United States 

Department of 

Agriculture 

Forest 

Service 

June 2009 

 

Draft Environmental 

Impact Statement 

North Billings County Allotment 

Management Plan Revisions 

Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

i 

North Billings County Allotment Management Plan Revisions 

Draft Environmental Impact Statement 

Medora Ranger District, Dakota Prairie Grasslands 

Billings County, North Dakota 

Lead Agency: USDA Forest Service 

Responsible Official: Ronald W. Jablonski, Jr., 

 District Ranger 

Medora Ranger District 

 99 23rd Ave W. Suite B 

Dickinson, ND 58601 

 

For information contact: Jeff Adams, Project Leader 

 Nickole Dahl, Project Co-leader 

Medora Ranger District 

 99 23rd Ave W. Suite B 

 Dickinson, ND 58601 

 701-227-7800 

Abstract: This draft environmental impact statement 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 ensure that the project area is meeting or moving toward management direction 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. Alternatives include No Action 

(no grazing), Existing Management, Proposed Action, which continues general 

management but incorporates some changes and adaptive management to address sitespecific concerns, and a fourth alternative which modifies the proposed action, but keeps 

the adaptive management options. The effects of each alternative are described to 

compare and contrast the alternatives. The responsible official has not identified a 

preferred alternative because he would like to hear what the public has to say about the 

project and its alternatives before selecting a course of action. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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EEO Statement - “The U.S. Department of Agriculture (USDA) prohibits discrimination in all 

its programs and activities on the basis of race, color, national origin, age, disability, and where 

applicable, sex, marital status, familial status, parental status, religion, sexual orientation, 

genetic information, political beliefs, reprisal, or because all or part of an individual’s income is 

derived from any public assistance program. (Not all prohibited bases apply to all programs.) 

Persons with disabilities who require alternative means for communication of program 

information (Braille, large print, audiotape, etc.) should contact USDA's TARGET Center at 

(202) 720-2600 (voice and TDD). To file a complaint of discrimination, write to USDA, 

Director, Office of Civil Rights, 1400 Independence Avenue, S.W., Washington, D.C. 20250-

9410, or call (800) 795-3272 (voice) or (202)720-6382 (TDD). USDA is an equal opportunity 

provider and employer.” 

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
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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Invitation to Comment 

Reviewers should provide the Forest Service with their comments during the review 

period of the draft environmental impact statement. This will enable the Forest Service to 

analyze and respond to the comments at one time and to use information acquired in the 

preparation of the final environmental impact statement, thus avoiding undue delay in the 

decision making process. 

The Medora District Ranger will consider all public comments before making a decision. 

In order to retain your administrative appeal rights, you must provide timely, written, 

oral, or electronic comments. Comments should include: (1) name, address, telephone 

number, and organization represented, if any; (2) title of the document on which the 

comment is being submitted; (3) specific facts and supporting reasons for the District 

Ranger to consider. For appeal eligibility, each individual or a representative from each 

organization submitting comments must either sign the comments or verify identity upon 

request. Comments received in response to this solicitation, including names and 

addresses of those who comment, will be considered part of the public record and will be 

available for public inspection. Comments received anonymously will be accepted and 

considered; however, those who submit anonymous comments may not have standing to 

appeal the subsequent decision under 36 CFR part 215. 

To ensure consideration, and establish appeal standing, comments must be postmarked or 

received at the Medora Ranger District office on the 45th calendar day following 

publication of the notice of availability (NOA) in the Federal Register. Comments can be 

mailed, faxed, emailed, hand-delivered or made orally. Please address your written 

comments to Ronald W. Jablonski, Jr., District Ranger, Medora Ranger District, 99 23rd

Ave. W.,Suite B, Dickinson, North Dakota 58601. Comments may also be handdelivered to this address from 8:00 a.m. to 4:30 p.m., Monday through Friday. Faxed 

comments should be to the attention of Jeff Adams or Nickole Dahl, project co-leaders, at 

(701) 227-7801. Oral comments should be given to Jeff Adams or Nickole Dahl, project 

co-leaders, at the District Office or by telephone, (701) 227- 7800, during business hours. 

Additional information on the project proposal may be obtained through any of the above 

contacts. 

Electronic comments may be submitted to comments-northern-dakota-prairie-medora@fs.fed.us. 

The subject line must contain the name of the project for which you are submitting comments. 

Acceptable formats for electronic comments are MS Word, Word Perfect or RTF. For electronically 

mailed comments, the sender should normally receive an automated electronic acknowledgement 

from the agency as confirmation of receipt. If the sender does not receive an automated 

acknowledgement of the receipt of comments, it is the sender’s responsibility to ensure timely 

receipt by other means.

To request a paper copy of the Draft EIS or for additional information contact Jeff Adams 

or Nickole Dahl, project co-leaders at 701-227-7800, by mail at 99 23Ave. W., Suite B,. 

Dickinson, ND 58601. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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Table of Contents 

Summary ix 

Chapter 1 Purpose of and Need for Action 1-1 

 Introduction 1-1 

 Purpose and Need 1-8 

 Proposed Action 1-10 

 Scope of the Proposal 1-20 

 Decision Framework 1-21 

 Tiered and Referenced Documents 1-22 

Chapter 2. Alternatives, Including the Proposed Action 2-1 

 Introduction 2-1 

 Public Involvement 2-1 

 Issues 2-1 

 Issues Dropped from Analysis 2-4 

 Alternatives Considered in Detail 2-13 

 Design Criteria Common to All Alternatives 2-17 

 Alternatives Considered but Dropped from Detailed Analysis 2-18 

 Monitoring 2-18 

 Summary Comparison of Alternatives 2-23 

 

Chapter 3. Affected Environment and Environmental Consequences 3-1 

 Introduction 3-1 

 Project Area 3-1 

 Past, Present and Reasonably Foreseeable Actions 3-3 

 Range 3-8 

 Affected Environment 3-13 

 Environmental Consequences 3-16 

 Riparian 3-54 

 Affected Environment 3-56 

 Environmental Consequences 3-72 

 Woody Draws 3-86 

 Affected Environment 3-89 

 Environmental Consequences 3-98 

 Herbaceous Structure 3-128 

 Affected Environment 3-130 

 Environmental Consequences 3-137 

 Seral Stages 3-142 

 Affected Environment 3-144 

 Environmental Consequences 3-146 

 Sharp-tail Grouse 3-152 

 Affected Environment 3-153 

 Environmental Consequences 3-155 

 Economics 3-159 

 Affected Environment 3-162 

 Environmental Consequences 3-170 

 Global Warming 3-177 

 Affect of Proposed Action on Global Climate Change 3-178 

 Affect of Climate Change on Proposed Projects 3-181 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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 Short-term Use/Long term productivity 3-182 

 Unavoidable Adverse Effects 3-182 

 Irreversible/Irretrievable 3-182 

 Other Required Disclosures 3-183 

Chapter 4. Consultation and Coordination 4-1 

References and Literature Cited 

Index 

Appendices 

Appendix A – Allotment Summary Sheets 

Appendix B – Allotment Maps 

Appendix C – Allotment Existing Condition 

Appendix D – Grazing Management Tool Box 

Appendix E - Glossary 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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List of Figures 

Figure 1-1 Project Area 1-7 

Figure 1-2 Grazing Allotment locations. 1-12 

Figure 1-3 An Illustration of Adaptive Management Process 1-15 

Figure 1-4 Management areas located in the project area. 1-17 

Figure 3-1 Fenceline contrast on Magpie Creek 3-55 

Figure 3-2 Surveys streams and functionality ratings 3-59 

Figure 3-3a Whitetrail Creek incised 3-60 

Figure 3-3b Knickpoint in Whitetail Creek 3-60 

Figure 3-4 Reaches 5, 6 and 7 of Magpie Creek 3-61 

Figure 3-5 Upstream reaches of Whitetail Creek at PFC 3-62 

Figure 3-6 Mikes Creek in pasture 8, 9 and 10 of Allotment 135 3-63 

Figure 3-7a North Creek at PFC 3-64 

Figure 3-7b Spring Creek at PFC 3-64 

Figure 3-8 Reach 4 of Blacktrail creek 3-65 

Figure 3-9a Livestock exclosure along Ash Coulee 3-66 

Figure 3-9b Ash Coulee channel outside livestock exclosure 3-66 

Figure 3-10a Middle reach of Scairt Woman draw 3-67 

Figure 3-10 b Upper reach of Scairt Woman draw 3-67 

Figure 3-11a Reach 7 of Magpie Creek 3-68 

Figure 3-11b Reach 11 of Whitetail Creek 3-68 

Figure 3-12 Livestock concentration area on Magpie Creek 3-70 

Figure 3-13 Decadent box elder tree with basal sprouts 3-89 

Figure 3-14 Example of young green ash trees 3-89 

Figure 3-15a Healthy riparian community adjacent to beaver pond 3-90 

Figure 3-15b Unhealthy conditions in an Ephemeral pond 3-90 

Figure 3-16. Trailing impacts along drainage of woody draw 3-91 

Figure 3-17a & b Healthy woody draw conditions 3-92 

Figure 3-17c & d At risk woody draw conditions 3-92 

Figure 3-17e & f Unhealthy woody draw conditions 3-92 

Figure 3-18 Bar chart of tree density by dbh by woody draw condition 3-94 

Figure 3-19 Person reading a Robel pole 3-129 

Figure 3-20 1996-2001 VOR transect data 3-131 

Figure 3-21 1996-2001 VOR transect distribution 3-132 

Figure 3-22 Herbaceous dominated structure transect results 3-133 

Figure 3-23 2004 and 2005 VOR distribution of stations 3-135 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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List of Tables 

Table 1-1 Grassland Plan Desired Conditions, Existing Conditions, and Need for Action. 1-9 

Table 1-2 Livestock Grazing Allotments included in the proposed action. 1-10 

Table 1-3 Management Area acreage in the project area. 1-18 

Table 2-1 Summary of sensitive species, MIS and raptor information 2-11 

Table 2-2 Grazing Management Toolbox 2-16 

Table 2-3 Design Criteria 2-17 

Table 2-4 Effectiveness Monitoring Schedule 2-20 

Table 2-5 Riparian Monitoring Trigger Points 2-21 

Table 2-6 Herbaceous Structure Trigger Points 2-22 

Table 2-7 Green Ash Woody Draw Trigger Points 2-23 

Table 2-8 Summary of how the Alternatives respond to the Purpose and Need. 2-24 

Table 2-9 Key Issue Comparison of the Alternatives 2-25 

Table 2-10 Authorized Use relative Comparison Table 2-27 

Table 3-1 Past, present and reasonably foreseeable future actions 3-7 

Table 3-2 Comparison of relative authorized use and percentages 3-52 

Table 3-3 PFC Functionality Ratings and Definitions 3-56 

Table 3-4 Riparian functionality ratings for North Billings 3-57 

Table 3-5 Riparian functionality ratings for streams 3-71 

Table 3-6 Comparative table of preference, current and proposed authorized use 3-75 

Table 3-7 Distribution of woody draw condition ratings 3-91 

Table 3-8 Characteristics of tree, shrub and grass cover among Healthy, At Risk and Unhealthy 3-93 

Table 3-9 Tree density per acre by dbh size class among Healthy, At Risk and Unhealthy 3-93 

Table 3-10 Percentage of sampled woody draws by health ratings 3-94 

Table 3-11 Likely affect of Alternative 3 on woody draws by allotment 3-110 

Table 3-12 Likely affect of Alternative 4 on woody draws by allotment 3-124 

Table 3-13 Distribution of allotments in relation to Grasslands Plan structure objectives 3-134 

Table 3-14 Comparison of transect and station averages for 2004 and 2005 3-136 

Table 3-15 Grasslands Plan structure objectives for Rolling Prairie GA 3-137 

Table 3-16 Seral stage percentages by methodology 3-144 

Table 3-17 Results of State and Transition Model on sere plot data 3-145 

Table 3-18 2004 and 2005 transect and station herbaceous structure distribution 3-153 

Table 3-19 2004 structure distribution within one mile of leks within the project area 3-154 

Table 3-20 Population, economic and geographic overview 3-163 

Table 3-21 Summary of occupations in North Dakota and Billings Co. 2000 3-164 

Table 3-22 Summary of Industries in ND and Billings Co. 2000 3-164 

Table 3-23 Annual part and full time employment contribution from N. Billings allotments 3-166 

Table 3-24 Annual labor income contribution from the N. Billings allotments 3-166 

Table 3-25 Average annual receipts and payments returned to project area county 3-167 

Table 3-26 Proposed authorized federal animal months 3-170 

Table 3-27 Annual part and full time employment contributions from N Billings allotments alt 3 3-172 

Table 3-28 Economic impacts of alt. 3 3-173 

Table 3-29 Annual part and full time employment contributions and impacts from alt 4 3-175 

Table 3-30 Annual part and full time employment and labor income 3-176 

Table 3-31 Affects of Alternative 4 on grazing fee collections 3-176 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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SUMMARY OF THE DRAFT 

ENVIRONMENTAL IMPACT STATEMENT 

Introduction 

The USDA Forest Service (FS) proposes to continue to permit livestock grazing on 43 

allotments in a manner that maintains, and/or moves resource conditions toward meeting 

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

The North Billings County Allotment Management Plan Revisions project area is located 

on the Medora Ranger District, which is part of the Dakota Prairie Grasslands (DPG). 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. 

There are 43 active livestock grazing allotments covered under this analysis. These 

allotments cover approximately 87,262 acres of National Forest System (NFS) land with 

approximately 70,871 of those acres being capable of sustaining grazing, as determined 

by the 2001 Northern Great Plains Final Environmental Impact Statement (FEIS). The 43 

allotments are all under permit via their Grazing Agreement to the Medora Grazing 

Association (MGA). The MGA subsequently issues grazing permits to their members 

associated with the allotments in this analysis. 

When scoped this project proposal contained 46 grazing allotments. Since that time three 

allotments, i.e., 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. 

This Draft Environmental Impact Statement (DEIS) focuses on NFS lands administered 

by the Medora Ranger District. It does not evaluate livestock grazing activities on private 

and State lands contained in the allotments. 

Scoping revealed confusion about the purpose of this EIS. The EIS will analyze different 

alternatives created to meet the purpose and need, which is to permit livestock grazing in 

a manner that maintains, and/or moves resource conditions towards meeting Grasslands 

Plan objectives. Once the National Environmental Policy Act (NEPA) process is 

completed and a Record of Decision (ROD) issued, information from the 

Final Environmental Impact Statement (FEIS) will be used in the writing of the 

Allotment Management Plans (AMPs) for each allotment contained in this analysis. This 

EIS does not analyze the specific AMPs, rather, the AMPs will be developed from 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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information contained in the selected alternative. The selected alternative is identified in 

the ROD which will accompany the Final EIS for this project. 

