in AMs are shown as both purely NFS AM reductions and as 

reductions in the total number of AMs reflecting a loss of all cattle spending any time of the year 

on NFS lands. The regional economic impact estimates also account for the small increases in 

Forest Service expenditures associated with allotment improvements in alternatives where these 

apply (3, 3A, and 4). These regional economic impacts are broken into direct impacts and 

multiplier impacts (indirect and induced) and then summed as total impacts. The majorities of 

the direct impacts, shown in the regional economic impact analysis, are due to AM reductions 

and are moderated only slightly by increased investments in allotment improvements. 

The NDSU report provides summary information suggesting what will happen to permittees with 

various size cow-calf operations under three reduction levels in terms of the operation’s net 

margins and their operator’s debt repayment capacity. These analyses are intended to represent 

many of the scenarios under Alternative 4. The loss of cow-calf operations described as a likely 

outcome of AM reductions on allotments in the project area by the NDSU economists would 

have similar effects to the direct decreases in jobs and labor income contributions estimated in 

the regional economic impact analysis. The regional economic impact analysis goes the extra 

step of describing the additional multiplier effects that would be felt in the 12-county economic 

impact area. 
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In general, Alternative 1 would terminate existing contributions that the project area makes to 

local ranch operations and the regional economy after grazing was eliminated (2012). This would 

also terminate the multiplier effects associated with these direct contributions and it would cause 

undesirable social change through the transition of several cattle ranching operators to other jobs 

and retirement, and to possible land sales. Barring unforeseen circumstances, Alternative 2 

would maintain economic current contributions and the ability to handle debt. Alternatives 3 and 

3A would provide a small increase in short-term contributions to the local economy from 

increased Forest Service investments in improvements, but, depending on monitoring and future 

AM scenarios, longer term impacts could be close to the existing contributions shown for 

Alternative 2 or the impacts associated with reductions under alternative 4. Alternative 4 is 

predicted under the Forest Service analysis to result in labor income impacts ranging from an 

additional $79 to a loss of $53,626 of annual labor income. 

Under the NDSU analysis, Alternative 4 would reduce ranchers’ net margins and debt repayment 

capacity as early as 2011, probably making it impossible for some permittees to survive many 

more years as cow-calf operations. The reduction in AMs and, therefore, reductions in 

marketings from this area would lead to negative direct effects, as well as negative multiplier 

effects for the 12-county economic impact area. This alternative could also cause social change 

through the transition of several cattle ranching operators to other jobs, retirement, and/or 

possible land sales.

As with any modeling, the combination of assumptions used and the fact that the economy is 

dynamic (the current boom in oil and gas) mean that both the ranch viability analysis and the 

regional economic impact analysis are best used as relative projections between alternatives. 

What is clear, however, is that those that could be affected by the selection of any alternative—

local ranchers and communities— hold cattle ranching culture in high esteem and do not wish to 

lose this cultural identity and preferred lifestyle. 

CUMULATIVE EFFECTS 

Cumulative effects result from the combination of effects resulting from past, present, and 

reasonably foreseeable actions plus the direct and indirect effects of the alternatives. A 

discussion of past and present actions, reasonably foreseeable actions, and a summary of the 

cumulative effects by alternative follows.

Past and Present Actions 

The following past and present actions have likely influenced economic conditions associated 

with raising livestock in the project area.

Livestock ranching has occurred on what is now the Little Missouri National Grassland (LMNG)

since the 1880s. Over the decades combinations of climatic events, markets, ranching and 

business management decisions, etc., have affected the economic returns associated with raising 

livestock on the LMNG. Drought, poor farming, and livestock management practices combined 

with the economic depression of the 1930s drove many ranchers out of the livestock industry. 
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Those days have passed; however, some of the same challenges remain today. Drought is a 

continuing factor directly affecting ranching operations and economic outcome. Noxious weeds, 

oil and gas development, and wildfire also continue to affect livestock management and 

economic returns. Fluctuations in livestock markets, business management decisions, etc., 

continue to affect economic returns, which in turn affects ranching profitability. 

Reasonably Foreseeable Actions

Elkhorn Ranchlands. The recently purchased Elkhorn Ranchlands require that the Grasslands 

Plan be amended to establish management direction for the newly acquired lands. Approximately 

800 acres of the 5,200-acre Elkhorn purchase are directly associated with five of the allotments 

in the North Billings project. Under the proposed amendment, these lands would be managed in 

accordance with the adjacent management area which is MA 3.65 Rangelands with Diverse 

Natural Appearing Landscapes. In the interim, as directed by 36 CFR 254.3(f)(2008), these 

portions of the purchase are being managed in accordance with the adjacent MA 3.65. 