Purpose and Need 

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

allotment conditions and management practices. 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 National Environmental Policy 

Act (NEPA) analysis prior to revision of existing allotment management plans. The 

underlying needs for this proposal include: 

3⁄4 Where consistent with other multiple use goals and objectives, there is Congressional 

intent to allow grazing on suitable lands. (Multiple Use Sustained Yield Act of 1960, 

Wilderness Act of 1964, Forest and Rangeland Renewable Resources Planning Act of 

1974, Federal Land Policy and Management Act of 1976, National Forest 

Management Act of 1976). 

It is Forest Service policy to make forage available to qualified livestock operators 

from lands suitable for grazing consistent with land management plans (FSM 

2203.1(6)). 

3⁄4 There is a need for continued livestock grazing to support local families and 

communities. Local ranch families depend on forage on these NFS lands to augment 

their own lands and raise livestock to provide an income for their families. Much of 

their income is spent locally and contributes to the general economic well-being of the 

community. 

3⁄4 Some resources are not at Desired Future Condition (DFC) as identified by the 

Grasslands Plan. There is a need to meet or move toward DFC for those affected 

resources in accordance with Grasslands Plan direction (pp 1-2, 1-3). 

3⁄4 There is an overall need 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; to be 

responsive to permittee requests for reasonable operational adjustments; and 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 the Allotment Summary 

Sheets located in Appendix A. Table S.1 below reveals which resources are of concern to 

this analysis. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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Table S.1 - Grasslands Plan Desired Conditions, Existing Conditions, and Need for 

Action. 

Grasslands Plan 

Desired Condition 

Existing Condition Need for Action 

-------------- Herbaceous Structure ------------ 

Maintain a mosaic of herbaceous 

structure across the landscape. 

Desired structure objectives are 

10-20 percent in low, 50-70 

percent in moderate, and 20-30 

percent in high structure. 

Structure is expressed in terms of 

Visual Obstruction Reading 

(VOR), which is obtained 

through use of the Robel pole 

survey method. VORs range from 

Low (less than 1.5 inches), 

Moderate (1.5 to 3.5 inches), and 

High (greater then 3.5 inches). 

(Grasslands Plan, pp. 2-13, 2-21). 

Generally desired high and low 

structure objectives are not being 

met. Survey data from 1996 to 

2005 show high structure ranging 

from 1 to 20 percent, moderate 

structure ranged from 56 to 71, 

and low structure ranged from 23 

to 53 percent. 

 

There is a need to create an 

upward trend in the amount of 

high structure and decrease the 

amount of low structure across 

the project area. 

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

Western North Dakota is 

classified as a semiarid region, 

water and riparian areas are 

important resources. The 

Grasslands Plan (pp. 1-2, 2-10, 2-

18), identifies that streams are to 

meet or move toward Proper 

Functioning Condition (PFC) on 

at least 80 percent of perennial 

streams. 

Within the analysis area 

approximately 54 miles of 

streams have been surveyed using 

the PFC methodology to 

determine the condition of the 

streams. Of the streams surveyed, 

26.7 miles (49.4%) were properly 

functioning, 2.5 miles (4.7%) 

were functioning at risk with an 

upward trend, 2.2 miles (4%) 

were functioning at risk no trend 

apparent, 2.9 miles (5.4%) were 

functioning at risk showing a 

downward trend, and 19.7 miles 

(36.5%) were non functional. 

There is a need to start an upward 

trend for the functioning at risk 

and nonfunctional streams. 

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

Trees cover about ten 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 

hardwood draws is that they be 

managed to maintain or develop a 

multi-layer and multi-age class of 

herbaceous plants, shrubs, and 

trees (Grasslands Plan, pp. 2-10, 

2-17). 

Wooded draw surveys, across the 

analysis area, show that 

approximately 52 percent are in 

healthy condition, 40 percent are 

at risk and 8 percent are 

unhealthy. Lack of or low tree 

regeneration and/or saplings and 

heavily impacted or absent shrub 

layers are the primary factors 

affecting woodland health. 

There is a need to create an 

upward trend in tree regeneration 

and sapling survival and improve 

shrub regeneration and survival. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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------------- Herbaceous Seral Stage ---------- 

The Grasslands Plan (pp.2-11, 2-

19) identifies a set of seral stage 

objectives. Seral stages are the 

successional stages a plant 

community progresses through 

and range from early pioneer 

vegetation to late seral, which is 

climax vegetation. Seral 

objectives are 10-15 percent in 

early, 65-75 percent in mid, and 

15-20 percent in late. 

Surveys completed across the 

project area indicate that seral 

stage objectives are near 

Grassland Plan objectives. 

The surveys also revealed an 

apparent trend of increasing 

invasive grasses, which if 

continued would adversely affect 

seral stage distribution. There is a 

need to look at ways to 

reduce/manage invasive grasses. 

Decision Framework 

The District Ranger 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 may select any of the 

alternatives or create a new alternative from the existing alternatives. He 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 on this project proposal, then AMPs will be 

written based on the alternative selected in the NEPA Decision. The AMP is the 

implementation document by which the Forest Service communicates to the permittee 

and others the management objectives and planned actions to accomplish those 

objectives. 

This draft environmental impact statement (DEIS) is not a decision document. Rather it 

discloses the environmental consequences of implementing the proposed action and 

alternatives to that action. After completion of this DEIS, there will be a 45-day public 

comment period. Based on the information in this analysis and a consideration of public 

comments on the DEIS, the Medora District Ranger will select the alternative to be 

implemented and document his reasoning in a Record of Decision (ROD) and publish a 

Final EIS (FEIS). 

This EIS focuses on National Forest System lands, within the project area, administered 

by the Medora Ranger District. It does not evaluate livestock grazing activities on other 

allotments, other Ranger Districts, or other Grasslands. 

Public Involvement 

A scoping letter was sent to 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 County 

Allotment Management Plan Revisions Project was published in the Federal Register on 

May 15, 2008. In addition, as part of the public involvement process, the Forest Service 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

xiii 

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, the Dakota Prairie Grasslands newspaper of record, Dickinson Press, 

the Bowman County Pioneer, New England 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 Schedule of Proposed Actions 

(SOPA). Ten comments on the proposed action were received. Individual meeting were 

also help with the Medora Grazing Association and each of the grazing permittees as part 

of developing Alternative 3. 

Issues 

Comments from the public, other agencies, and the Forest Service were used to formulate 

issues concerning the proposed action. The IDT identified the following as key issues the 

District Ranger concurred and directed that these should be carried through the analysis. 

Key issues were defined as those directly or indirectly related to implementing the 

proposed action which should be resolved by the alternatives. 

Key Issue #1. Herbaceous structure –The Grasslands Plan, in Chapter 2, identifies a set 

of desired herbaceous structure objectives. Herbaceous structure refers to the height, 

density, and litter cover of grasses and forbs. The objectives are expressed in terms of a 

Visual Obstruction Reading (VOR). Low structure is grass and forb vegetation that has a 

VOR reading of 0 to 1.49 inches, moderate is 1.5 to 3.5 inches, and high is greater than 

3.5 inches. The Grasslands Plan identifies the desired condition for herbaceous structure 

as 10-20 percent in low, 50-70 percent in moderate, and 20-30 percent in high structure 

(Grasslands Plan, Ch.2, pp. 2-13, 2-19). 

Visual Obstruction Reading surveys conducted periodically from 1996 to 2005 show high 

structure ranging from 1 to 20 percent, moderate structure 55 to 71 percent, and low 24 to 

52 percent. Surveys were conducted on “biologically capable” lands within the project 

area. Biologically capable refers to lands that have or are able to sustain plant 

communities that are capable of producing high structure. The survey information 

indicates that across the project area we are exceeding the low structure objective, 

meeting the moderate structure objective, and are below the high structure objective. 

Livestock grazing is believed to be a contributing factor. 

Key Issue #2. Riparian areas - Perennial and major intermittent streams on National 

Forest System lands, in the project area, were surveyed 1997 through 1999, 2004, 2006, 

and 2007 using the Proper Functioning Condition (PFC) protocol (Pritchard et. al., 1998). 

Perennial streams flow continuously year around, intermittent streams flow only at 

certain times of the year when they receive water from springs or from surface sources 

such as snow or rain runoff. No ephemeral streams were surveyed. 

A total of approximately 54 miles on 11 streams were surveyed. Of the surveyed streams 

28.1 miles (49.4%) were Properly Functioning, 2.5 miles (4.7%) were Functioning-at-
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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Risk-Upward Trend, 2.2 miles (3.4%) were Functioning-at-Risk-Trend Not Apparent, 2.9 

miles (5.4%) were Functioning-at-Risk-Downward Trend, and 19.7 miles (36.5%) were 

Nonfunctioning. 

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. Functioning-at-Risk means that riparian areas 

are in a functional condition but one or more properties, i.e., soil, water, or vegetation are 

impaired which makes the riparian area susceptible to degradation. Nonfunctioning 

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. 

At risk and nonfunctional streams exhibit an inadequate amount of residual vegetation to 

trap sediments from fall/spring runoff or to control erosive energy in the channel. They 

are affected by excessive bank trampling, lack of desired riparian plant communities, and 

display poor channel morphology (structure). The Grasslands Plan identifies a goal of 

meeting or moving towards PFC on at least 80 percent of perennial streams (Grasslands 

Plan Ch. 1, p. 1-2). Some causes of stream degradation include livestock grazing and road 

impacts. 

Key Issue 3. Green Ash woody draws - There are several different types of woody draws 

in the project area including juniper, aspen, cottonwood and green ash hardwood draws. 

Most of the woody draws are in good condition, however, there is a concern with the 

green ash draws. 

Green ash woody draws were surveyed in 1998 and 1999, 2005, 2006, and 2007. They 

were rated as Healthy, At Risk or Unhealthy. Of the green ash woody draws that were 

surveyed, 52 percent were Healthy, 40 percent were At Risk and about 8 percent were 

Unhealthy. It is recognized that there are some natural forces, such as, late frosts and lack 

of wildfire, both of which affect woodlands, however, livestock grazing appears to be the 

primary force affecting the health of the green ash woody draws. 

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 (Grasslands Plan, Ch 1, p.1-2,1-13;.Ch 2, p. 2-10) 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 and exhibit 

inconsistent or patchy shrub diversity and structural complexity. Unhealthy woody draws 

are generally characterized by old or decadent tree layers, a lack of younger tree age 

classes and little or no tree regeneration. The understory is dominated by herbaceous 

vegetation instead of a diverse shrub layer. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

xv 

Grasslands-wide Direction is to move to at least 80 percent of riparian areas and woody 

draws 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 4. Seral Stage (Plant composition) - Seral stage/plant composition refers to the 

floristic composition of grass and grass-like life forms. The Grasslands Plan uses seral 

stages to identify desired condition for plant composition. 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. The 

Grasslands Plan objectives for sere are 10-15 percent early, 65-75 percent mid, and 15-20 

percent in late seral stage. Surveys of seral stage/plant composition across the project area 

indicate that seral stage objectives are near to the Grasslands Plan seral stage objectives, 

however, the analysis revealed an apparent trend of increasing invasive grasses, which, if 

continued, would adversely affect seral stage distribution. 

Key Issue 5. Drought - A major factor affecting structure, forage availability, and other 

resources across the landscape is drought. Reece et.al. (1991) state that drought is 

generally defined as a prolonged period during which annual precipitation is less than 75 

percent of average. Based on this definition, drought has occurred in 21 percent of the 

years in the northern Great Plains, since 1940 (Holecheck et.al. 1989). While livestock 

grazing is adjusted annually, according to weather patterns, specific drought management 

guidelines are not currently in place on the Dakota Prairie Grasslands. 

Key Issue 6. Economics – Essentially any changes over the current grazing situation 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 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 different alternatives on jobs and income within an identified 

economic impact area of associated counties. 

Alternatives 

Alternative 1 

The Council for Environmental Quality (CEQ) regulations for implementing the National 

Environmental Policy Act (NEPA) requires 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 no permitted livestock grazing (USDA 

Forest Service 1996; Forest Service Handbook [FSH] 2209.13). 

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 

grazing permitted livestock in the analysis area. Pursuant to Forest Service Handbook 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

xvi 

(FSH) 2209.13, Section 16.24, this alternative could not be implemented until two years 

after the notification of each affected permittee (36CFR 222.4(4)(1)). No permits would 

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

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

draw, herbaceous structure or composition would be completed. However, restoration 

projects could be planned and implemented but that 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. All fences, except Forest boundary fences or allotment 

boundary fences adjacent to other active grazing allotments, and any water developments 

not needed for wildlife or other purposes, would be removed. 

Treatment strategies for noxious weeds would be in compliance with direction outlined in 

the March 2007 Noxious Weed Management Project FEIS for the Dakota Prairie 

Grasslands. 

Alternative 2 

Allotment Management Plans (AMPs) would be developed for the 43 allotments in the 

project area. Current management for each allotment is identified in Appendix C. There 

would be no changes in authorized use numbers of livestock, permitted season of use, 

kind or class of livestock, or grazing system (other than minor changes made, by 

exception, in the Annual Operating Instructions (AOI). 

Alternative 3 

Alternative 3 (Proposed Action ) was developed in conjunction with the Medora Grazing 

Association (MGA) and the individual permittees associated with the allotments in the 

project area. This is consistent with the September 2006, Livestock Grazing Record of 

Decision (ROD) for the Dakota Prairie Grasslands Plan and provisions of the 

“Demonstration Project” contained within the ROD. 

Alternative 3 is an adaptive management based alternative. As identified in Chapter 1, 

Adaptive Management is: the process of making use of monitoring information to 

determine if management changes are needed, and if so, what changes, and to what 

degree. The goal of this alternative is to achieve site-specific desired resource conditions 

in accordance with the Grasslands Plan resource direction. Appendix A contains a set of 

Allotment Summary Sheets, one for each allotment in this analysis. The summary sheets 

identify resource issues, the existing condition of that resource on the allotment and a 

need for action if the resource is not meeting Grasslands Plan resource direction. Also 

contained on the summary sheets is a set of initial actions and adaptive options developed 

to address identified resource concerns. Taken together, the initial actions and adaptive 

options create the proposed action for that individual allotment. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

xvii 

A key component of this alternative is monitoring, as it is the driving factor which 

determines if management actions are accomplishing their intended resource goals. The 

starting point for each allotment is identified as “Initial Actions” on the Allotment 

Summary Sheets. If monitoring indicates that the initial actions are not meeting or 

moving a resource towards desired condition, then adaptive options contained in the 

Allotment Summary Sheets or the Management Tool Box (Appendix D) become 

available for use. The decision to implement management changes would be the 

responsibility of the District Ranger. Monitoring is discussed in detail later in Chapter 2 

The type, frequency, and duration of monitoring on each allotment is identified in the 

Allotment Summary Sheets. 

If for some reason initial or adaptive management action(s) identified in the Allotment 

Summary Sheets cannot be implemented as planned, then an team comprised of different 

specialists, the affected permittee, and affected Grazing Director, would recommend to 

the District Ranger a possible course of action based on the Grazing Management 

Toolbox. For example, allotment A contains an initial or adaptive 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, for economic reasons it becomes 

unfeasible to develop the well and facilities in the reasonably foreseeable future. 

However, 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 (Table S.2) 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. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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Table S.2 Grazing Management Toolbox. 

Implement Dakota Prairie Grasslands drought management strategy 

Adjust season of use 

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

Adjust AUMs based on average cow size 

Utilize non-native grass pastures early to defer grazing on native grasses 

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

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

species 

Rest for one or more seasons 

Reallocation of pastures (change allotment boundary) 

Construct temporary fence to control livestock distribution patterns 

Construct and/or remove cross fences 

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

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

Manage water availability/access at water developments 

Maintain existing developments to reestablish use 

Implement deferred grazing system 

Implement rest-rotation grazing system 

Implement twice-over grazing system 

Incorporate private “off permit” land into rotation 

Fertilize crested wheatgrass areas 

Hay or cut-&-leave crested wheatgrass areas 

Interseed pasture with native grass species 

Scarify clubmoss areas within a pasture 

Implement prescribed burns 

Mechanical brush management 

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

Manage salt and supplement locations 

Construct fence to create riparian unit – allow grazing under riparian grazing dates 

Implement BMPs for riparian pastures 

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

Construct/harden stream crossings 

Construct water gap to limit livestock access on stream 

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

etc.) 

Move winter feeding areas off of National Forest System lands 

Utilize biological controls for noxious weed control in woody draws 

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 to the extent 

that their implementation is consistent with the effects documented in this EIS and its 

accompanying Record of Decision. Grasslands Plan standards and guidelines, the 

Watershed Conservation Practices Handbook (FSH 2509.25), and Project Design Criteria 

are incorporated by reference. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

xix 

Alternative 4 

Alternative 4 is an adaptive management alternative that is similar to Alternative 3 in 

some respects. The ID team reviewed the initial and adaptive actions identified in 

Alternative 3 and 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. This alternative also establishes 

authorized use based on estimated livestock carrying capacities and accounts for changes 

in animal unit forage demands with changes in cow/calf size, i.e., animal weight. The 

Allotment Summary Sheets located in Appendix A identify 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. 

Design Criteria Common to All Alternatives 

Design criteria (Table S.3) are actions designed into the action alternatives 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 S.3 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. 

o On inventory permits, early turnout on native pastures is allowed one out 

of three 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. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

xx 

• For allotments requiring a AM/AUM reduction: 

3⁄4 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 needed. 

3⁄4 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. 

3⁄4 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. 

• If stocking rate adjustment are needed, annual reductions will generally not exceed 

ten percent. 

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

• When drought conditions occur the Dakota Prairie Grasslands, 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. 

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 utilizing native 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. 

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

following growing season to ensure regrowth of forage species. 

• 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. 

Often in Allotment Management Planning analysis, a common question asked is how 

many cows would be permitted by alternative or what would the difference be in how 

many cows 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 alternative. The table below shows the AUMs by action 

alternative, which specialists used as a way to compare between alternatives and their 

effects in Chapter 3. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

xxi 

Under Alternatives 2 and 3 authorized use is expressed in terms of AMs, however, 

Alternative 4 authorized use is expressed in terms of AUMs. For comparison purposes in 

the table below the AMs under Alternatives 2 and 3 were converted from AMs to AUMs 

by multiplying the authorized use AM number (i.e. Preference Number) by 1.15 (see 

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

within the range of 1,100-1,300 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 

again this is done for comparison purposes. Allotments 132A and 248 are expressed in 

AMs under Alternative 4 because they were meeting resource objectives and no 

adjustment to their proposed authorized use was needed. 

Alternative 3 and 4 are adaptive 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 AM/AUMs is 

one of the tools in the tool box that can be used. 

Table S.4 Authorized Use relative comparison table 

NOTE DISCLAIMERS ABOVE.

Allot # Alternative 1 Alternatives 2 and 3 Alternative 4 

 AMs *AUMs AUMs 

126/128 0 2355 2708 1929 

127 0 412 474 384 

129 0 1090 1254 1090 

130 0 833 958 833 

131 0 273 314 273 

132A 0 176 202 176 AMs – Meeting Obj. 

132H 0 332 382 332 

133 0 272 313 196 

133D5 0 (Hay) 49 (Hay) 56 (Hay) 35 

134 0 254 292 220 

135 0 1559 1793 1559 

136/139 0 362 416 252 

140 0 281 323 232 

141 0 177 204 113 

142 0 167 192 106 

158 0 1566 1801 1347 

220 0 160 184 112 

221 0 246 283 174 

230 0 364 419 333 

237 0 288 331 236 

239 0 250 288 176 

240 0 809 930 809 

241 0 359 413 358 

243 0 375 431 347 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

xxii 

244 0 236 271 236 

248 0 312 359 312 AMs – Meeting Obj. 

249 0 204 235 181 

256 0 1591 1830 1509 

258 0 2071 2382 1529 

272 0 1473 1694 1472 

277 0 1129 1298 1129 

278 0 272 313 230 

281 0 295 339 272 

282 0 2123 2441 2123 

283 0 300 345 300 

286 0 278 320 237 

287 0 579 666 513 

288 0 268 308 192 

289 0 1789 2057 1789 

300 0 486 559 486 

301 0 1666 1916 1509 

302 0 1044 1201 1027 

* Alternative 2 and 3 authorized AM use converted to AUMs. 

Summary Comparison of Alternatives 

Table S.5 summarizes the response of each alternative to the Purpose and Need for this 

project. 

Key issues and their indicator(s) by Alternative are shown in Table S.6. Key issues were 

previously listed in this chapter. 

Table S.5 summary of how the Alternative respond to the Purpose and Need. 

Purpose and Need Alternative 

1 

Alternative 2 *Alternative 3 *Alternative 4 

Allow grazing and 

provide forage 

No Yes Yes Yes 

Support ranching 

community 

No Yes Yes Yes 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

xxiii 

Purpose and Need Alternative 

1 

Alternative 2 *Alternative 3 *Alternative 4 

Meet or rmove 

towards DFC for 

resources 

Resources 

would meet 

or show 

significant 

progress 

towards 

DFC in 10-

15 year time 

frame of this 

project. 

Herbaceous 

structure 

objectives, 

woody draw 

health, and 

riparian 

condition are 

expected to 

remain below 

Grasslands 

objectives for 

these 

respective 

resources . 

Herbaceous structure may see 

reduction in amount of low 

structure with a slight shift 

towards moderate, no gain 

expected in high structure. 

Woody draws would see 

varying degrees of 

improvement in about 44 

percent of the At-Risk and 

Unhealthy. Riparian condition 

would improve in some 

allotments 

General concern that 

continuing existing levels of 

authorized use will negate the 

effects of proposed initial 

actions with some exceptions 

such as a riparian exclosures. 

Herbaceous 

structure 

movement would 

be into both 

moderate and high 

classes, although to 

what degree is 

unknown. Woody 

draws would see 

varying degrees of 

improvement in 84 

percent of At-Risk 

and Unhealthy 

woody draws. 

Riparian would see 

improvement in a 

greater amount of 

allotments. 

Concern that 

setting authorizing 

at carrying 

capacity in some 

allotments may 

need further 

adjustment. 

Provide for 

management 

flexibility i.e 

Adaptive 

Management 

No No Yes Yes 

*Both alternatives 3 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 between the two alternatives 

when considering the adaptive management portion of the alternatives is time. 

Alternative 4 takes more aggressive steps to address resource concerns than does 

Alternative 3. If under Alternative 3 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. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

xxiv 

Table S.6 Comparison of alternative by key issue. 

Table S.5 Key Issue Comparison of the Alternatives. 

Alternatives. 

Key Issue Indicator(s) 1 2 3 4 

Herbacious 

Structure 

Percentage 

of structure 

in low, 

medium and 

high 

categories 

Would see 

increase in high 

structure and 

decrease in low 

structure. At 

some point in 

time system 

may become 

stagnated due 

to lack of 

herbivory 

Approx 19 

percent of 

allotments are 

meeting structure 

objectives. 

Remaining 

allotments 

typically are 

exceeding low 

structure, are 

meeting moderate 

structure but are 

not meeting high 

structure 

objectives.

In general the initial 

management actions 

under this alternative may 

move some structure from 

low to moderate, with 

little or no increase in 

high structure. However, 

several allotments that are 

close to meeting 

objectives may do so 

under this alternative. The 

remaining allotments not 

meeting objectives are not 

likely to achieve 

appreciable progress 

towards high structure 

objectives Adaptive 

actions over time would 

likely meet or move 

towards high structure 

objectives, however 

achieving appreciable 

progress for all below 

objective allotments 

within the timeframe of 

project is unlikely. 

In general the 

initial 

management 

actions under this 

alternative would 

likely move low 

structure into 

moderate and 

increase the 

amount of high 

structure. The 

percentage of 

movement into 

the moderate and 

high categories is 

unknown. 

Adaptive actions 

over time would 

likely provide a 

better opportunity 

then Alternative 3 

to achieve 

structure 

objectives within 

the timeframe of 

this project. 

Woody 

Draws 

Woody draw 

condition 

class: 

Healthy, AtRisk, 

Unhealth 

Some heavily 

impacted 

hardwood 

woody darws 

would likely 

leave 

landscape. 

Most would 

eventually 

recover to a 

Healthy 

condition 

class.. 

Of sampled 

stands 52 

percent were 

healthy, 40 

percent were at 

risk and 8 

percent were 

unhealthy. 

Of the 43 allotments, 5 

have no woody draws and 

6 are meeting objectives. 

Of the remaining draws 

14 are predicted to 

improve and 18 not 

improve. 

Of the 43 

allotments, 5 have 

no woody draws 

and 6 are meeting 

objectives. Of the 

remaining draws 

27 are predicted 

to improve and 5 

not improve. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

xxv 

Riparian Properly 

functioning 

condition 

(PFC) 

Some streams 

would continue 

to function 

below PFC due 

to effects of 

roading and 

road ditches. 

Streams 

affected 

primarily by 

livestock would 

recover 

Of 54 miles of 

stream survey on 

11 streams show 

that 49.4 percent 

were at PFC, 

4.7percent 

FARUT, 4 

percent 

FARTNA, 5.4 

percent FARDT, 

and 36.5 percent 

NF. 

Would see some shift 

towards PFC in some 

allotments, however, 

continued stocking at 

current levels may offset 

beneficial effects of 

proposed initial 

management actions. 

Initial actions plus 

authorized use 

adjustment set at 

carrying capacity 

provides best 

opportunity to 

start improving 

impaired stream 

segments toward 

PFC. 

 Seral 

stage 

Percentage of 

project area in 

low, mid, and 

late seral 

stages. 

Overall, the 

removal of 

livestock 

grazing would 

result in shift 

towards late 

seral stages and 

decrease in 

early seral 

stages. 

However, 

Invasive 

grasses would 

have potential 

to move 

distribution 

towards early 

seral stage. 

Seral stage 

objectives are 

near objectives, 

but at risk due to 

an apparent 

increasing trend 

of invasive 

grasses. If trend 

continues seral 

stage distribution 

will be adversely 

effected. 

Same as Alternative 2 Seral stages 

objective are at 

risk, however, 

stocking to 

carrying capacity 

would assist in 

slowing the 

apparent trend of 

increasing 

invasive grasses. 

Drought Precipitation No drought 

strategy needed 

No drought 

strategy in place. 

Would adapt 

DPG strategy 

when complete. 

Would use McKenzie 

strategy until DPG 

drought strategy 

completed 

Would use 

McKenzie 

strategy until 

DPG drought 

strategy 

completed 

Economics Jobs and 

Income 

Loss of 20 to 

39 jobs and 

$359,497 to 

$708, 453 in 

income. 

20 to 39 jobs and 

income of 

$359,497 to 

$708,453. 

Possible gain of two jobs 

and an additional $55,405 

in income over existing 

condition. 

Possible loss of 

two to six jobs 

and a loss of 

$17,213 to 

$87,702 in 

income over 

existing condition. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

xxvi 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

1-1 

CHAPTER 1 

Purpose of and Need for Action 

INTRODUCTION

Document Structure 

The Forest Service has prepared this Draft Environmental Impact Statement in compliance with 

the National Environmental Policy Act (NEPA) and other relevant Federal and State laws and 

regulations. This Environmental Impact Statement 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. 

Chapter 2. Alternatives, Including the Proposed Action: This chapter provides a more 

detailed description of the agency’s proposed action as well as alternative actions that were 

developed in response to comments raised by the public during scoping. This chapter also details 

how the Forest Service informed the public of the proposed action and how the public responded. 

Finally, this chapter provides a summary table of the environmental consequences associated 

with each alternative. 

Chapter 3. Affected Environment and Environmental Consequences: This chapter describes 

the environmental effects of implementing the proposed action and other alternatives. 

Chapter 4. Consultation and Coordination: This chapter provides a list of preparers and 

agencies consulted during the development of the Draft Environmental Impact Statement. 

 Index: The index provides page numbers by document topic. 

 Appendices: The appendices provide more detailed information to support the analyses 

presented in the environmental impact statement. 

Additional documentation, including more detailed analyses of project-area resources, may be 

found in the Project Record located at the Medora Ranger District. 

Note: Dakota Prairie Grasslands Land and Resource Management Plan (Grasslands Plan) 

references .i.e., page numbering) may or may not exactly conform to the CD version of the 

Grasslands Plan.
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

1-2 

Overview 

The USDA Forest Service (FS) proposes to continue to permit livestock grazing on 43 allotments 

in a manner that maintains, and/or moves resource conditions toward meeting the Grasslands Plan 

objectives and desired on-the-ground conditions. 

The North Billings County Allotment Management Plan Revisions project area is located on the 

Medora Ranger District, which is part of the Dakota Prairie National 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. 

There are 43 active livestock grazing allotments covered under this analysis (see Figure 1.2). 