The proposed Plan amendment for the Elkhorn Ranchlands also includes establishing a special 

interest area (SIA) for the remaining 4,400 acres of the purchase and approximately 17,160 acres 

contained in grazing allotments 279 and 280, which were associated with the Elkhorn 

Ranchlands when they were owned privately. If implemented, the SIA would establish a forage 

reserve on those acres. 

Travel Management. An environmental assessment (EA) for travel management on the LMNG 

was released for comment in 2010. The proposed action under this EA would close all single-use 

oil and gas roads, unauthorized roads (i.e., two tracks), and an additional 18 miles of system 

roads in the project area. The travel management plan is expected to have minimal effect on 

grazing permit holders unless single-use roads are blocked from access. If access were to be 

blocked, then additional two-track roads could be created as permittees can travel cross county to 

administer their permits. It would be unlikely that the travel management plan would have an 

effect on economic and social conditions.

Oil and Gas Development. The Forest Service has received five applications for permit to drill 

(APDs) on NFS lands in the project area. The APDs seek to drill oil and gas wells. The well pads 

associated with each well would be approximately 4 to 5 acres in size, encompassing about 22 

acres total. Approximately 4,250 feet of roads would be built to access the well sites. The well 

pads would be surfaced with scoria or gravel and kept free of vegetation so there is little 

opportunity to encourage the spread of invasive grasses. One of the proposed wells is located 

with a mile of a known sharp-tailed grouse lek the others are not. 

Cumulative Effects by Alternative 

ECONOMICS

This section summarizes direct and indirect effects of the alternatives and the effects of 

reasonably foreseeable actions on economics. These effects in combination with past and present 

effects combine to create cumulative effects.
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Alternative 1 would result in a shift of current livestock grazing occurring on national grasslands 

to private pasture and/or feeding operations and a reduction in the number of cattle grazing in the 

economic impact area starting two years after notification of permit cancellation. Under this 

alternative some people may retire or change to other professions. This may result in a new 

configuration of cattle ranching operations in the economic impact area. Some land owners with 

pasture available for lease may benefit from new demand.

Reasonably foreseeable oil and gas exploration and extraction are expected to continue to grow 

in the area and on the LMNG. Oil and gas development may provide an additional source of 

income for some ranchers or a different career opportunity. The employment growth in the oil 

and gas sector will likely outpace any declines in the cattle ranching and farming sector, even 

when considering forward and backward economic linkages with cattle ranching. The Elkhorn 

Ranchlands Grasslands amendment may offer some relief as an alternate source of forage for a 

limited number of livestock for short periods of time. 

Alternative 2 represents the current grazing occurring on the 43 allotments. No changes are 

anticipated in federally authorized AMs. This means the current economic contributions from the 

allotments would continue, there would be no changes to economic impacts and no change to 

collected receipts expected from federal actions unless grazing fees change. However, ranchers 

with small herds may need to seek additional income or new job opportunities as market factors 

and other factors may cause some ranchers with smaller operations to leave the ranching 

industry.

The NDSU ranch viability analysis describes baseline conditions and associated 10-year 

enterprise conditions as total and annual net margins and annual and total debt repayment 

capacity. Since this alternative would not change grazing levels in the project area, these baseline 

observations would persist, and there would be no change from the existing condition. However, 

as pointed out by the NDSU analysis, small herd ranchers are barely able to service livestock 

related debt. Given the uncertainty of future markets, management decisions, etc., the cumulative 

effects would be the same as identified under the Forest Service analysis, that is, some ranchers 

may leave the livestock ranching occupation, find additional work to supplement ranch income, 

change careers, or retire. The effect of reasonable foreseeable actions would be the same as 

previously identified.

Alternatives 3 and 3A would initially maintain stocking at current levels, so the cumulative 

effects are similar to Alternative 2. However, if monitoring indicates that impacted resources are 

not making sufficient progress towards desired conditions and reductions in Authorized Use are 

implemented as adaptive actions, then cumulative effects would change. However, the effects 

would vary depending on the size of the reductions, the size of the ranching operation, other 

available forage opportunities, reasonably foreseeable events, and other factors, so it is not 

possible at this time to predict the cumulative effects. 