These allotments cover approximately 87,262 acres of National Forest System land with 

approximately 70,871 of those acres being capable of sustaining grazing, as determined by the 

2001 Northern Great Plains Final Environmental Impact Statement (FEIS). The 43 allotments are 

all under permit via their Grazing Agreement to the Medora Grazing Association (MGA). The 

MGA subsequently issues grazing permits to their members associated with the allotments in this 

analysis. 

When scoped this project proposal contained 46 grazing allotments. Since that time three 

allotments, i.e., 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. 

This Draft Environmental Impact Statement (DEIS) focuses on National Forest System lands 

administered by the Medora Ranger District. It does not evaluate livestock grazing activities on 

private and State lands contained in the allotments. 

Scoping revealed confusion about the purpose of this EIS. The EIS will analyze different 

alternatives created to meet the purpose and need, which is to permit livestock grazing in a 

manner that maintains, and/or moves resource conditions towards meeting Grasslands Plan 

objectives and desired on-the-ground conditions. Once the National Environmental Policy Act 

(NEPA) process is completed and a Record of Decision (ROD) issued, information from the 

Final Environmental Impact Statement (FEIS) will be used in the writing of the Allotment 

Management Plans (AMPs) for each allotment contained in this analysis. This EIS does not 

analyze the specific AMPs, rather, the AMPs will be developed from information contained in 

the selected alternative. The selected alternative is identified in the ROD which will accompany 

the Final EIS for this project. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

1-3 

Creation of Little Missouri National Grassland 

The lands comprising the Little Missouri National Grassland (LMNG), which contains the 

Medora Ranger District, were formerly held mostly in the private sector. The following narrative 

briefly describes how livestock management on the LMNG became the responsibility of the 

USDA Forest Service. 

Livestock grazing has occurred on what is now the Little Missouri National Grassland since the 

last half of the 19th century when livestock was brought to the plains by ranchers and 

homesteaders in response to government programs, such as the 1862 Homestead Act. A 

combination of drought, the 1929 stock market crash, and national economic depression of the 

1930s led to hard times for many of the 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 

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. Under this act, lands purchased were to be 

managed for multiple uses. 

From 1938 to 1954, the Soil Conservation Service (SCS) administered the LUP. In 1954, the 

LUP was transferred to the U.S. Forest Service. On June 23, 1960, the USDA created nineteen 

national grasslands, from the LUP lands, the Little Missouri National Grassland (LMNG) is one 

of the created grasslands. In 1974, the Forest and Rangeland Renewable Resources Planning Act 

defined the national grasslands as part of the National Forest System. 

Grazing livestock on the LMNG has been a predominate use since the establishment of the 

LMNG in 1954. Many livestock operations in the area belong to multigenerational ranching 

families with strong ties to the land and their communities. 

Grasslands Plan Grazing Management History 

On July 31, 2002, Regional Forester Brad Powell signed the Record of Decision for the Dakota 

Prairie Grasslands (DPG) Final Environmental Impact Statement (FEIS) and Land and Resource 

Management Plan (Grasslands Plan). During the public comment periods for the Environmental 

Impact Statement, concerns were expressed that: 1) the grazing portion of the Grasslands Plan 

could not be implemented, and 2) if implemented, the Grasslands Plan would result in much 

higher reductions in livestock numbers than was predicted by the Forest Service. 

In order to address these concerns, Mr. Powell committed to paneling an independent group of 

scientists to review the parts of the Grasslands Plan related to livestock grazing. Mr. Powell 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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delayed making a decision on the livestock portion of the Grasslands Plan until the independent 

group of scientists completed its review. 

The resulting Scientific Review Team (SRT) consisted of eight members. Team members were 

selected based on recommendations of the North Dakota governor’s office, conservation and 

industry groups, state and federal natural resource agencies, and county representatives. 

SRT members conducted 14 meetings between February of 2003 and May of 2005. During these 

meetings, the Dakota Prairie Grasslands presented details on 69 Allotment Management Plans 

(AMPs). These were grouped into eight study areas. Presentations were supplemented with field 

trips to these study areas. Details on this process and the resulting reports can be found on-line 

at http://www.fs.fed.us/r1/dakotaprairie. 

The Forest Service, in their final report titled “Final Response to the Scientific Review Team 

Reports”, states that it’s the Forest Service’s intent to implement the SRT’s recommendations 

consistent with our final response. The report also noted, however, that as science and 

technology evolve, implementation of the recommendations may change over time to take 

advantage of new information. 

The Forest Service identified that SRT recommendations could be implemented in four ways: 1) 

change or reinforce local policy, protocols and agreements, 2) change or reinforce monitoring 

practices at the Grasslands Plan or the project level, 3) change the Grasslands Plan, or 4) change 

or reinforce analysis techniques and practices for on-the-ground implementation projects. None 

of the SRT recommendations, nor FS response, resulted in a need to change the Grasslands Plan. 

This is discussed in the September 2006 Record of Decision document. 

The completion of the SRT process allowed the DPG to complete the Livestock Grazing Record 

of Decision (ROD) in September of 2006. The signing of the ROD completed the “Planning 

Process” for the Grasslands Plan. This means that all decisions from that point forward must be 

consistent with the finalized Grasslands Plan. 

Despite the SRT process, controversy over the livestock grazing portion of the Grasslands Plan 

has continued. Due to the controversy and the national grassland mandate to demonstrate sound 

and practical principles of multiple use management that includes grassland agriculture, a 

“Demonstration Project” was authorized in the Grazing ROD. 

The Demonstration Project was developed as a vehicle to implement the livestock grazing 

portion of the Grassland Plan and develop integrated AMPs while meeting all applicable laws 

and regulations. 

The purpose of the Demonstration Project is to: 1) develop and implement integrated AMPs 

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. 
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In developing the integrated AMPs, 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 animal unit month (AUM) levels and providing sufficient habitat for 

grassland species. It is this balance of multiple uses that drives this analysis. 

Monitoring results from the selected alternative, other range projects, and Grasslands-wide 

monitoring will be used to determine if the Grasslands Plan Goals and Objectives related to 

grazing management are achievable or if amendments are needed. The monitoring data will also 

fulfill the third purpose of the Demonstration Project. 

The Demonstration Project is contained in the 2006 Livestock Grazing ROD which is located in 

the Project Record. 

Demonstration Project Implementation 

The Demonstration Project identifies that the Forest Service and affected grazing associations 

would work together to develop a proposed action for proposed range projects. This jointly 

created proposed action would then be carried forward in the NEPA process. 

This analysis was under way when the Grazing ROD was signed implementing the 

Demonstration Project. Previous to the signing of the ROD the district range staff had been 

meeting with individual permittees and their directors to review their individual allotments and 

discuss different management options that could be used to address resource concerns. The team 

had been pursuing the idea of adaptive management during these meetings and had been 

documenting this approach through the use of Allotment Summary Sheets. The sheets eventually 

became part of the proposed action for this project. 

In December of 2006, the District Ranger and members of the North Billings Range Project 

interdisciplinary team (IDT) met with the MGA Board of Directors. At the meeting, several IDT 

members presented information to the board about the recently signed Grazing ROD and the 

Demonstration Project. At this point the Forest Service hadn’t formally created the proposed 

action for the project but had been considering an adaptive management based proposed action. 

The IDT presented information about the concept of adaptive management to the board and 

proposed that it be carried forward as the basis of the proposed action for this project analysis. At 

the January 10, 2007 MGA meeting, the board identified that they were in agreement with 

pursuing an adaptive management based proposed action. 

At the March 5, 2008 MGA board meeting, members of the IDT met with the board to update 

them on the proposed action and inform them that the Forest Service was close to sending out a 

scoping letter on the proposed North Billings Range project. An example of what the proposed 

action would look like in the scoping letter was given to the board and discussed. The team again 

briefed the board on the adaptive management based proposed action, as the board president and 

some of the directors had changed. The Forest Service asked if the board still agreed with using 

the adaptive management proposed action. On April 3, 2008, the president of the MGA sent a 

short e-mail to the Medora Ranger District range staff saying the board still agreed with the 

adaptive management based proposed action. 
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Project Location 

The project area contains 43 livestock grazing allotments located approximately 13 miles 

northwest of Belfield, North Dakota. The project encompasses all or portions of NFS lands 

located in T144N, R99W, R100W, R101W, and R102W; T143N, R99W, R100W, R101W, 102, 

R103W; and T142N, R100W and, R101W (See Figure 1.1). 
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Figure 1.1 Project Area 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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Purpose and Need 

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

allotment conditions and management practices. 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 National Environmental Policy Act (NEPA) analysis 

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

include: 

3⁄4 Where consistent with other multiple use goals and objectives, there is Congressional intent 

to allow grazing on suitable lands. (Multiple Use Sustained Yield Act of 1960, Wilderness Act 

of 1964, Forest and Rangeland Renewable Resources Planning Act of 1974, Federal Land 

Policy and Management Act of 1976, National Forest Management Act of 1976). 

It is Forest Service policy to make forage available to qualified livestock operators from 

lands suitable for grazing consistent with land management plans (FSM 2203.1(6)).

3⁄4 There is a need for continued livestock grazing to support local families and communities. 

Local ranch families depend on forage on these NFS lands to augment their own lands and 

raise livestock to provide an income for their families. Much of their income is spent locally 

and contributes to the general economic well-being of the community. 

3⁄4 Some resources are not at Desired Future Condition (DFC) as identified by the Grasslands 

Plan. There is a need to meet or move toward DFC for those affected resources in accordance 

with Grasslands Plan direction (pp 1-2, 1-3). 

3⁄4 There is an overall need 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; to be responsive to permittee 

requests for reasonable operational adjustments; and 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 the Allotment Summary Sheets located in Appendix 

A. Table 1.1 below reveals which resources are of concern to this analysis. 
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Table 1.1 - Grasslands Plan Desired Conditions, Existing Conditions, and Need for Action. 

Grasslands Plan 

Desired Condition 

Existing Condition Need for Action 

-------------- Herbaceous Structure ------------ 

Maintain a mosaic of herbaceous 

structure across the landscape. 

Desired structure objectives are 10-

20 percent in low, 50-70 percent in 

moderate, and 20-30 percent in high 

structure. 

Structure is expressed in terms of 

Visual Obstruction Reading (VOR), 

which is obtained through use of the 

Robel pole survey method. VORs 

range from Low (less than 1.5 

inches), Moderate (1.5 to 3.5 

inches), and High (greater then 3.5 

inches). (Grasslands Plan, pp. 2-13, 

2-21). 

Generally desired high structure 

objectives are not being met and 

there is a surplus of low structure. 

Survey data from 1996 to 2005 show 

high structure ranging from 

1 to 20 percent, moderate structure 

ranged from 56 to 71, and low 

structure ranged from 23 to 53 

percent. 

 

There is a need to create an upward 

trend in the amount of high structure 

and decrease the amount of low 

structure across the project area. 

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

Western North Dakota is classified 

as a semiarid region, water and 

riparian areas are important 

resources. The Grasslands Plan (pp. 

1-2, 2-10, 2-18), identifies that 

streams are to meet or move toward 

Properly Functioning Condition 

(PFC) on at least 80 percent of 

perennial streams. 

Within the analysis area 

approximately 54 miles of streams 

have been surveyed using the PFC 

methodology to determine the 

condition of the streams. Of the 

streams surveyed, 26.7 miles 

(49.4%) were properly functioning, 

2.5 miles (4.7%) were functioning at 

risk with an upward trend, 2.2 miles 

(4%) were functioning at risk no 

trend apparent, 2.9 miles (5.4%) 

were functioning at risk showing a 

downward trend, and 19.7 miles 

(36.5%) were non functional. 

There is a need to start an upward 

trend for the functioning at risk and 

nonfunctional streams. 

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

Trees cover about ten 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 

hardwood draws is that they be 

managed to maintain or develop a 

multi-layer and multi-age class of 

herbaceous plants, shrubs, and trees 

(Grasslands Plan, pp. 2-10, 2-17). 

Wooded draw surveys, across the 

analysis area, show that 

approximately 52 percent are in 

healthy condition, 40 percent are at 

risk and 8 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 create an upward 

trend in tree and shrub regeneration 

and survival. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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------------- Herbaceous Seral Stage ---------- 

The Grasslands Plan (pp.2-11, 2-19) 

identifies a set of seral stage 

objectives. Seral stages are the 

successional stages a plant 

community progresses through and 

range from early pioneer vegetation 

to late seral, which is climax 

vegetation. Seral objectives are 10-

15 percent in early, 65-75 percent in 

mid, and 15-20 percent in late. 

Surveys completed across the project 

area indicate that seral stage 

objectives are near Grassland Plan 

objectives 

The surveys also revealed an 

apparent trend of increasing invasive 

grasses, which if continued would 

adversely affect seral stage 

distribution. There is a need to look 

at ways to reduce/manage invasive 

grasses. 

Proposed Action 

The action proposed for this project is to continue to permit livestock grazing by incorporating 

adaptive management strategies on the 43 allotments in the project area while meeting or moving 

towards Grasslands Plan desired conditions. The proposed action is designed to: 

3⁄4 Provide adaptive management flexibility to meet changing conditions. 

3⁄4Contribute to the general economic and social vitality of the local area. 

3⁄4Meet direction contained in the “Demonstration Project” including recommendations 

from the Final Response to the SRT Report. 

Table 1.2 identifies the grazing allotments associated with the proposed action. Figure 1.2 

displays the location of the allotments within the project area. 

Table 1.2- 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 

The proposed action was constructed using an adaptive management approach to resolve 

livestock-related resource issues. Adaptive management provides the responsible official with 

constrained flexibility to respond to changing conditions or issues without having to initiate a 

new NEPA process addressing those changes. A more detailed explanation of adaptive 

management is provided later in this chapter. The proposed actions for each allotment are 

documented in the Allotment Summary Sheets located in Appendix A. These sheets 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. The proposed action also includes a monitoring plan and adoption of the 

McKenzie Ranger District drought management strategy as identified for the NE McKenzie 

County Allotment Management Plan Revisions FEIS 2005. The proposed action, monitoring 

plan, and drought strategy are described in more detail in Chapter 2. 

Information from the Allotment Summary Sheets will be used in the development of new 

Allotment Management Plans (AMPs) for the 43 allotments in the project area. The individual 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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

the Record of Decision (ROD) for this proposal. 

Collectively the 43 allotments in this analysis contain approximately 87,262 acres of National 

Forest System (NFS) lands. There are private and state lands associated with many of the 

allotments. However, the proposed action deals only with NFS lands and discloses affects 

associated with only those lands. 
Draft Environmental Impact Statement North Billings County Allotmen

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Figure 1.2 - Grazing Allotment Locations
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Adaptive Management 

Two of the action alternatives contained in the analysis, Alternatives 3 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. 

A practical definition of Adaptive Management is: the process of implementing land 

management activities in incremental steps and evaluating[based on monitoring information] 

whether desired outcomes are being achieved at each step (Moir and Block 2001). It is a process 

that allows us to deal with uncertainty and changing conditions over time. It provides the 

responsible official with “constrained flexibility” to adapt to changing conditions or 

unanticipated resource response. Adaptive management is based on the assumption that current 

resources and scientific knowledge is 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. 

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 NEPA, 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 that the concept of adaptive management could be incorporated into the NEPA 

process. 

As previously identified the traditional approach to the NEPA process doesn’t provide the 

decision maker with much latitude to adjust actions once a decision has been made. For example, 

lets say on allotment X we decide to permit 203 cattle, cow/calf pairs, for a season of 6/3 to 9/14, 

under a three pasture deferred rotation grazing system. However, within a short time an 

opportunity or need is presented to: shorten the season, or to run a mix of cow/calf and yearlings, 

or to use some electric fencing to create a riparian pasture in a problem area – or, we find 

through our monitoring that something isn’t working or being implemented as we planned – or, 

the Forest Service receives new regulations, policies, etc. So, in a conceivably short timeframe, 

after the NEPA-based decision, something has changed which causes the responsible official to 

want, or need, to move in a direction different from that specified in the NEPA-based decision. 

This leaves the responsible official with the situation of either continuing existing management, 

knowing that it isn’t 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. 
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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’s 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 that it cannot be implemented as 

planned, then an interdisciplinary team would determine, from the NEPA document, those 

adaptive options that are available. The responsible official, working in conjunction with an 

interdisciplinary team and the permittee, would review the monitoring information and determine 

if a management change is needed and if so which adaptive action should be used. For this 

analysis the adaptive options are displayed in the Allotment Summary Sheets located in 

Appendix A and Appendix D (Tool Box). The adaptive actions are evaluated in Chapter 3 of this 

analysis. Figure 1.3 displays in graphic form how adaptive management works. 
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Figure 1.3 - An Illustration of the Adaptive Management Approach for the Action 

Alternatives

Describe the desired out-come, 

goals/objectives. 

Ex. 80 % of riparian areas are at 

Properly Functioning Condition 

(PFC).

Apply initial management 

actions (These are identified on 

the Allotment Summary 

Sheets). Ex. Modify rotation to 

minimize impacts to stream. 

Is the desired outcome being 

accomplished? 

Ex. 80% of streams are at or moving 

towards PFC. 

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 

YES

NO

Review available adaptive 

actions, select action(s) and 

implement. 

Ex. Create riparian pasture. 

NO

Review available adaptive 

actions, select action(s) and 

implement. Ex. Develop other 

water source(s) to pull livestock 

off of stream.
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Management Direction, Related Policies and Guidance 

Legal Framework 

The Forest and Rangeland Renewable Resources Planning Act of 1974, as amended, requires 

preparation of land and resource management plans for the National Forest System. The National 

Forest Management Act of 1976 regulations provide a process for developing, adopting and 

revising the plans. The Land and Resource Management Plan for the Dakota Prairie Grasslands 

revised in 2001 (USDA Forest Service 2001) and its accompanying 2002 and 2006 Records of 

Decision (ROD). The Land and Resource Management Plan for the Dakota Prairie Grasslands is 

hereafter referred to as the Grasslands Plan. 

The Grasslands Plan provides the framework to guide the day-to-day resource management on 

the Dakota Prairie Grasslands. Site-specific projects, including allotment management plans, 

must be consistent with the Grasslands Plan, unless the plan is modified by amendment. 

Grasslands Plan Direction 

The Grasslands Plan provides several levels of direction including grasslands-wide direction, 

geographic area direction, and management area direction. Chapters 1, 2, and 3 of the Grasslands 

Plan contain the grasslands-wide, geographic, and management area direction applicable to the 

North Billings County Allotment Management Plan Revisions. 

The project area is located in both the Badlands and Rolling Prairie geographic areas. 

Geographic areas include management direction that is too specific to apply across the entire 

Dakota Prairie Grasslands and is tailored to variables such as vegetation types, climate, and 

productivity of an area. Approximately 60,872 acres (70 percent) of the project area is in 

Badlands and 26,390 acres (30 percent) in Rolling Prairie geographic areas. 

The project area contains eight Management Areas (MAs), Figure 1.4 shows the management 

areas location within the project area. The Management Area (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 1.3. A description of each MA 

including the management emphasis as well as the direction that is specific to range resource 

management or livestock grazing also follows. 
Draft Environmental Impact Statement North Billings County 

1-17 

Figure 1.4 Management Areas Located in the Project Area. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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Table 1.3 - Management Area Acreage in the Project Area. 

Management Prescription Area Total Acres

1.31 7,155 

 2.1 240 

2.2 1,771 

 3.51a 2,929 

 3.51b 1,727 

 3.65 47,392 

 4.22 1,027 

 6.1 24,215 

 806 (Eberts Ranch Purchase – No 

 MA assigned as of yet) 

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. 

Range Resource Management: Refer to Chapter 1 (Grasslands-wide Direction), Section 

I, and Chapter 2 (Geographic Area Direction) for additional livestock grazing direction. 

Management Area 2.1: Special Interest Areas

Special Interest Areas (SIA) are managed to protect sites with important physical, 

biological, and/or cultural characteristics for the purpose of public use and enjoyment. 

Where applicable, areas are managed to maintain or enhance plant and wildlife 

population viability. 

Range Resource Management: Refer to Chapter 1 (Grasslands-wide Direction), Section I, 

and Chapter 2 (Geographic Area Direction) for additional livestock grazing direction. 

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 under an adaptive-management philosophy by serving as a 

“natural” reference for areas that are intensively managed for a particular objective. 

Range Resource Management: 1. Do not increase animal unit months (AUMs) or 

developments unless determined necessary in the Research Natural Area management 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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plan. Grazing suitability and desired vegetative conditions will be determined by the 

Research Natural Area management plan. Guideline 

 Refer to Chapter 1 (Grasslands-wide Direction), Section L, and Chapter 2 (Geographic 

Area Direction) for additional livestock management direction. 

Management Areas 3.51A: Bighorn Sheep & 3.51B: Bighorn Sheep Habitat With NonFederal 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 the non-federal mineral 

ownership. These areas would also possibly allow petroleum resource development on 

federal minerals once non-federal production has been established. 

Range Resource Management: 1. Do not convert existing livestock allotments to 

domestic sheep allotments in or adjoining this management area. Standard 

2. Limit livestock forage allocation based on bighorn sheep needs. Guideline 

3. Refer to Chapter 1 (Grasslands-wide Direction), Section L, and Chapter 2 (Geographic 

Area Direction) for additional livestock grazing direction. 

Management Area 3.65: Rangelands with Diverse Natural Appearing Landscapes 

This management area emphasizes maintaining or restoring a diversity of desired plants 

and 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. 

Refer to Chapter 1 (Grassland-wide Direction), Section L, and Chapter 2 (Geographic 

Area Direction) for additional livestock management direction. 

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. 

1. Use livestock grazing strategies that maintain or improve the vegetative composition 

and structure with the scenic qualities of the area. Guideline 

2. Range Resource Management: Refer to Chapter 1 (Grasslands-wide Direction), 

Section L, and Chapter 2 (Geographic Area Direction) for additional livestock 

management direction. 

Management Area 6.1: Rangeland With Broad Resource Emphasis 

This area is primarily a rangeland ecosystem 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 consider the range of natural variability. These lands often display high levels of 

development, commodity uses, and activity; density of facilities; and evidence of 

vegetative manipulation. Users expect to see other people and evidence of human 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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activities. Facilities supporting the various resource uses are common. Motorized 

transportation is common on designated roads and two-tracks. 

Range Resource Management: 

1. Design grazing practices to provide landscape diversity for plant composition and 

structure. Guideline 

2. Refer to Chapter 1 (Grasslands-wide Direction), Section L, and Chapter 2 (Geographic 

Area Direction) for additional livestock management direction. 

Additional direction, policy, and guidance are provided by the following sources: 

♦ Forest Service Manual (FSM) 2200, Range Management. 

♦ FSH 2209.13 Grazing Permit Administration Handbook; and FSH 2109.13 Pesticideuse Management and Coordination Handbook. 

Scope Of The Proposal 

Geographic Scope 

The Medora Ranger District has prepared this DEIS to document the analysis and disclose the 

environmental effects of alternative management actions in the designated “project area”. 

The project area encompasses 43 livestock grazing allotments. The allotments are made up of 

NFS, State, and private lands. However, this analysis deals only with the NFS lands in the 

allotments. 

The project area (See 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 being 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 Record of 

Decision (ROD) for this project. Information contained in the FEIS would be used to create new 

Allotment Management Plans (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 

There are state and private lands intermingled in NFS grazing allotments. The state and private 

landowners may elect to fence their property and manage it separately. For this reason the 

analysis only considered NFS lands. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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AMPs will be developed from information contained in the FEIS and will be based on the 

decision associated with this EIS. The AMPs guide livestock management within the allotments, 

with adaptive adjustments being implemented based on monitoring. 

Four alternatives were developed and analyzed in detail for this project. Alternatives 1 through 4 

are described in depth 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 EIS was developed under the implementing regulations of the National Environmental 

Policy Act (NEPA), Council on Environmental Quality, 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. This EIS is the final, site-specific NEPA 

documentation for the proposal, and is not a programmatic analysis. General management 

direction is found in the Dakota Prairie National Grasslands Land and Resource Management 

Plan. 

Decision Framework 

The District Ranger 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 may select any of the alternatives or create a new alternative 

from the existing alternatives. He 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 on this project proposal, then AMPs will be written based 

on the alternative selected in the NEPA Decision. The AMP is the implementation document by 

which the Forest Service communicates to the permittee and others the management objectives 

and planned actions to accomplish those objectives. 

This draft environmental impact statement (DEIS) is not a decision document. Rather it discloses 

the environmental consequences of implementing the proposed action and alternatives to that 

action. After completion of this DEIS, there will be a 45-day public comment period. Based on 

the information in this analysis and a consideration of public comments on the DEIS, the Medora 

District Ranger will select the alternative to be implemented and document his reasoning in a 

Record of Decision (ROD) and publish a FEIS. 

This EIS focuses on National Forest System lands, within the project area, administered by the 

Medora Ranger District. It does not evaluate livestock grazing activities on other allotments, 

other Ranger Districts, or other Grasslands. 
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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. Agencies are also directed to incorporate by 

reference, material that will help cut down the bulk of a document. All of the following 

documents supporting this analysis are located in the either the appendices or Project Record. 

The environmental analysis documented in this assessment is tiered to the 2002 Dakota Prairie 

Grasslands Revised Land and Resource Management Plan (Grasslands Plan), the 2006 

Rangeland Record of Decision, and the associated 2001 Final Environmental Impact Statement 

(FEIS) for the Northern Great Plains. The 2002 Grasslands Plan establishes the management 

direction for the DPG in compliance with the 1976 National Forest Management Act, the 1969 

National Environmental Policy Act (NEPA), and other laws and regulations. It also sets forth 

goals, objectives, standards and guidelines applicable to all resource management activities on 

the Dakota Prairie Grasslands. 
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CHAPTER 2 

ALTERNATIVES 

Introduction 

This chapter describes the four alternatives considered in this analysis. It describes the public 

involvement process used and the identification of key issues resulting from that process. The 

chapter 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. Issues considered but dropped from analysis are also identified. The chapter ends 

with a summary of the effects of implementing each alternative in relation to the purpose and 

need and the significant issues. 

Public Involvement 

A scoping letter was sent to 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 County Allotment Management 

Plan Revisions Project was published in the Federal Register on May 15, 2008. In addition, as 

part of the public involvement process, 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, the Dakota Prairie Grasslands 

newspaper of record, Dickinson Press, the Bowman County Pioneer, New England 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 Schedule of Proposed 

Actions (SOPA). Ten comments on the proposed action were received. 

Issues 

Comments from the public, other agencies, and the Forest Service were used to formulate issues 

concerning the proposed action. The IDT identified the following as key issues the District 

Ranger concurred and directed that these should be carried through the analysis. Key issues were 

defined as those directly or indirectly related to implementing the proposed action which should 

be resolved by the alternatives. 

Key Issue #1. Herbaceous structure –The Grasslands Plan, in Chapter 2, identifies a set of 

desired herbaceous structure objectives. Herbaceous structure refers to the height, density, and 

litter cover of grasses and forbs. The objectives are expressed in terms of a Visual Obstruction 

Reading (VOR). Low structure is grass and forb vegetation that has a VOR reading of 0 to 1.49 

inches, moderate is 1.5 to 3.5 inches, and high is greater than 3.5 inches. The Grasslands Plan 

identifies the desired condition for herbaceous structure as 10-20 percent in low, 50-70 percent in 

moderate, and 20-30 percent in high structure (Grasslands Plan, Ch.2, pp. 2-13, 2-19). 
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Visual Obstruction Reading surveys conducted periodically from 1996 to 2005 show high 

structure ranging from 1 to 20 percent, moderate structure 55 to 71 percent, and low 24 to 52 

percent. Surveys were conducted on “biologically capable” lands within the project area. 

Biologically capable refers to lands that have or are able to sustain plant communities that are 

capable of producing high structure. The survey information indicates that across the project 

area we are exceeding the low structure objective, meeting the moderate structure objective, and 

are below the high structure objective. Livestock grazing is believed to be a contributing factor. 

Key Issue #2. Riparian areas - Perennial and major intermittent streams on National Forest 

System lands, in the project area, were surveyed 1997 through 1999, 2004, 2006, and 2007 using 

the Proper Functioning Condition (PFC) protocol (Pritchard et. al., 1998). Perennial streams flow 

continuously year around, intermittent streams flow only at certain times of the year when they 

receive water from springs or from surface sources such as snow or rain runoff. No ephemeral 

streams were surveyed. 

A total of approximately 54 miles on 11 streams were surveyed. Of the surveyed streams 28.1 

miles (49.4%) were Properly Functioning, 2.5 miles (4.7%) were Functioning-at-Risk-Upward 

Trend, 2.2 miles (3.4%) were Functioning-at-Risk-Trend Not Apparent, 2.9 miles (5.4%) were 

Functioning-at-Risk-Downward Trend, and 19.7 miles (36.5%) were Nonfunctioning. 