Alternative 4 sets Authorized Use at carrying capacity, which is predicted to reduce the ability of 

ranchers to repay debt and the number of jobs and labor income generated in the impact areas 

cattle ranching sector. Both the Forest Service and NDSU analyses indicate a reduction in jobs. 
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The Forest Service analysis predicted up to four jobs lost in the 12-county economic impact area 

and a loss of up to about $53,600 in annual labor income. The NDSU analysis indicates that the 

150-cow herd could not support the same levels of debt as the 250- and 350-cow herds and that 

small reductions in grazing capacity quickly compromise the ability of the 150-cow herd 

ranchers to repay debt. It also points out that regardless, of existing debt obligations, debt 

repayment capacities for all herd sizes decrease with grazing reductions. In some cases, debt 

repayment capacities become negative, implying that the herd could no longer service any debt.

Under those circumstances, only debt-free operations would survive grazing reductions. The 

NDSU report concludes that this alternative may result in an unspecified number of ranchers 

leaving the ranching industry.

The cumulative effect of this alternative impacting a handful of jobs in the 12-county economic 

impact area, which had 57,261 jobs during 2005, is low; however, to those directly affected it 

may be a major change resulting in a new career, lifestyle changes, or retirement. Reasonably 

foreseeable oil and gas development may provide additional income or new career opportunities 

and the Elkhorn amendment may offer some short term forage alternatives. 

Adaptive Management: If monitoring reveals that initial proposed action are not achieving 

desired resource outcomes than adaptive options or other tools from the grazing management 

toolbox would be implemented to address the concern. The selected tools may include additional 

Authorized Use reductions, other structural or nonstructural actions or a combination thereof. 

Actions affecting Authorized Use would likely affect jobs and revenue whereas changes in range 

infrastructure or grazing systems probably would not. Because of the different combinations of 

management actions that could be implemented under the action alternatives, it is not possible at 

this point to determine the potential cumulative economic effects.
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SOCIAL 

Livestock grazing has occurred in the project are since at least the 1880s. At that time 

communities were often formed around ranching and the agricultural sectors in western North 

Dakota. Those communities that have endured are still influenced socially and economically by 

these sectors today. For many, raising livestock is more than an occupation it defines their 

lifestyle and life choices. So anything perceived as a threat to the occupation is also seen as a 

threat to a valued way of life. 

The reasonable foreseeable actions associated with this project proposal include the LMNG 

Travel Management EA, the Elkhorn Ranchlands Grasslands Plan amendment, and oil and gas 

development. 

Alternative 1 would result in the cessation of livestock grazing on the allotments contained in the 

project area. This may lead to changes in professions and lifestyles as ranching operations are no 

longer able to continue due to lack of graze or the ability to replace graze. The social fabric of 

smaller rural communities may be affected if longtime ranching residents leave the area for other 

jobs or retire to larger communities. Another social impact would be the relationship between the 

cattle ranching community and the Forest Service. This long tradition of grazing NFS lands 

would likely be perceived as degrading. Even if resource conditions were to improve following 

the implementation of proposed actions, and even if this spurred additional economic activity in 

the agriculture support services and recreation and tourism-related sectors (such as hunting and 

bird watching), the net effect would likely be a negative perception of federal lands management.

Reasonably foreseeable oil and gas development offers the potential for new jobs or 

supplemental income, however, for some this may mean the loss or modification of a valued way 

of life.

Alternative 2 would maintain the current lifestyles and normal economic cycles. Ranching 

operations may change as ranches are bought and sold; communities would adjust accordingly. 

Oil and gas development may offer additional sources of income or a second job opportunity. 

The relationship between the ranching community and the Forest Service would likely remain 

the same. The Elkhorn Ranchlands Plan amendment would offer alternate sources of forage in 

the event of graze being lost to fire or other natural climatic events.

Alternatives 3 and 3A initially do not reduce Authorized Use; therefore, the social effects would 

be similar to Alternative 2. If monitoring shows that additional management actions are needed 

and reductions in authorize use occur, then there could be a shift of some livestock grazing from 

federal to private lands and, if the federal graze can’t be made up for by private graze and /or 

feeding, a possible reduction in herd sizes. This may lead to a new configuration of cattle 

ranching operations in the economic impact area. In other cases, the increased cost of renting 

private graze and/or feed for the current herd size could lead to a smaller number of cattle 

ranching operations. This could mean that some people retire or change to other professions. 

However, this is supposition because the amount of reductions, if they occur, is unknown at this 

point it time. Oil and gas development may offer additional sources of income or a second job 
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opportunity. The Elkhorn Ranchlands Plan amendment would offer alternate sources of forage in 

the event of graze being lost to fire or other natural climatic events.