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. Functioningat-Risk means that riparian areas are in a functional condition but one or more properties, i.e., 

soil, water, or vegetation are impaired which makes the riparian area susceptible to degradation. 

Nonfunctioning 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. 

At risk and nonfunctional streams exhibit an inadequate amount of residual vegetation to trap 

sediments from fall/spring runoff or to control erosive energy in the channel. They are affected 

by excessive bank trampling, lack of desired riparian plant communities, and display poor 

channel morphology (structure). The Grasslands Plan identifies a goal of meeting or moving 

towards PFC on at least 80 percent of perennial streams (Grasslands Plan Ch. 1, p. 1-2). Some 

causes of stream degradation include livestock grazing and road impacts. 

Key Issue 3. Green Ash woody draws - There are several different types of woody draws in the 

project area including juniper, aspen, cottonwood and green ash hardwood draws. Most of the 

woody draws are in good condition, however, there is a concern with the green ash draws. 

Green ash woody draws were surveyed in 1998 and 1999, 2005, 2006, and 2007. They were 

rated as Healthy, At Risk or Unhealthy. Of the green ash woody draws that were surveyed, 52 

percent were Healthy, 40 percent were At Risk and about 8 percent were Unhealthy. It is 
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recognized that there are some natural forces, such as, late frosts and lack of wildfire, both of 

which affect woodlands, however, livestock grazing appears to be the primary force affecting the 

health of the green ash woody draws. 

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 (Grasslands Plan, Ch 1, p.1-2,1-13;.Ch 2, p. 2-10) 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 and exhibit inconsistent or patchy shrub 

diversity and structural complexity. Unhealthy woody draws are generally characterized by old 

or decadent tree layers, a lack of younger tree age classes and little or no tree regeneration. The 

understory is dominated by herbaceous vegetation instead of a diverse shrub layer. 

Grasslands-wide Direction is to move to at least 80 percent of riparian areas and woody draws 

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 4. Seral Stage (Plant composition) - Seral stage/plant composition refers to the floristic 

composition of grass and grass-like life forms. The Grasslands Plan uses seral stages to identify 

desired condition for plant composition. 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. The Grasslands Plan objectives for seral are 10-

15 percent early, 65-75 percent mid, and 15-20 percent in late seral stage. Surveys of seral 

stage/plant composition across the project area indicate that seral stage objectives are near to the 

Grasslands Plan seral stage objectives, however, the analysis revealed an apparent trend of 

increasing invasive grasses, which, if continued, would adversely affect seral stage distribution. 

Key Issue 5. Drought - A major factor affecting structure, forage availability, and other resources 

across the landscape is drought. Reece et.al. (1991) state that drought is generally defined as a 

prolonged period during which annual precipitation is less than 75 percent of average. Based on 

this definition, drought has occurred in 21 percent of the years in the northern Great Plains, since 

1940 (Holecheck et.al. 1989). While livestock grazing is adjusted annually, according to weather 

patterns, specific drought management guidelines are not currently in place on the Dakota Prairie 

Grasslands. 

Key Issue 6. Economics – Essentially any changes over the current grazing situation 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 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 different alternatives on jobs 

and income within an identified economic impact area of associated counties. 
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Issues Dropped from Analysis 

This section identifies issues that were brought forth but dropped and discusses why they weren’t 

carried forward in the environmental analysis. This is in compliance with Council on 

Environmental Quality (CEO) direction. 

The Council on Environmental Quality 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 CFR 1502.2 (c) ). The Council 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 Council 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 is a summarization of information contained in the Archeological 

Report prepared by the Forest Service Zone Archeologist for the LMNG. The report is located in 

the Project Record. 

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 evidenced the entire span of human prehistoric and historic 

occupation in North Dakota over the last ca. 12,000 years. 

Cultural Sites 

To date, 840 projects have been conducted in the North Billings project area. A complete 

bibliography of the projects is included in the Archeological Report located in the Project 

Record. 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 37% of the total federal 

acres under study (149,140 acres). The inventories have resulted in the location and recording of 

a total of 304 cultural sites within the North Billings project area. The sites are listed in 

Appendix I, of the Archeological Report, by site number, site type, and eligibility. The site 

density is calculated at one 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, or 12%, are considered to be eligible for the National Register of Historic 

Places (NRHP), although none are listed on the National Register. An additional 80 sites, 26%, 

have been formally determined ineligible for the National Register. The remaining 187 sites, 

62%, 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. 
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Traditional Cultural Property 

A Traditional Cultural Property (TCP) is defined as one that is eligible for inclusion to 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 TCP’s are known to be present within the 

North Billings planning area. 

Grazing and Rangeland Management Effects 

A sampling of sites were monitored during the 1997-98 field seasons in an attempt to assess 

effects to 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. 

3⁄4Livestock 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 Milling/Trampling. 

3⁄4Range Improvements are projects constructed on the ground for the betterment 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. 

3⁄4Vehicular 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 trails have developed adjacent to the lines. 

Of the 304 sites within the project study area, 141 (46%) were within the 1998 monitor results. 

Of these, 109 (77% of the monitored sites), are within the actual 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 Project Record. 

Of the 109 sites being used for the effects analysis, 33 (30%) were noted to have some type of 

effects from cattle, range improvements, or vehicular use across the site 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, (70%) of the sites monitored. Of the 14 sites, 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 new management practices will help to alleviate adverse effects to 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 help to reduce the potential for erosion of cultural sites and loss of integrity in the 

pasture areas. 
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Under Alternatives 3 and 4, 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 Archeological Report that the 

implementation of new management plans for the allotments in the North Billings area will have 

no adverse effect to cultural resources. The State Historical Society of North Dakota, after 

review of the Archeological Report, stated that “We concur with a “No Adverse Effect” 

determination, and we concur with the proposed management recommendations as outlined in 

the conclusion”(NDSHPO, 2006). Therefore this issue is 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. 

Noxious weeds identified in the project area included leafy spurge, Canada thistle, burdock, 

black henbane, field bindweed, and absinth wormwood. The amount of 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 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). The 

ROD approves the use of the integrated adaptive approach to continue to treat existing and future 

infestations of noxious weeds. 

Threatened and Endangered Plant Species 

The Forest Service Botanist, in the Botany Report, has identified that there are no federally listed 

Threatened or Endangered (T&E) plant species, nor is there any designated critical habitat for 

T&E plant species on the Little Missouri National Grassland. There are no plant species 

proposed for federal listing nor is there any proposed critical habitat associated with the proposed 

project. The Botany Report is located in the Project Record. Therefore this issue was dropped 

from further consideration in this analysis. 
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Sensitive Plant Species 

There are three populations of known sensitive plant species in the project area, they are 

Hooker's townsendia (Townsendia hookeri), blue-eyed Mary (Collinsia parviflora), Dakota 

buckwheat (Eriogonum visheri). 

Hooker's townsendia population sites occur around the periphery of barren sediment exposures 

or ridge shoulders with relatively thin or less developed soil that support relatively sparse plant 

cover. 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. 

Two population sites of blue-eyed Mary (Collinsia parviflora) are also 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 is not having an obvious adverse 

affect on the populations. Current livestock disturbances may confer a benefit through grazing 

of Kentucky bluegrass, thus inhibiting the development of high herbaceous structure and litter 

accumulations that could overshadow and crowd the diminutive species. 

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, attesting to the beneficial affect of 

livestock enhancing microsites for establishment of this annual species. To a degree, depending 

on site characteristics, livestock trailing and grazing may also provide benefits of decreased 

competition with other species. 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. 
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The three sensitive plant populations known in the project area exhibit no or minimal impacts 

and/or beneficial impacts associated with grazing. The Forest Service Botanist (see Botany 

Report) has determined the proposed project would not affect the viability of existing sensitive 

plant populations. For these reasons, sensitive plants areas 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 known non-motorized Maah 

Daah Hey Trail passes through part of the project area. The area also contains the Ice Caves, a 

favorite dispersed recreation site, the Two Top Big Top Research Natural Area, and the Magpie 

and Blacktail Inventoried Roadless Areas. 

Environmental Effects 

Regardless of the amount of grazing activities in any of the action alternatives, effects to the 

recreation resource are about the same. 

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 fences prevent access to the campground at this time. In recent years, there has 

been no impacts from any grazing activity in any developed recreation area. None is expected 

under any alternative. 

Dispersed recreation includes the Maah Daah Hey Trail, outfitters, individual hunting and land 

uses such as road easements and utility corridors. All the allotments contain a variety of 

dispersed recreation activities. The Maah Daah Hey 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, 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 

concern for managers. Some users complain about cow manure on trails. 

Range permittees have also experienced problems from recreating publics that 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 season-long 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 to hunting opportunities for either 

individual hunters or outfitters are expected. None have been reported in the past. 

Winter activities in the project area are of a minimal nature and exist primarily of cross country 

snowmobiling when there is enough snow present to allow that activity. There may be some 
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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 permit. 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. Permittees, creating their own motorized 

trails in conjunction with administration of their permits, can inadvertently encourage 

unauthorized off-road motorized use. 

Summary 

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 and 3 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 permitted AUMs which may 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. Since there would be no increases in the numbers or 

seasons of grazing under any alternative, no cumulative effects are expected to recreation. 

Therefore this issue is dropped from further consideration in this analysis. 

Threatened and Endangered Wildlife Species. The following discussion on Threatened and Endangered wildlife species was taken from the 

Wildlife Biological Evaluation Report which is located in the Project Record. 

The list of federally listed species for the project area was obtained through the USFWS web site 

at: http://northdakotafieldoffice.fws.gov/county_list.htm. 

Whooping Crane (Grus americana; Endangered Species) 

The whooping crane may occur incidentally as a very rare spring and fall migrant within the 

analysis area. However, except for one spring migration stop at the South Unit of Theodore 

Roosevelt National Park in 2000 (Austin 2001), there are no documented stops for whooping 

cranes on the Medora Ranger District (MRD). While birds can show up in all parts of North 

Dakota, the vast majority of sightings occur along the Missouri River corridor. Whooping cranes 

foraging and roosting stops on or near the LMNG are very uncommon and considered incidental 

(App. H, USDA 2001). Migrating whooping cranes primarily use a variety of wetland habitats 

for roosting and feed in nearby grain fields. Whooping crane use within the MRD is so rare that 

it is not possible to quantify the amount of potential and suitable habitat, nor potential stop-over 

locations. 

None of the alternatives will disrupt migratory activities or habitat of whooping cranes. Given 

the lack of use of the LMNG by whooping cranes and lack of potential impacts from the 

alternatives, the Forest Service Wildlife Biologist has determined that there would be “no 

effects” for whooping cranes. 
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Black-footed Ferret (Mustela nigripes; Endangered Species) 

Prairie dogs and their colonies are critical habitat of the black-footed ferret. Prairie dogs are the 

ferret’s primary prey and their burrows provide denning locations. Black-footed ferrets do not 

currently occur within the LMNG (App. H, USDA 2001). There may be one small prairie dog 

colony, less than two acres in size, within the project area but there are no complexes identified 

within the project area. 

Under all alternatives, given the small number of prairie dog acres, habitat suitable for the blackfooted ferret is functionally not present within the project area; there are currently no ferrets on 

the LMNG; there is no designated ferret reintroduction area on the MRD; and there are no 

immediate plans to reintroduce ferrets into North Dakota at this time. The Forest Service 

Wildlife Biologist determined that there will be “no effects” for black-footed ferrets from the 

implementation of the proposed activity. 

Gray Wolf (Canis lupus; Endangered Species) 

The gray wolf on the LMNG is very rare and is not known to occur on the MRD at this time. 

North Dakota sightings of wolves are probably young wolves dispersing from Canada, or 

perhaps Minnesota. It appears that most wolf dispersal occurs during winter (Licht 1994). 

There are several variables that affect gray wolf establishment. These are road densities, human 

population densities, forested areas, and the percentage of crop or pasture acres. The approximate 

road densitiy on the MRD is 1.3 mile per section. Although there may be caveats (e.g. type of 

road), this exceeds the apparent tolerance level in wolf habitat that varies from .3 to 1.1 miles of 

road per square mile (Licht 1994 and Johnson 1999). Areas where human population densities 

are approximately 10 people per square mile are probably unsuitable. Population densities for 

Billings and Slope Counties are one person per square mile. However, the industry-based nature 

of the human population insures that people are on the ground a good part of the time and that, 

coupled with the open nature of the landscape, would likely render the region and area unsuitable 

for wolves. Johnson (1999) suggests that wolves have trouble establishing territories in areas 

where average crop and pastureland exceeds 27 percent of land area and where forest cover is 

less than 60 percent of land area. The NGP FEIS shows that the Great Plains, in general, exceeds 

the 27 percent cropland and pastureland percentage and forest cover is below 10 percent. 

Under all alternatives: Any proposed changes to livestock management from this project will 

have no effect on wolf habitat variables. Though wolves have dispersed significant distances 

from Minnesota and Canada into the Dakotas (Licht 1994), existing habitat is marginal at best. 

Due to the extremely rare sightings of Gray Wolf in North Dakota, let alone the LMNG, it is not 

possible to establish potential or suitable habitat or a population for the wolf. There are no 

critical habitat areas designated for wolves in ND. The Forest Service Wildlife Biologist 

determined that there will be “no effects” to the gray wolf from this project proposal. 

On the LMNG there are no federally listed T&E wildlife species. There is no designated critical 

wildlife habitat and there are no wildlife species proposed for federal listing nor is there any 

proposed critical habitat associated with the proposed project. The Forest Service Wildlife 

Biologist has determined the proposed project, under all alternatives, would have “No Effect” on 

T&E species therefore this issue is dropped from further consideration in this analysis. 
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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 Biological Evaluation which is located in Appendix D of the Wildlife 

Report. The Wildlife Report is located in the Project Record. The table below summarizes 

information for each species. 

Table 2.1 Summary of sensitive species, management indicator species (MIS) and raptor information 

1. Species 

2. Designation1

3. Habitat on or Near 

LMNG 

4. 2

Occurren

ce within 

Analysis 

Area 

5. Pot

ential for 

Project 

Area 

Impacts on 

Habitat or 

Population 

6. 3Effects 

Call 

Bald Eagle 

(Haliaeetus 

leucocephalus) 

S 

Large trees for perching and roosting, 

areas with carrion, small mammals or 

fish. Use at this time is restricted to 

migration.. 

UQ None All Alt’s: 

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. 