Alternative 4 is projected to result in the loss of one to four jobs, loss of annual labor income, 

and reductions in cumulative net margins and the ability pay down debt. Under Alternative 4,

with the initial reductions, and possibly with additional reductions following monitoring, there 

would be an immediate shift of some livestock grazing from federal to private lands and a 

possible reduction in herd sizes if the federal graze can’t be made up with private graze and /or 

feeding. This may lead to a new configuration of cattle ranching operations in the economic 

impact area. In other cases the increased cost of renting private graze and/or feed for the current 

herd size could possibly lead to a smaller number of cattle ranching operations. This could mean 

that some people may retire or change to other professions. Oil and gas development may offer 

additional sources of income or a second job opportunity. The Elkhorn Ranchlands Plan 

amendment could offer alternate sources of forage in the event of graze being lost to fire or other 

natural climatic events if the Grasslands Plan were amended to allow this.
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Index

A

adaptive management, xiv, xix, xxii, xxiii, 15, 16, 17, 46, 51, 

54, 57, 63, 69, 93, 247

alternative, vii, xii, xiv, xxii, xxiii, 1, 7, 17, 20, 32, 44, 46, 51, 

62, 63, 69, 74, 87, 102, 103, 180, 188, 197, 216, 218, 

225, 246, 247, 248, 251

alternatives, vii, xi, xii, xviii, xxii, xxiii, 1, 15, 17, 20, 26, 32, 

44, 49, 51, 62, 63, 69, 74, 208, 238

AM, xviii, xxix, 50, 69, 247

AMs, 94, 102, 104, 107, 238, 239, 244, 245, 247, 248, 251, 

258

animal month, 237, 245

animal months, 237, 245

animal unit equivalent, 93

animal unit equivalents, 93

AUEs, 93

AUE, 93

AUEs, 93

AUM, xviii, 50, 216

AUMs, xv, xviii, xxix, 33, 42, 46, 50, 69, 248

C

carrying capacity, 51, 188, 248

CEQ, 16, 27, 77

Council on Environmental Quality, 16, 17, 27

Council on Environmental Quality (CEQ), 16

cow size, xv, 46, 93

D

deferred rotation, 16

E

early seral stage, xxvi, 67, 188

ecological site, 188

ecological sites, 188

economics, xi, 26

Economics, xi, 26

ephemeral stream, 121

ephemeral streams, 121

erosion, ix, 22, 29, 75, 79, 134, 187

F

Forest Service Handbook (FSH), xiii, 45, 244

Forest Service Manual (FSM), 11

G

grazing association, 5, 6, 29, 86, 93, 94, 242, 243, 247, 251

H

habitat, x, xiii, 23, 29, 30, 31, 33, 34, 45, 79, 81, 188, 195, 

211, 212, 213, 214, 216, 219, 222

herbaceous structure, vi, xiii, 14, 45, 61, 180, 212, 213, 

214, 216

I

income, xi, xxvii, 26, 68, 235, 237, 238, 239, 245, 246, 247, 

248, 249, 250

intermittent stream, ix, 22, 78, 81

intermittent streams, ix, 22, 78, 81

invasive grasses, xxvi, 67, 84, 197, 201, 202, 208, 210

invasive species, 197

issues, iv, viii, xii, xxii, 1, 12, 16, 20, 22, 27, 44, 58, 64

J

jobs, xi, 26, 234, 237, 238, 244, 245, 246, 247, 248, 249, 

250, 259

L

late seral stage, xi, xxvi, 25, 61, 67, 188, 201

M

MA, 8

management area, 7, 8, 10

management areas, 8

management indicator species, 33

MAs, 8

mid seral stage, 188

MIS, 33, 35, 36, 211

N

noxious weeds, 20, 30, 81, 84, 134, 208

O

overgrazing, 29, 79

P

perennial stream, 78

perennial streams, 78

PFC, ix, xxi, xxiv, 22, 56, 58, 59, 64

plant composition, xi, 25, 61, 188

preference, xiv, 46, 237, 243

prescribed burn, xv, xix, 47, 50

prescribed fire, xix, 50
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R

recreation, 10, 11, 31, 32, 33, 132, 236, 260

S

scoping, vii, xii, 21, 44

SRT, 15

V

VOR, xxi, 56, 60, 172, 212, 213

W

wildfire, 145, 208

winter feeding, xv, 47, 94

winter grazing, 94

woody draw, x, xiii, xv, xx, xxi, xxv, 23, 31, 45, 47, 55, 56, 

59, 60, 65, 75, 76, 101, 131, 132, 133, 134

woody draws, ix, x, xv, xx, xxi, xxv, 23, 31, 47, 55, 56, 59, 

65, 101, 131, 132, 133, 139, 145, 146