UQ None All Alt’s: 

No Impact 

Baird’s Sparrow 

(Ammodramus 

bairdii) 

S Idle native or tame grasslands or 

lightly to moderately grazed pastures. Known High 

Alt’s 1,2: May 

impact 

Alt’s 3,4: Beneficial 

(with adaptive 

actions over time) 

Burrowing Owl 

(Athene cunicularia) S 

Well drained, gentle grassland with 

sparse vegetation; usually rely on 

burrowing mammals for nest sites; 

prairie dog colonies not known in 

project area. 

UQ None All Alt’s: 

No Impact 

Loggerhead Shrike 

(Lanius ludovicianus) S Open habitat with low stature grasses 

and forbs and shrubs or low trees. Likely Moderate 

Alt’s 1,2: May 

impact 

Alt’s 3,4: Beneficial 

(with adaptive 

actions over time) 

Long-billed Curlew 

(Numenius 

americanus) 

S Expansive, open, gentle grassland with 

short vegetation. PSH Low All Alt’s: May impact 

Sprague’s Pipit 

(Anthus spragueii) S Grasslands of intermediate height and 

sparse to intermediate vegetation. K High 

Alt’s 1,2: May 

impact 

Alt’s 3,4: Beneficial 

(with adaptive 

actions over time) 

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 Alt’s: May 

impact 

Dakota Skipper 

(Hesperia dacotae) 

S Undisturbed tallgrass to mixed grass 

prairies; East: low (wet) bluestem 

prairie; West: upland (dry) prairie 

UQ None All Alt’s: 

No Impact 
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1. Species 

2. Designation1

3. Habitat on or Near 

LMNG 

4. 2

Occurren

ce within 

Analysis 

Area 

5. Pot

ential for 

Project 

Area 

Impacts on 

Habitat or 

Population 

6. 3Effects 

Call 

dominated by bluestems and 

needlegrasses. 

Ottoe Skipper 

(Hesperia ottoe) S Undisturbed mid-grass to tall grass 

prairie, drier sites/hilltops. PSH Moderate 

Alt’s 1,2: May 

impact 

Alt’s 3,4: Beneficial 

(with adaptive 

actions over time) 

Regal Fritillary 

(Speyeria idalia) S Tallgrass to mixed grass bluestem 

prairies. UQ None All Alt’s: No Impact 

Tawny Crescent 

(Phyciodes batessi) S 

North-facing or other mesic sites – 

green ash forest margins that border 

bluestem prairie. 

K Moderate 

Alt’s 1,2: May 

impact 

Alt’s 3,4: Beneficial 

(with adaptive 

actions over time) 

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 Alt’s: 

No Impact 

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 Alt’s: 

No Impact 

Golden Eagle R Nests: Trees, Cliffs; Prey: 

opportunistic K Low No Measurable Impacts 

Prairie Falcon R Cliffs UQ None All Alt’s: 

No Impact 

Merlin R Forested draws PSH Low All Alt’s: 

No Impact 

Ferruginous Hawk R Nests: Isolated buttes, trees, etc UQ None All Alt’s: 

No Impact 

Sage Grouse 

(Centrocercus 

urophasianus) 

S & 

MIS Sagebrush shrubland. UQ None All Alt’s: No Impact 

Black-tailed Prairie 

Dog 

(Cynomys 

ludovicianus) 

S & 

MIS 

Gentle grassland terrain; short grass 

communities; not forested or wet. K/P Low All Alt’s: May impact 

1

S=Sensitive, MIS=Management Indicator Species, R=Raptor 2K=Known, P=Possible, PSH=Potential Suitable 

Habitat, UQ=Unlikely or Questionable. May Impact =May impact individuals but will not lead to federal listing or a 

loss of viability in the planning area. 

Effects to the sensitive species listed above indicate that the alternatives will have no impact, be 

beneficial, or they may affect individuals of a population however, the viability of those 

populations is not threatened. Because the alternatives will not have a significant adverse effect 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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on the sensitive species identified above they are dropped from further consideration in this 

analysis. 

All but one of the listed raptors would not be impacted by the alternatives. The alternatives may 

effect golden eagle habitat and hence prey diversity in potentially beneficial and adverse ways. 

Alternative 1 would improve upland and woodlands conditions the quickest, but as time 

progresses a homogenous landscape may appear limiting prey species diversity. Alternative 2 

may see a decreasing diversity of prey species particularly on the Rolling Prairie, unless prairie 

dogs become established. Alternative 3 assumes minor improvement in uplands and woody 

draws and, hence, prey diversity would have some marginal benefit to golden eagles. Alternative 

4 is assumed to initially improve the diversity of habitat conditions more quickly than 

Alternative 3 and hence prey species diversity. Currently, the golden eagle is not of concern in 

the project area. The alternatives may have minor effects, both beneficial and adverse, however, 

there is no significant adverse effect the eagles in the project area or their habitat. Therefore this 

issue is dropped from further consideration in this analysis. 

There are three MIS species for the DPG: sage grouse, Blacktailed prairie dogs and sharp-tailed 

grouse. Sharp-tailed grouse will be addressed in Chapter 3. The closest known sage grouse occur 

approximately 35-40 air miles southwest of the project area and there are insufficient amounts of 

habitat in the project area to support a sage grouse population. There is one very small prairie 

dog colony in the project area, which due to its small size, is subject to stochastic events that may 

remove it from the landscape. Under Alternatives 2-4 there is potential habitat for future 

populations, Alternative 1 would likely see a reduction in potential habitat. The biological 

evaluation (BE) identifies that all alternatives “may impact individuals but will not lead to a 

federal listing or loss of viability in the planning area, therefore this issue is dropped from further 

consideration in this analysis.” 

Alternatives Considered in Detail 

The IDT for this project considered the following elements in the development of the action 

alternatives: Key issues; The purpose of and the need for this project 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 other agencies during the scoping process; The 

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

The Forest Service is also required, under the Council for Environmental Quality (CEQ) 

regulations, to develop and analyze a No Action Alternative. The No Action alternative would 

terminate all livestock grazing on federal lands in the project area. 

A total of four alternatives were developed for this analysis. 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. 
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Alternative 1 

The Council for Environmental Quality (CEQ) regulations for implementing the National 

Environmental Policy Act (NEPA) requires 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 no permitted livestock grazing (USDA Forest Service 1996; 

Forest Service Handbook [FSH] 2209.13). 

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 grazing permitted 

livestock in the analysis area. Pursuant to Forest Service Handbook (FSH) 2209.13, Section 

16.24, this alternative could not be implemented until two years after the notification of each 

affected permittee (36CFR 222.4(4)(1)). No permits would be issued for any of the 43 affected 

allotments. Since livestock grazing would no longer be permitted under this alternative, no 

mitigation measures for riparian habitat, woody draw, herbaceous structure or composition 

would be completed. However, restoration projects could be planned and implemented but that 

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. All fences, except Forest boundary fences or allotment boundary fences adjacent to 

other active grazing allotments, and any water developments not needed for wildlife or other 

purposes, would be removed. 

Treatment strategies for noxious weeds would be in compliance with direction outlined in the 

March 2007 Noxious Weed Management Project FEIS for the Dakota Prairie Grasslands. 

Alternative 2 

Allotment Management Plans (AMPs) would be developed for the 43 allotments in the project 

area. Current management for each allotment is identified in Appendix C. There would be no 

changes in authorized use numbers of livestock, permitted season of use, kind or class of 

livestock, or grazing system (other than minor changes made, by exception, in the Annual 

Operating Instructions (AOI). 

Alternative 3 

The Proposed Action was developed in conjunction with the Medora Grazing Association 

(MGA) and the individual permittees associated with the allotments in the project area. This is 

consistent with the September 2006, Livestock Grazing Record of Decision (ROD) for the 

Dakota Prairie Grasslands Plan and provisions of the “Demonstration Project” contained within 

the ROD. 
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Alternative 3 is an adaptive management based alternative. As identified in Chapter 1, Adaptive 

Management is: the process of making use of monitoring information to determine if 

management changes are needed, and if so, what changes, and to what degree. The goal of this 

alternative is to achieve site-specific desired resource conditions in accordance with the 

Grasslands Plan resource direction. Appendix A contains a set of Allotment Summary Sheets, 

one for each allotment in this analysis. The summary sheets identify resource issues, the existing 

condition of that resource on the allotment and a need for action if the resource is not meeting 

Grasslands Plan resource direction. Also contained on the summary sheets is a set of initial 

actions and adaptive options developed to address identified resource concerns. Taken together, 

the initial actions and adaptive options create the proposed action for that individual allotment. 

A key component of this alternative is monitoring, as it is the driving factor which determines if 

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

allotment is identified as “Initial Actions” on the Allotment Summary Sheets. If monitoring 

indicates that the initial actions are not meeting or moving a resource towards desired condition, 

then adaptive options can be applied. The decision to implement management changes would be 

the responsibility of the District Ranger. Monitoring is discussed in detail later in this chapter. 

The type, frequency, and duration of monitoring on each allotment is identified in the Allotment 

Summary Sheets. 

If for some reason initial or adaptive management action(s) identified in the Allotment Summary 

Sheets cannot be implemented as planned, then an team comprised of different specialists, the 

affected permittee, and affected Grazing Director, would recommend to the District Ranger a 

possible course of action(s) based on the Grazing Management Toolbox (see Table 2.2). For 

example, allotment A contains an initial or adaptive 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, for economic reasons it becomes unfeasible to develop the well 

and facilities in the reasonably foreseeable future. However, 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 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. 
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Table 2.2 Grazing Management Toolbox. 

Implement Dakota Prairie Grasslands drought management strategy 

Adjust season of use 

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

Adjust AUMs based on average cow size 

Utilize non-native grass pastures early to defer grazing on native grasses 

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

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

species 

Rest for one or more seasons 

Reallocation of pastures (change allotment boundary) 

Construct temporary fence to control livestock distribution patterns 

Construct and/or remove cross fences 

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

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

Manage water availability/access at water developments 

Maintain existing developments to reestablish use 

Implement deferred grazing system 

Implement rest-rotation grazing system 

Implement twice-over grazing system 

Incorporate private “off permit” land into rotation 

Fertilize crested wheatgrass areas 

Hay or cut-&-leave crested wheatgrass areas 

Interseed pasture with native grass species 

Scarify clubmoss areas within a pasture 

Implement prescribed burns 

Mechanical brush management 

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

Manage salt and supplement locations 

Construct fence to create riparian unit – allow grazing under riparian grazing dates 

Implement BMPs for riparian pastures 

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

Construct/harden stream crossings 

Construct water gap to limit livestock access on stream 

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

etc.) 

Move winter feeding areas off of National Forest System lands 

Utilize biological controls for noxious weed control in woody draws 

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 to the extent that their 

implementation is consistent with the effects documented in this EIS and its accompanying 

Record of Decision. Grasslands Plan standards and guidelines, the Watershed Conservation 

Practices Handbook (FSH 2509.25), and Project Design Criteria are incorporated by reference. 
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Alternative 4 

Alternative 4 is an adaptive management alternative that is similar to Alternative 3 in some 

respects. The IDT reviewed the initial and adaptive actions identified in Alternative 3, 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. This 

alternative also establishes authorized use based on estimated livestock carrying capacities and 

accounts for changes in animal unit forage demands with changes in cow/calf size, i.e., animal 

weight. The Allotment Summary Sheets located in Appendix A identify 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. 

Design Criteria Common to All Alternatives 

Design criteria (Table 2.3) are actions designed into the Proposed Action and action alternatives 

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 2.3 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. 

o On inventory permits, early turnout on native pastures is allowed one out of three 

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: 

3⁄4 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 

needed. 

3⁄4 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. 

3⁄4 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. 
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• If stocking rate adjustment are needed, annual reductions will generally not exceed ten 

percent. 

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

• When drought conditions occur the Dakota Prairie Grasslands, 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. 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 utilizing native weed seed free 

mixtures prescribed by the Forest Service Botanist. 

• Burn plans will be developed and approved for all prescribed fires prior to implementing onthe-ground actions. 

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

growing season to ensure regrowth of forage species. 

• 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. 

Alternatives Considered but Dropped from Detailed Analysis 

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 difference 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 ID T’s recommendation to consolidate Alternatives 4 

and 5, thus Alternative 5, as a separate alternative, was dropped from consideration in this 

analysis. 

Monitoring 

Monitoring includes both Forest-level and project-level analysis and evaluation. Forest-level 

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 EIS. 
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Monitoring and evaluation are key elements of adaptive management. 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. Also refer to discussion of adaptive management in Chapter 1. 

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

allotment i.e. implementation 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 Record of Decision for this project) are being 

applied, while effectiveness monitoring will evaluate how effective management actions are at 

moving toward, achieving, or maintaining desired conditions. If a management action is 

determined not to be effective, the monitoring will trigger implementation of an adaptive 

management action. 

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, and green ash woody draws will be the focus of effectiveness monitoring. 

The Allotment Summary Sheets located in Appendix A identify 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. The Forest Service conducts this type of monitoring 

through administration of the grazing authorization (permit). Administration includes inspection 

of the project area. The Forest Service would evaluate whether livestock management was in 

compliance with the grazing authorization, including the AMP and Annual Operating 

Instructions (AOI), which are part of the authorization. 

Allotment Management Plan (AMP): 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 conditions (as selected in the Record of 

Decision for this project and consistent with Grasslands Plan direction). 

Compliance with Annual Operating Instructions (AOI): The AOIs implement the AMP and 

clearly explain how each allotment is to be managed on a year-to-year basis. These instructions 

become part of the Grazing Permit for each permittee and responsibility for carrying out the 

instructions is a requirement of the permit holder. The AOIs include instructions for pasture 

rotations, kind and numbers of livestock to be grazed, pasture entrance and exit dates (subject to 

not exceeding standards), standards for and determination of allowable use, improvement 

maintenance and construction, and general allotment operating procedures. Checks through out 
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and following the grazing season, including discussions with the permit holder, will be used to 

evaluate compliance with the AOI. 

Effectiveness (Long-Term Trend) Monitoring 

Effectiveness monitoring is long-term monitoring which 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, herbaceous composition and structure, 

and green ash woody draws will be monitored on each allotment using the methods described in 

Table 2.4 below: 

Table 2.4 - Displays the effectiveness monitoring schedule that would be followed if an action 

Alternative is selected. 

Monitoring Item Method General 

Frequency

Trigger By Whom

Herbaceous 

Structure

VOR Annually for some 

allotments, every 3rd year 

for others 

See Trigger Point 

Section below 

USFS/MGA/Others 

Riparian PFC Every 5 years See Trigger Point 

Section below 

USFS/MGA/Others 

Green ash hardwood 

woody draws 

Sapling Density Every 5 years See Trigger Point 

Section below 

USFS/MGA/Others 

Plant composition 

(seral stage) 

NDSU Ecological 

Sites and/or 

NRIS TERRA 

Every 3 to 5 years See Trigger Point 

Section below 

USFS/MGA/Others 

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, in 

conjunction with the allotment permittee, and affected Grazing Director will review the 

monitoring data and other pertinent information to determine if a management adjustment is 

needed. If it is determined that an adjustment(s) is needed, the team will review the adaptive 

management options identified in the Allotment Summary Sheets and/or the “Toolbox” and 

recommend a course of action(s) to the District Ranger. 
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It is important to note that hitting a trigger point doesn’t necessarily mean a change is needed. A 

review of the monitoring information may show that acceptable progress is being made but a 

longer timeframe is needed to accomplish the desired resource condition. 

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 

(PFC). PFC assesses and classifies riparian as being (in): Proper Functioning Condition (PFC), 

Functional—At Risk, with either an upward or downward trend, and Non-functional. 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 2.5 identifies the triggers associated with riparian 

monitoring. 

Table 2.5 – Riparian Monitoring Trigger Points 

Existing Stream Condition 

Trigger Point 

Fifth year post implementation of 

initial management actions 

Trigger Point 

10 year post implementation 

Nonfunctional 

(NF) 

Stream has not improved to FAR 

status. Determine which processes are 

nonfunctional and what the cause(s) 

are. Identify management 

modifications. 

If stream has not improved to FAR-U 

status. Determine which processes are 

nonfunctional and what the cause(s) 

are. Identify management 

modifications 

Functional At Risk--Downward 

Trend 

(FAR-D) 

FAR-U is not met. Determine which 

processes are functional at risk and 

what the cause(s) are. Identify 

management modifications. 

If stream is not at PFC, determine 

which processes are functional at risk 

and what the cause(s) are. Identify 

management modifications. 

Functional At Risk--Trend Not 

Apparent 

(FAR-NA) 

FAR-U is not met. Determine which 

processes are functional at risk and 

what the cause(s) are. Identify 

management modifications. 

If stream is not at PFC, determine 

which processes are functional at risk 

and what the cause(s) are. Identify 

management modifications. 

Functional At Risk--Upward 

Trend 

(FAR-U) 

If no management change is needed, 

continue to monitor stream. 

If stream is not at PFC, determine 

which processes are functional at risk 

and what the cause(s) are. Consider 

management modifications. 

Properly Functioning Condition 

(PFC) 

If no management change is needed, 

continue to monitor. 

If no management change is needed, 

continue to monitor. 
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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 2.6 

identifies the triggers associated with Herbaceous Structure monitoring. 

Table 2.6 - Herbaceous Structure Trigger Points 

If monitoring indicates that the existing structure condition on a grazing allotment is less than 

Tier I objectives, shown in Table 2.6, a three year period is allotted to meet the structure 

objectives of that tier. This is followed by another three year period to reach Tier II and a final 

three year period to reach Tier III, which is the Grasslands Plan desired condition for herbaceous 

structure. If existing condition structure is meeting Tier I objectives then there is a three year 

period to meet Tier II objectives and a final three years to meet Tier III objective. If existing 

condition is at Tier II the same process follows. If at the end of each three 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. 

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% 50-70% 10+% 

Structure Objectives 

not met at end of 

third year of 

monitoring. 

Sixth year post 

implementation 

(Tier II) 

15-25% 50-70% 15+% 

Structure Objectives 

not met at end of 

sixth year of 

monitoring. 

Tenth year post 

implementation 

(Tier III -Grasslands 

Plan Structure Objectives 

Met) 

10-20% 50-70% 20-30% 

Structure Objectives 

not met at end of 

ninth year of 

monitoring 
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Green Ash Woody Draws 

The long-term health of Green Ash woody draws will be monitored based on the number of 

surviving tree saplings. Researchers have noted a correlation between sapling survival and the 

condition of woody draws (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 associated with Green Ash woody draw 

monitoring. 

Table 2.7 – Green Ash Woody Draw Trigger Points 

Monitoring Frequency is 5 years 

Current Woody 

 Draw Rating 

Trigger Points 

1st Monitoring 

Trigger Points 

2nd Monitoring 

Unhealthy 

(averaged 61 *saplings per acre) **NA **NA 

At Risk 

(averaged 85 saplings per acre) 

Average number of saplings in a 

woody draw is less than 184 per 

acre. 

Average number of saplings in a 

woody draw is less than 359 per 

acre. 

Healthy 

(averaged 359 saplings per acre). 

Average number of saplings falls 

below 359 per acre. 

Average number of saplings falls 

below 359 per acre. 

*Saplings refer to tree species found in green ash hardwood draws that are greater than 2.5 feet in height and less 

than an inch in diameter. ** Unhealthy woody draws have reached a point where restoration would require 

extensive amounts of limited resources with unknown results, therefore it was decided to let the Unhealthy woody 

draws revert back to grasses or grass/shrubs over time. 

Plant Composition (Seral Stage) 

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 plant composition is the amount of the project area that is in each seral 

stage. The Grasslands Plan objectives for seral stages are 10 to 15 percent in early, 65-75 percent 

in mid and 15 to 20 percent in late seral. If early seral exceeds 15 percent and late seral is less 

than 15 percent at the end of a monitoring period than a review will be triggered. The results of 

the review will determine if management adjustments are needed. 
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Summary Comparison of Alternatives 

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

2.8 summarizes the ability of the alternatives to meet the Purpose and Need. Table 2.9 

summarizes the effects of the alternative by Key Issue. 

Table 2.8 Summary of how the Alternatives respond to the Purpose and Need. 

Purpose and Need Alternative 

1 

Alternative 2 *Alternative 3 *Alternative 4 

Allow grazing and 

provide forage 

No Yes Yes Yes 

Support ranching 

community 

No Yes Yes Yes 

Meet or move 

towards DFC for 

resources 

Resources 

would meet 

or show 

significant 

progress 

towards 

DFC in 10-

15 year time 

frame of this 

project. 

Herbaceous 

structure 

objectives, 

woody draw 

health, and 

riparian 

condition are 

expected to 

remain below 

Grasslands 

objectives for 

these 

respective 

resources . 

Herbaceous structure may see 

reduction in amount of low 

structure with a slight shift towards 

moderate, no gain expected in high 

structure. Woody draws would see 

varying degrees of improvement in 

about 44 percent of the At-Risk 

and Unhealthy. Riparian condition 

would improve in some allotments 

General concern that continuing 

existing levels of authorized use 

will negate the effects of proposed 

initial actions with some 

exceptions such as a riparian 

exclosures. 

Herbaceous structure 

movement would be 

into both moderate 

and high classes, 

although to what 

degree is unknown. 

Woody draws would 

see varying degrees 

of improvement in 

84 percent of AtRisk and Unhealthy 

woody draws. 

Riparian would see 

improvement in a 

greater amount of 

allotments. Concern 

that setting 

authorizing at 

carrying capacity in 

some allotments may 

need further 

adjustment. 

Provide for 

management 

flexibility i.e 

Adaptive 

Management 

No No Yes Yes 

*Both alternatives 3 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 between the two alternatives when considering the 

adaptive management portion of the alternatives is time. Alternative 4 takes more aggressive 

steps to address resource concerns than does Alternative 3. If under Alternative 3 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. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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Key issues and their indicator(s) by Alternative are shown in Table 2.9. Key issues were 

previously listed in this chapter. 

Table 2.9 Key Issue Comparison of the Alternatives. 

Alternatives. 

Key Issue Indicator(s) 1 2 3 4 

Herbacious 

Structure 

Percentage 

of structure 

in low, 

medium and 

high 

categories 

Would see 

increase in 

high structure 

and decrease 

in low 

structure. At 

some point in 

time system 

may become 

stagnated due 

to lack of 

herbivory 

Approx 19 

percent of 

allotments are 

meeting 

structure 

objectives. 

Remaining 

allotments 

typically are 

exceeding low 

structure, are 

meeting 

moderate 

structure but are 

not meeting high 

structure 

objectives.

In general the initial 

management actions 

under this alternative 

may move some 

structure from low to 

moderate, with little or 

no increase in high 

structure. However, 

several allotments that 

are close to meeting 

objectives may do so 

under this alternative. 

The remaining 

allotments not meeting 

objectives are not likely 

to achieve appreciable 

progress towards high 

structure objectives 

Adaptive actions over 

time would likely meet 

or move towards high 

structure objectives, 

however achieving 

appreciable progress for 

all below objective 

allotments within the 

timeframe of project is 

unlikely. 

In general the 

initial 

management 

actions under 

this alternative 

would likely 

move low 

structure into 

moderate and 

increase the 

amount of high 

structure. The 

percentage of 

movement into 

the moderate and 

high categories is 

unknown. 

Adaptive actions 

over time would 

likely provide a 

better 

opportunity then 

Alternative 3 to 

achieve structure 

objectives within 

the timeframe of 

this project. 

Woody 

Draws 

Woody draw 

condition 

class: 

Healthy, AtRisk, 

Unhealth 

Some heavily 

impacted 

hardwood 

woody darws 

would likely 

leave 

landscape. 

Most would 

eventually 

recover to a 

Healthy 

condition 

class.. 

Of sampled 

stands 52 

percent were 

healthy, 40 

percent were 

at risk and 8 

percent were 

unhealthy. 

Of the 43 allotments, 5 

have no woody draws 

and 6 are meeting 

objectives. Of the 

remaining draws 14 are 

predicted to improve and 

18 not improve. 

Of the 43 

allotments, 5 

have no woody 

draws and 6 are 

meeting 

objectives. Of 

the remaining 

draws 27 are 

predicted to 

improve and 5 

not improve 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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Riparian Properly 

functioning 

condition 

(PFC) 

Some streams 

would 

continue to 

function below 

PFC due to 

effects of 

roading and 

road ditches. 

Streams 

affected 

primarily by 

livestock 

would recover 

Of 54 miles of 

stream survey on 

11 streams show 

that 49.4 percent 

were at PFC, 

4.7percent 

FARUT, 4 

percent 

FARTNA, 5.4 

percent FARDT, 

and 36.5 percent 

NF. 

Would see some shift 

towards PFC in some 

allotments, however, 

continued stocking at 

current levels may offset 

beneficial effects of 

proposed initial 

management actions. 

Initial actions 

plus authorized 

use adjustment 

set at carrying 

capacity provides 

best opportunity 

to start 

improving 

impaired stream 

segments toward 

PFC. 

 Seral 

stage 

Percentage of 

project area in 

low, mid, and 

late seral 

stages. 

Overall, the 

removal of 

livestock 

grazing would 

result in shift 

towards late 

seral stages 

and decrease 

in early seral 

stages. 

However, 

Invasive 

grasses would 

have potential 

to move 

distribution 

towards early 

seral stage. 

Seral stage 

objectives are 

near objectives, 

but at risk due to 

an apparent 

increasing trend 

of invasive 

grasses. If trend 

continues seral 

stage 

distribution will 

be adversely 

effected. 

Same as Alternative 2 Seral stages 

objective are at 

risk, however, 

stocking to 

carrying capacity 

would assist in 

slowing the 

apparent trend of 

increasing 

invasive grasses. 

Drought Precipitation No drought 

strategy 

needed 

No drought 

strategy in 

place. Would 

adapt DPG 

strategy when 

complete. 

Would use McKenzie 

strategy until DPG 

drought strategy 

completed 

Would use 

McKenzie 

strategy until 

DPG drought 

strategy 

completed 

Economics Jobs and 

Income 

Loss of 20 to 

39 jobs and 

$359,497 to 

$708, 453 in 

income. 

20 to 39 jobs 

and income of 

$359,497 to 

$708,453. 

Possible gain of two jobs 

and an additional 

$55,405 in income over 

existing condition. 

Possible loss of 

two to six jobs 

and a loss of 

$17,213 to 

$87,702 in 

income over 

existing 

condition. 

Often in Allotment Management Planning analysis, a common question asked is how many cows 

would be permitted by alternative or what would the difference be in how many cows 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 alternative. 

The table below shows the AUMs by action alternative, which specialists used as a way to 

compare between alternatives and their effects in Chapter 3. 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

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Under Alternatives 2 and 3 authorized use is expressed in terms of AMs, however, Alternative 4 

authorized use is expressed in terms of AUMs. For comparison purposes in the table below the 

AMs under Alternatives 2 and 3 were converted from AMs to AUMs (Table 2.10) by 

multiplying the authorized use AM number (i.e. Preference Number) by 1.15 (see Grasslands 

Plan, Appendix I). This assumes that all of the animal units are larger cows within the range of 

1,100-1,300 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 again this is done for comparison purposes. 

Allotments 132A and 248 are expressed in AMs under Alternative 4 because they were meeting 

resource objectives and no adjustment to their proposed authorized use was needed. 

Alternative 3 and 4 are adaptive 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 AM/AUMs is one of the tools in the 

tool box that can be used (see Table 2.2 and other discussions on adaptive management). 

Table 2.10 Authorized Use relative comparison table 

NOTE DISCLAIMERS ABOVE.

Allot # Alternative 1 Alternatives 2 and 3 Alternative 4 

 AMs *AUMs AUMs 

126/128 0 2355 2708 1929 

127 0 412 474 384 

129 0 1090 1254 1090 

130 0 833 958 833 

131 0 273 314 273 

132A 0 176 202 176 AMs – Meeting Obj. 

132H 0 332 382 332 

133 0 272 313 196 

133D5 0 (Hay) 49 (Hay) 56 (Hay) 35 

134 0 254 292 220 

135 0 1559 1793 1559 

136/139 0 362 416 252 

140 0 281 323 232 

141 0 177 204 113 

142 0 167 192 106 

158 0 1566 1801 1347 

220 0 160 184 112 

221 0 246 283 174 

230 0 364 419 333 

237 0 288 331 236 

239 0 250 288 176 

240 0 809 930 809 

241 0 359 413 358 

243 0 375 431 347 

244 0 236 271 236 
Draft Environmental Impact Statement North Billings County Allotment Management Plan Revisions

2-28 

248 0 312 359 312 AMs – Meeting Obj. 

249 0 204 235 181 

256 0 1591 1830 1509 

258 0 2071 2382 1529 

272 0 1473 1694 1472 

277 0 1129 1298 1129 

278 0 272 313 230 

281 0 295 339 272 

282 0 2123 2441 2123 

283 0 300 345 300 

286 0 278 320 237 

287 0 579 666 513 

288 0 268 308 192 

289 0 1789 2057 1789 

300 0 486 559 486 

301 0 1666 1916 1509 

302 0 1044 1201 1027 

*Alternative 2 and 3 authorized AM use converted to AUMs.